Launch Site Safety Assessment Overview and Update

For launches from a Federal launch range, a license applicant typically contracts with the Federal 

launch range to provide launch services and property to satisfy some of the FAA’s regulatory 

requirements. In accordance with 14 CFR § 415.31, if the FAA has assessed a Federal launch 

range, through its launch site safety assessment (LSSA), and found that an applicable range 

safety-related launch service or property satisfies FAA requirements, then the FAA will treat the 

Federal launch range’s launch service or property as that of a license applicant’s and not need

further demonstration of compliance to the FAA. 

Per 14 CFR § 401.5, a Launch site safety assessment (LSSA) means an FAA assessment of a 

Federal launch range to determine if the range meets FAA safety regulations. A difference 

between range practice and FAA regulations is documented in the LSSA. 

The 14 CFR part 417 requirements for the launch of expendable launch vehicles were derived 

from the safety requirements of the Federal launch ranges. Some Federal launch range practices 

change over time. As these changes become known, the FAA holds discussions with the Federal 

ranges to clarify the changes from the previous practices that had been assessed, to determine 

whether the changes still meet FAA requirements and if that is not the case, identify the possible 

paths an applicant or current licensee may consider taking to meet those requirements. 

A record of these changes is tabulated and maintained in the following “Launch Site Safety reAssessment Matrix.” Hyperlinks to supporting documentation are provided in the matrix. This

matrix streamlines the LSSA process by identifying and evaluating some of the known or major 

changes in range practices that have occurred since the initial LSSA efforts and publication of 14 

CFR part 417 in 2006. This matrix will be updated as additional changes in range practices are

identified and the changes assessed to determine if an operator must request relief through an 

equivalent level of safety (ELS) or waiver, or have no impact to the FAA regulations. 

The “LSSA reAssessment Matrix” for identified changes in 

Federal Launch Range Practices, is accompanied by texts 

from referenced range documentation, for the reader’s 

convenience. Further following is a technical document of 

the FAA’s review of the identified changes to federal range 

current practices, for determinations of equvalent levels of 

safety. 

LSSreAssess Matrix for changes in

Federal Launch Range Practices
14 CFR 417 

Federal (U.S. Air Force or NASA) 

Launch Range's Requirement(s)  Noted Change(s) Affecting Respective Range Practice Path To Ensure Req't is Met

#

Year

Affected Section(s), w/Title or Brief Description

(For actual full FAA regulations under part 417, go to eCFR.gov) ER 

CCAFS

WR 

VAFB WFF Affected Section(s), w/Title or Brief Description

(Cells hyperlinked to view referenced text)

Brief description (Cells hyperlinked to FAA ELS Report or Federal Register)

AFSPCMAN 91-710 (2004): 

Vol. 6, Atch 7, Range Safety Launch Commit Criteria

A7.2.8. Launch Area Air and Sea Surveillance

AFSPCMAN 91-711 (2007): 

Ch 5, Sec 5.4.2. Hazardous Area Surveillance and

Control, 5.4.2.1. Surveillance Aircraft.

Ref Text in: Range Docs - Item N01

AFSPCMAN 91-217 (2010):

Ch 4, 4.6.6 Safe Separation – CA and COLA

AFSPCMAN 91-217 updated (2014):

Ch 4, 4.4.3 Launch Collision Aviodance (LCOLA)

AFSPCMAN 91-710 (2004):

Vol. 6, Atch 7, Range Safety Launch Commit Criteria

A7.2.3. Collision Avoidance

AFSPCMAN 91-711 (2007): 

Ch 3, Sec 3.8.18. Collision Avoidance Analysis

Equivalent Level of Safety for Launch Collision Avoidance (LCOLA):

The analysis of LCOLA is consolidated at the JSpOC, which works with both ER & WR. 

The ER and WR requirements meet or exceed FAA regulation § 417.107 (e), because 

they also protect for active satellites in addition to manned spacecraft. Each federal 

range also enforces COLA closures, as a launch commit criteria. 

