The FAA rules specific to ELVs [Expendable Launch Vehicles] are a voluminous set of prescriptive and detailed regulations. FAA promulgated these ELV regulations almost 15 years ago by codifying the United States Air Force (USAF) requirements governing launch vehicle operations at Federal Ranges. FAA’s ELV regulations and their corresponding USAF requirements impose great oversight on vehicle programs. For example, these requirements allow FAA and Range officials to define the design of flight safety systems, and then to review and approve every step of test and verification…
They also require that the regulating authority approve production procedures and observe the installation of certain safety-related components. They must review and approve design changes or changes to test or operations procedures. Such oversight is not appropriate for the cadence of operations today’s commercial operators are trying to achieve.
That was Audrey Powers, Deputy General Council at Blue Origin on June 26, 2018 before the House Subcommittee on Aviation, “Hearing on Commercial Space Transportation Regulatory Reform.”
Here’s a bit more about how reusable launch vehicle [RLV] regulations are different:
Instead of telling the operator how to design, test, manufacture, and operate a vehicle, the operator presents a comprehensive safety case founded upon the process of identifying and controlling hazards. This performance-based approach allows the operator to present their design and describe the methods used to control risks… In short, the RLV regulations impose risk limits that an operator must meet, and the operator can choose any number of acceptable approaches.
Yet problems continued for RLVs because launching them at federal ranges still mandated the standards imposed on ELVs. This means RLVs lose the benefit of performance-based approaches at federal ranges like Cape Canaveral. Ms. Powers advocated that federal ranges should remove duplicating jurisdictions and impose only performance-based approaches to regulations.
One of the problems of reforming the system is that seemingly small or technical aspects of government regulations have enormous impacts on business and innovation. Usually it’s hard to see the impact without living it for years, and that doesn’t jive well with how the media operates based on simple story lines.
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