Experimental Permits, Anyone?

When implementing provisions of the CSLAA, FAA/AST is used to good feedback, like the planeload of comments it got in connection with the proposed Human Space Flight Requirements for Crew and Space Flight Participants. Seemed like everybody who was anybody in space transportation popped off in response to that widely read and ultimately well-received NPRM.

But as
Jon Goff alerts us, in connection with the companion rulemaking, Experimental Permits for Reusable Suborbital Rockets -- in which the FAA proposes application requirements for an operator of a reusable suborbital rocket to obtain an experimental permit; and operating requirements and restrictions on launch and reentry of reusable suborbital rockets operated under a permit -- industry folks have remained silent: So far no comments appear on DOT's docket site. Hmm.

For those waiting for the last minute, Jon reminds everyone that the deadline is May 30.

Remember, Congress intended that permits be "granted more quickly and with fewer requirements than licenses." Does this experimental flight permit regime "make it easier for an operator to launch"? What's your view of the regulatory burden this NPRM puts on developers of reusable suborbital rockets?

As to public safety, FAA explains that it "models its experimental permit regime for space transportation on the special airworthiness certificates granted to experimental aircraft. The FAA does not propose to require satisfaction of its risk criteria for a permit as it does for a license. Likewise, of all the system safety management and engineering requirements the FAA requires for a license, the FAA only proposes to require a hazard analysis to obtain a permit."

And FAA proposes to apply a "simplified version" of the three-pronged approach currently used to license the launch of reusable launch vehicles (RLVs).

What do you think of the exclusion of quantitative risk criteria, streamlining of system safety management and engineering, and operating requirements, and other provisions in this proposed rulemaking? Tell FAA/AST what you might prefer and why. And if you think the regulators are on target here, they like to hear that, too.

By the way, yes, this proposal ties in with the earlier NPRM: to conduct a reusable suborbital rocket launch or reentry with flight crew or a space flight participant on board, and applicant would have to demonstrate compliance with part 460, Human Space Flight Requirements.

If you have any questions, send a note to senior attorney Laura Montgomery at FAA, laura.montgomery@faa.gov. (But tell her you saw her e-mail address in the Federal Register, not on SLP ;).

True, all this may not be as engaging as actually building and flying 'em. Or as fun as, say, Jonny Bloggin'. Or, in my case, Jake Bloggin'. But as Jon Goff says, it's important ;)

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