# Presentation: 219040

## Office of Commercial Space Transportation 

**Office of Commercial Space Transportation **
- Experimental Permit
- Program Report

- Presented to: COMSTAC RLV Working Group
- By: Michelle Murray, AST-300, Experimental Permit Program Lead
- Date: May 15, 2008

## Outline

- Introduction To Experimental Permits
- What Is A Permit?
- How Was It Created?
- How Long Does It Take To Get A Permit?
- What Is The Permit Safety Strategy?
- What Other Regulations Apply?
- Maximum Probable Loss Determinations
- Experimental Permits Issued
- Permitted Launches
- Challenges

## What Is An Experimental Permit?

- Authorization issued by the FAA to allow an experimental reusable suborbital rocket to launch or reenter
- Alternative to licensing
- Valid for one year renewable term
- Permits are only issued for:
- Research and development
- Showing compliance with requirements to obtain a license, or
- Crew training

## How Was The Experimental Permit Created?

- The Commercial Space Launch Amendments Act of 2004 established an experimental permit regime
- The FAA published experimental permit regulations in April 2007
- Statutory Differences Between A License And An Experimental Permit

|  | Experimental Permit | RLV Mission License |
| --- | --- | --- |
| Review Period  | 120 day review period | 180 day review period |
| Compensation 
or Hire  | Compensation or hire is prohibited | Revenue generating launches are allowed |
| Indemnification | Launches are not eligible for indemnification | Launches are eligible for government indemnification for 3rd party liability greater than required financial responsibility |
| Transferability  | Permits are not transferable | Licenses are transferable |

## How Long Does It Take To Get An Experimental Permit?

- The FAA review period for an experimental permit is 120 days
- Complying with financial responsibility regulations takes an additional 30 days
- Applicants should submit a _complete enough_ application 150 days before their first launch

| Pre-application consultation 
(Submit draft application) | L-150+ days |
| --- | --- |
| Submit complete enough permit application  | L-150 days |
| Start of 120 day review period | L-150 days |
| Permit issuance | L-30 days |
| Submit proof of financial responsibility | L-30 days |
| First launch | L-0 days |

## What Is The Experimental Permit Safety Strategy?

- The safety strategy for permits consists of three elements:
- A Hazard Analysis
- Operating Area Containment
- Abiding by Operating Requirements

## What Is A Hazard Analysis?

- A hazard analysis is an integral part of a system safety engineering process to:
- Identify and eliminate hazards
- Reduce the associated risk to the public
- Typical elements of a hazard analysis include:
- Identifying and describing hazards
- Assessing risk using qualitative severity and likelihood levels
- Identifying and describing risk elimination and mitigation measures to reduce the risk to acceptable levels
- Demonstrating that the risk elimination and mitigation measures are correct, complete, and achieve an acceptable reduction in risk through validation and verification

## What Is Operating Area Containment?

**Operating Area**
- An operating area is an FAA approved three-dimensional region proposed by a permit applicant where permitted flights can take place
**Operating Area Containment**
- A permittee must operate its vehicle such that its instantaneous impact point (IIP) remains within an operating area and outside any exclusion areas
- The FAA requires an applicant to demonstrate, at a minimum, either that
- there are physical limits on the ability of the reusable suborbital rocket to leave the operating area
- the operator will use abort procedures and other safety measures to contain the IIP

## What Are Operating Requirements?

- Follow rest rules
- Establish safety clear zones
- Implement safety requirements derived from the hazard analysis
- Maintain hazard analysis validity
- Contain vehicle within the operating area
- Conduct all key flight-safety events in appropriate areas
- Use appropriately sized and cleared landing locations
- Comply with agreements
- Perform collision avoidance analyses above 150km

- Provide real time tracking of position and velocity
- Maintain communications with Air Traffic Control
- Record any communications affecting safety of the flight
- Implement launch commit criteria
- Abort the launch if it would endanger the public
- Prevent careless or reckless operations
- Record and report anomalies
- Report, respond to, and investigate any mishaps
- Abide by any additional requirement the FAA believes is necessary to protect public safety

- The operating requirements with which a permittee must comply while conducting permitted activities are outlined below:

## What Other Regulations Apply? 

- Other regulations may apply to permitted operations, including:
- Application Procedures
- Environmental
- Financial Responsibility
- Human Space Flight