Ref Text in: Range Docs - Item E01

Ref. FAA Review of Changes in Federal Range Practices for Determination of ELS: E-01, for 

Collision Aviodance

AFSPCMAN 91-710: 

Vol. 1, Ch 2, Responsibilities and Authorities: 2.3.5. 

Range Safety Offices. 

AFSPCMAN 91-711: 

Ch 3, FSA Policy and Processes: 3.1. AFSPC Launch

Safety Program

45 SW's newer practice to pre-process the trajectories is also used by the FAA. The 

pracitice is an equivalent level of safety . The 30SW conducts Flight Safety Analysis in 

accordance with their FSA Handbook. The 30SW FSA approach is consistent with the 

45SW, WFF and the FAA. The practice is an equivalent level of safety . WFF's 

processes are consistent with that used by FAA. The practice is an equivalent level of 

safety . 

 Both FAA and Ranges have adopted like, if not identical, analysis practices, at around 

the same time. 

Ref Text in Range Docs - Item E02

Ref. FAA Review of Changes in Federal Range Practices for Determination of ELS: E-02, for 

Flight Safety Analysis

LSSA Re-Assessments for Federal Launch Ranges: EWR - Eastern & Western Ranges (Cape Canaveral Air Force Station, CA and Vandenberg Air Force Base, CA), and NASA WFF (Wallops Flight Facility, VA) 

Focus is on 14 CFR part 417 requirements affected by changes in Federal launch range practices since part 417 was published in 2006. 

Subject 

ITEM ELS, 

WVR, 

or N/I?

Affected 

Range(s)

N 

01

2016

Sea & Air Surveillance



  

§ 417.111(b)(6) Launch plans: Flight Safety Plan

Support systems and services. Identification of any support systems

and services that are part of ensuring flight safety, including any

aircraft or ship that a launch operator will use during flight.

§ 417.111(j) Hazard area surveillance and clearance plan. (j)(2)

Describe how the launch operator will provide for day-of-flight

surveillance of the flight hazard area ...

Does not impact requirements. Part 417 does not mandate a type or model of 

aircraft, nor that an aircraft even be used, in conducting the required 

survelliances as called out in the Rule. As long as surveillance requirement is 

met through other means by the range, a reassessment with regard to LSSA is 

not necessary. 

ELS

When AFI 91-217, Space Safety and Mishap Prevention Program , was published

in 2010 (later updated in 2014), Space wings, in conjunction with the Joint Space 

Operations Center (JSpOC, USSTRATCOM), were instructed to protect on-orbit 

manned spacecraft and active satellites from collision with launched objects. 

On 22 Jul 2016, the responsibility for the COLA function was reassigned from 

JSpOC to 18th Space Control Squadron (18 SPCS, AFSPC). Space wings were to 

obtain Conjunction Assessments from the 18 SPCS to establish COLA holds in the 

launch windows to ensure safe separation criteria from manned and active orbital 

objects. It should also be noted that the AF COLA process includes screening for 

orbital debris, as well as manned/mannable and active satellites. 

Current practice now is for both ER and WR to comply with AFI 91-217 for launch

COLA requirements. The commercial launch operator launching from the federal 

ranges (ER & WR) will have a required minimum COLA analysis that is consistent 

with FAA regulation § 417.107 (e). The commercial launch operator may request 

more stringent analysis at its discretion. 

 

In 2016, the ER reduced use of helicopters (Sikorsky HH-3 “Jolly”) because 45SW 

Safety considered radar, AIS (Automatic Identification System), and Suretrak (a 

multi-sensor, fully integrated, data acquisition and display system) to be sufficient, 

and if a Range User does not want Safety to call a fouled range for a faulty radar 

return (wave showing up on a radar), then the User could pay for helicopter 

support. 

N/I

§ 417.107 (e) Flight safety, Collision avoidance analysis:

(1) A launch operator must ensure that a launch vehicle, any

jettisoned components, and its payload do not pass closer than 200

kilometers to a manned or mannable orbital object ....

