Comments, compliments for FAA

XCOR has a lot of fans. It's a company used to praise.

And now, in its 17-page comment (dated Jan 31, 2006) in response to the FAA's
Notice of Proposed Rulemaking on Human Space Flight Requirements for Crew and Space Flight Participants, it was the rocket company's turn to give a little praise of its own. Before turning to its substantive comments on the proposed rules, XCOR took the opportunity to go on the record with these kind words for the FAA's space regulators:

We want to commend the FAA on this NPRM. There are numerous improvements, refinements, and clarifications to the draft guidelines. This is the best-crafted and most practical NPRM regarding launch vehicles that we have ever seen. Reading this NPRM, both XCOR reviewers were independently struck by the same pair of thoughts several times. "Hey, they listened to us," was followed by, "Hey, they heard us!" Reading the industry's comments on the draft guidelines, and then reading the NPRM, it is clear that in almost every case, the FAA listened to the industry's comments, understood the industry's comments, thought about the industry's comments, agreed with the industry's comments, incorporated the industry's comments into their thinking on the subject, and then recapitulated the industry's comments better than the industry had. This is excellent work.

The product of the process is very good regulation . . .. We are very pleased with how well this process has worked. If we were giving out letter grades to the FAA, this proposal would get an A-. . .. We know of no other government agency capable of demonstrating that level of excellence, and we commend the FAA for its work. . .. This NPRM is an example of government at its best.

The feds don't typically hear that sort of feedback from industry in public comments. (AST chief Patti Smith may have almost expected a dozen roses to go along with it. ;)

Randall Clague, government liaison for XCOR, then went on to flesh out the company's thoughts on "a few revisions" such as:

  • The definition of 'crew' needs to be addressed, so that non-safety-critical flight crew do not require inappropriate medical certification;
  • The regulations for environmental control need to be refined, so that systems which do not need both active monitoring and control are not required to be both monitored and controlled;
  • The exact language of the crew informed consent needs to be published; and
  • The Constitutional and statutory authority by which the FAA would prohibit space flight participants from carrying weapons on their flights needs to be explicitly cited and quoted.

    Interesting. (By the way, the company also "congratulate[s] the FAA for publishing this NPRM within twelve months of the CSLAA becoming law.") To read the full comment, and others submitted, go to the DOT's
    docket site, click on "simple search" and type 23449.

    noted a few initial comments last month; Jeff Foust also looked at some early comments here. Checking back in I see engineer Jon Goff of Masten Space Systems (not to mention his blog, Selenian Boondocks ;) has thoughtfully commented (with the reservation, "I wish we lived in a society where such regulation could be done by the industry itself, instead of being imposed by the government, but at least if we have to be regulated, I definitely prefer regulations that make sense, and don't require you to do things that aren't good ideas anyway." Yes.) Kent Ewing of TGV submitted comments; Aerospace Medical Association executive director Russell B. Rayman presented his view, and other folks commented so far.

    Remember, if you want to weigh in, the deadline is Feb. 27. (At the recent FAA conference SpaceX counsel Tim Hughes, for example, mentioned his company planned to offer some thoughts on the NPRM. I'll check back later to see what he and other interested parties may have submitted.)

    And if you don't comment, you can't complain.

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