## What is Maximum Probable Loss?

- The FAA requires financial responsibility for losses to the US government and third parties resulting from a permitted activity based on a maximum probable loss (MPL) analysis
- MPL is the greatest dollar amount of loss for bodily injury or property damage that is reasonably expected to result from a permitted activity

| Company Vehicle | Operating Area | US Gov Property | Third Party |
| --- | --- | --- | --- |
| Blue Origin PM-1 | West Texas | $0 | $3M |
| Armadillo MOD  | Oklahoma | $0 | $3M |
| Armadillo MOD & QUAD | HAFB without concurrent operations | $1.5M | $3M |
| Armadillo MOD & QUAD | HAFB with concurrent operations | $1.5M | $6M |
| Armadillo QUAD | Las Cruces Int’l Airport | $0.5M | $9M |
| Armadillo QUAD | Oklahoma | $0 | $3M |

**MPL Determinations for Permits**

## What Experimental Permits Have Been Issued?

- We have issued four experimental permits as shown in the table below:
- For the most up to date information:
- http://ast.faa.gov >> Launch Data & Vehicles>> Active Permits

| Company Vehicle | Permit | Issued | Effective | Expiration |
| --- | --- | --- | --- | --- |
| Blue Origin PM-1 | EP06-001 | 9/15/06 | 10/2/06 | 10/2/07 |
| Armadillo QUAD | EP06-002 | 10/17/06 | 10/18/06 | 10/21/06 |
| Armadillo QUAD | EP07-003 | 2/27/07 | 3/1/07 | 3/1/08 |
| Armadillo  MOD | EP07-004 | 10/18/07 | 10/18/07 | 10/18/08 |

**Experimental Permits Issued**

## How Many Permitted Launches Have There Been?

- http://ast.faa.gov >> Launch Data & Vehicles >> Recently Completed & Historical Launch Data

| # | Date | Vehicle | Company | Operating Area |
| --- | --- | --- | --- | --- |
| 1 | 10/19/06 | Pixel | Armadillo Aerospace | Las Cruces Int’l Airport |
| 2 | 10/20/06 | Pixel | Armadillo Aerospace | Las Cruces Int’l Airport |
| 3 | 10/21/06 | Pixel | Armadillo Aerospace | Las Cruces Int’l Airport |
| 4 | 10/21/06 | Pixel | Armadillo Aerospace | Las Cruces Int’l Airport |
| 5 | 10/21/06 | Pixel | Armadillo Aerospace | Las Cruces Int’l Airport |
| 6 | 11/13/06 | PM-1 | Blue Origin | West Texas Site |
| 7 | 3/22/07 | PM-1 | Blue Origin | West Texas Site |
| 8 | 4/19/07 | PM-1 | Blue Origin | West Texas Site |
| 9 | 6/2/07 | Pixel | Armadillo Aerospace | Oklahoma Spaceport |
| 10 | 6/2/07 | Pixel | Armadillo Aerospace | Oklahoma Spaceport |
| 11 | 10/20/07 | MOD-1 | Armadillo Aerospace | Oklahoma Spaceport |
| 12 | 10/27/07 | MOD-1 | Armadillo Aerospace | Holloman Air Force Base |
| 13 | 10/27/07 | MOD-1 | Armadillo Aerospace | Holloman Air Force Base |
| 14 | 10/28/07 | MOD-1 | Armadillo Aerospace | Holloman Air Force Base |
| 15 | 10/28/07 | MOD-1 | Armadillo Aerospace | Holloman Air Force Base |

## Challenges

- There are a number of challenges facing the FAA with respect to issuing experimental permits
- Below are the most pressing issues we are currently working to resolve
- Allowable Changes vs. Application Modification
- Methodology for determining MPL
- Safety Clear Zones
- Operating Areas
- Buffer Zones
- Regression and Software Testing
- 1st party vs. 3rd party

## For More Information

- Michelle Murray
- Experimental Permit Program Lead
- Michelle.Murray@faa.gov
- http://ast.faa.gov >> Licenses & Permits >> Experimental Permits

## Experimental Permits Report to COMSTAC

- Eight Maximum Probable Loss Determinations
- Third Party Ranged from $3-9M
- Government Ranged from $0-1.5M
- Four Experimental Permits Issued
- Fifteen Permitted Launches
- Challenges
- Allowable Changes vs. Application Modification
- Methodology for determining MPL
- Safety Clear Zones
- Operating Areas
- Buffer Zones
- Regression and Software Testing
- 1st party vs. 3rd party