Also § 417.231 and § A417.31 contain the requirements for

obtaining a collision avoidance analysis. 

2010

COLA

E

01

E

02

2013

FSA as conducted by ranges 

§ 417.203 Compliance,

(d) Analyses performed by a Federal launch range.

FAA will accept a flight safety analysis used by a Federal launch

range without need for further demonstration of compliance to the

FAA, if:

(1) Launch operator contracted with Federal launch range for

provision of flight safety analysis; and

(2) the FAA assessed the Federal launch range [via LSSA], and

found range's analysis methods satisfy requirements ... In this case,

FAA will treat Fed range's analysis as that of a launch operator.

  

45SW now uses the Trajectory Toolkit (TTK) to pre-process the trajectories 

received from the launch operators and creates the input files for its Range Risk 

Analysis Tool (RRAT). The FAA uses the same program. 

30SW is now doing the Flight Safety Analysis in-house, as opposed to it being 

done previously by contractor. The 30SW incorporation of previously contracted 

tasks onto the Government side is transparent to how they conduct trajectory 

analysis. 

WFF uses the following analysis tools: Joint Advanced Range Safety System 

(JARSS), BlastDFO (for Distance Focus Overpressure), and Launch Area Toxic 

Risk Assessment (LATRA). 

ELS

LSSreAssess Matrix for Changes in Federal Launch Range Practices, Rev 1 (09_27_2016) (links to ref sheets inactivated).xlsx LSSA of ID'd Chgs in Rng Prctcs 1 of 21
14 CFR 417 

Federal (U.S. Air Force or NASA) 

Launch Range's Requirement(s)  Noted Change(s) Affecting Respective Range Practice Path To Ensure Req't is Met

#

Year

Affected Section(s), w/Title or Brief Description

(For actual full FAA regulations under part 417, go to eCFR.gov) ER 

CCAFS

WR 

VAFB WFF Affected Section(s), w/Title or Brief Description

(Cells hyperlinked to view referenced text)

Brief description (Cells hyperlinked to FAA ELS Report or Federal Register)

LSSA Re-Assessments for Federal Launch Ranges: EWR - Eastern & Western Ranges (Cape Canaveral Air Force Station, CA and Vandenberg Air Force Base, CA), and NASA WFF (Wallops Flight Facility, VA) 

Focus is on 14 CFR part 417 requirements affected by changes in Federal launch range practices since part 417 was published in 2006. 

Subject 

ITEM ELS, 

WVR, 

or N/I?

Affected 

Range(s)

N 

01

2016

Sea & Air Surveillance

  

§ 417.111(b)(6) Launch plans: Flight Safety Plan

Support systems and services. Identification of any support systems 

and services that are part of ensuring flight safety, including any 

aircraft or ship that a launch operator will use during flight.

§ 417.111(j) Hazard area surveillance and clearance plan. (j)(2)

Describe how the launch operator will provide for day-of-flight 

surveillance of the flight hazard area ...

Does not impact requirements. Part 417 does not mandate a type or model of 

aircraft, nor that an aircraft even be used, in conducting the required

survelliances as called out in the Rule. As long as surveillance requirement is 

met through other means by the range, a reassessment with regard to LSSA is 

not necessary. 

In 2016, the ER reduced use of helicopters (Sikorsky HH-3 “Jolly”) because 45SW

Safety considered radar, AIS (Automatic Identification System), and Suretrak (a

multi-sensor, fully integrated, data acquisition and display system) to be sufficient,

and if a Range User does not want Safety to call a fouled range for a faulty radar

return (wave showing up on a radar), then the User could pay for helicopter

support.

N/I

AFSPCMAN 91-710: 

Vol. 6, Atch 7, Range Safety Launch Commit Criteria:

7.2.5. Natural and Triggered Lightning:

7.2.5.4. Natural and Triggered Lightning Launch

Commit Criteria:

45 SWI 15-101 (2 Dec 2015), 

Sec 6.7 Range Safety Natural and Triggered Lightning

Launch Commit Criteria (LCC), and 

Atch 14 Lightning Launch Commit Criteria, Lightning

Advisory Panel (LAP) Recommendation.

"Lightning Flight-Commit Criteria, Updated 

11/01/13": by 45 Weather Squadron (45 WS), in

support of LAP

Equivalent Level of Safety for Lightning Launch Comit Criteria (LLCC)

The changes made by the 45th Weather Squadron for the Eastern Range do not impact 

FAA requirements and provide an equivalent level of safety. As part of the EWR,

Vandenberg AFB is already updating its respective LLCC’s to reflect these changes. 

Also, the updated LLCC approaches as described here are easily transferable to any 

other federal range (e.g., Wallops Flight Facility, or Reagan Test Site), if they choose to 

adopt these approaches for their respective operations. In all instances, the approaches 

as described by the range do not impact FAA requirements and they do provide an 

equivalent level of safety.

Formalizing changes to the FAA's Lightning Flight Commit Criteria requires the FAA to 

initiate a rulemaking activity. The equivalent level of safety evaluation and process will 

suffice for these and future changes until a rulemaking activity is completed.

Ref Text in: Range Docs - Item E03

Ref. FAA Review of Changes in Federal Range Practices for Determination of ELS: E-03, 

Lightning Flight Commit Criteria

AFSPCMAN 91-710 (2004),

Vol 2, 1.6.9.1; Vol 6, Atch 7, A7.2.1.1.3.1.

Equivalent Level of Safety for Launch Area Tracking: 

The FAA's previously evaluated and accepted one tracking source from T-0 through 3 

seconds prior to MTE and two sources from 3 seconds prior to MTE to the end of Range 

Safety Responsibility as an equivalent level of safety. With flight history supporting GPS 

MT off of the pad, the Range now commits GPS at T-0 and can achieve one tracking 

source from T-0 through 3 seconds prior to MTE and two sources from 3 seconds prior to 

MTE to the end of Range Safety Responsibility for all FAA licensed launch vehicles.

Ref Text in: Range Docs - Item E04

Ref. FAA Review of Changes in Federal Range Practices for Determination of ELS: 

E-04, Launch Area Tracking

AFI 91-217, (18 Feb 2010): 

4.6.5 Launch Safety, Public & Launch Personnel Risk:

4.6.5.1.1. Public.

AFSPCMAN 91-710 (2004):

Vol 1, A4.3.5: Acceptable Risk Criteria

AFSPCMAN 91-711 (2007)

Ch 3, Sec. 3.6. Risk to General Public.

3.6.1, 3.6.1.2

Equivalent Level of Safety for Flight Safety, Public Risk (Expected Casualties, EC)

Part 417 was revised on 20 July 2016, whereby FAA requirements for risk no longer 

lags behind AF ranges. This final rule also revises the acceptable risk threshold for 

launch from an Ec of 30 × 10

-6

 for each hazard to an Ec of 1 × 10

-4

 for all three

hazards combined . Furthermore, this final rule expresses the revised Ec limit using 

the correct number of significant digits to properly represent the uncertainty in Ec 

calculations. This final rule changes the FAA’s collective risk limits for launch and 

reentry to more closely match the Ec standard currently used by the US Air Force and 

NASA for government missions, and to account for the level of uncertainty that exists in 

the Ec calculations.

Ref Text in: Range Docs - Item E05

E

03

2014

Lightning Commit Criteria

Apx G (G417); Lightning Commit Criteria, General 

(a) Provides flight commit criteria to protect against natural lightning

and lightning triggered by the flight of a launch vehicle. 

(b) The launch operator must employ: (1) Any weather monitoring

and measuring equipment needed to satisfy the lightning flight 

commit criteria; and (2) Any procedures needed to satisfy the LFCC

[Lightning Flight Commit Criteria].

(c) If a launch operator proposes alternative LFCC, it must...

demonstrate an ELS.

Apx G (G417.3): Definitions, Explanations and Examples 

[affected definitions below:]

"Thick cloud layer means one or more cloud layers whose combined 

vertical extent from the base of the bottom cloud layer to the top of 

the uppermost cloud layer exceeds 4,500 feet. Cloud layers are 

combined with neighboring layers for determining total thickness only 

when they are physically connected by vertically continuous clouds"

"Volume-averaged, height integrated radar reflectivity (VAHIRR) 

means the product, expressed in units of dBZ-km or dBZ-kft, of a 

volume-averaged radar reflectivity and an average cloud thickness in 

a specified volume corresponding to a point."







In the LAP's "Lightning Launch Commit Criteria" -- 45 WS made changes to 

lightning launch commit criteria: Complete removal of Volume Average Height 

Integrated Radar Reflectivity (VAHIRR) technique, replaced by improved 

Maximum Radar Reflectivity (MRR); and a change to Thick Cloud overlay rule:

1. 45SWI 15-101, A14.2 Definitions -- The VAHIRR technique has been removed

entirely from the LLCC document, and replaced with the MRR. Added Definition:

"Maximum radar reflectivity (MRR) means the largest radar reflectivity within a

specified volume that is associated with an evaluation point." [This term also

shows up in the Anvil Cloud (attached & detached) and Debris cloud sections]

2. 45SWI 15-101, sec. A14.10.4 -- Thick Cloud layer rule.

Range second update to Launch Area Tracking Requirements: 

 ER reverts back to previous launch area tracking requirements. Comes after 

engineering evaluation of historical GPS metric tracking performance off CCAFS 

pads, shows acceptable coverage, and MFCOs determining MTE-3 seconds does 

not provide sufficient reaction time. 

Previous Practice: Range Safety allowed for two tracking sources mandatory by

3 sec's prior to Minimum Time to Endanger (MTE). This change was necessary for 

GPS/TMIG (Global Positioning System/ Telemetry Inertial Guidance) equipped 

vehicles since GPS Metric Tracking was new and the Range did not have 

performance history necessary to commit GPS at T-0. Once GPS had 

demonstrated availabilty at T-0, the Range began to commit GPS at T-0 and the 

requirements were reverted back to 1 source at T-0 and a second NLT 3 seconds 

prior to MTE. 

Current Practice: One tracking source mandatory at T-0; two tracking sources 

mandatory by 3 seconds prior to MTE. 

417.113(c)(2)(iii) Launch safety rules, Flight-commit criteria.

(2) For a launch that uses a flight safety system, the flight-commit

criteria must ensure that the flight safety system is ready for flight.

This must include... (iii) The launch vehicle tracking system has no

less than two tracking sources prior to lift-off... [and] has no less than

one verified tracking source at all times from lift-off to orbit insertion

for an orbital launch, to the end of powered flight for a suborbital

Launch Area Tracking

launch

(Re-visited)

2015

E

04

E

05

2010

100x10-6

§ 417.107 (b) Flight safety, public risk criteria,

(1) ...total risk associated with the launch to all members of the

public, excluding persons in water-borne vessels and aircraft, does

not exceed an expected number of 1 × 10-4 casualties. The total risk

consists of risk posed by impacting inert and explosive debris, toxic 

release, and far field blast overpressure.

Air Force Instruction (AFI) 91-217, (18 Feb 2010) modified the requirements for

public risk on Air Force launch ranges for government launches to now be 0.0001 

(100 x 10-6).

AFSPCMAN 91-710 (current version 2004) having thus been amended, finds its

revised requirements are not in sync with current FAA requirements. 

 

ELS

ELS

ELS

LSSreAssess Matrix for Changes in Federal Launch Range Practices, Rev 1 (09_27_2016) (links to ref sheets inactivated).xlsx LSSA of ID'd Chgs in Rng Prctcs 2 of 21

Ref. FAA Review of Changes in Federal Range Practices for Determination of ELS: 

E-05, Public Risk Criteria (Expected Casualty)
14 CFR 417 

Federal (U.S. Air Force or NASA) 

Launch Range's Requirement(s)  Noted Change(s) Affecting Respective Range Practice Path To Ensure Req't is Met

#

Year

Affected Section(s), w/Title or Brief Description

(For actual full FAA regulations under part 417, go to eCFR.gov) ER 

CCAFS

WR 

VAFB WFF Affected Section(s), w/Title or Brief Description

(Cells hyperlinked to view referenced text)

Brief description (Cells hyperlinked to FAA ELS Report or Federal Register)

LSSA Re-Assessments for Federal Launch Ranges: EWR - Eastern & Western Ranges (Cape Canaveral Air Force Station, CA and Vandenberg Air Force Base, CA), and NASA WFF (Wallops Flight Facility, VA) 

Focus is on 14 CFR part 417 requirements affected by changes in Federal launch range practices since part 417 was published in 2006. 

Subject 

ITEM ELS, 

WVR, 

or N/I?

Affected 

Range(s)

N 

01

2016

Sea & Air Surveillance

  

§ 417.111(b)(6) Launch plans: Flight Safety Plan

Support systems and services. Identification of any support systems 

and services that are part of ensuring flight safety, including any 

aircraft or ship that a launch operator will use during flight.

§ 417.111(j) Hazard area surveillance and clearance plan. (j)(2)

Describe how the launch operator will provide for day-of-flight 

surveillance of the flight hazard area ...

Does not impact requirements. Part 417 does not mandate a type or model of 

aircraft, nor that an aircraft even be used, in conducting the required

survelliances as called out in the Rule. As long as surveillance requirement is 

met through other means by the range, a reassessment with regard to LSSA is 

not necessary. 

In 2016, the ER reduced use of helicopters (Sikorsky HH-3 “Jolly”) because 45SW

Safety considered radar, AIS (Automatic Identification System), and Suretrak (a

multi-sensor, fully integrated, data acquisition and display system) to be sufficient,

and if a Range User does not want Safety to call a fouled range for a faulty radar

return (wave showing up on a radar), then the User could pay for helicopter

support.

N/I

AFSPCMAN 91-710 (2004), 

Vol 1, Atch 4: A4.3.5, A4.3.7. 

Vol 6, Atch 7: A7.2.7.2.3.3., A7.2.8.1, A7.2.8.3.1.1 

AFSPCMAN 91-711: 

Ch 3, sec. 3.6.1, 3.7.4

Ch 5, sec. 5.4.3.2

A waiver will be required for transition from Hit Probabilities to Ec for waterborne 

vessels, for each licensed launch from ER or WR. Until a regulatory change is made in 

the future, a waiver must be issued for the affected mission to meet current FAA 

requirements [§§ 417.107 (b)(3) and B417.5(a)] . 

Ref Text in: Range Docs - Item W01 Ref. Fed Register 81 FR 28930 (May 10, 2016)

AFSPCMAN 91-710 (2004): 

Vol.2, Atch 3, A3.3.6. 

AFSPCMAN 91-711 (2007): 

Ch 3, Sec 3.8.7.2. 

The FAA coordinated with the USAF range safety teams, reviewed the recently 

identified limitations in the current process, and determined that while the practice is 

not in technical compliance with the FAA Rule, there is continued protection of the 

public through a risk analysis and meeting established AF and FAA risk criteria. 

Formalizing changes to the FAA's flight safety limits/impact limit line determinations will 

require the FAA to initiate a rulemaking activity. The waiver process will suffice for 

these and future changes until a rulemaking activity is completed.

Ref Text in: Range Docs - Item W02 Ref. Fed Register 81 FR 1470 (Jan. 12, 2016)

―Regulatory text has been paraphrased for the sake of brevity. The full text regulations can be found at AST's website (http://ast.faa.gov). ELS Practice is Equivalent Level of Safety to FAA Regulation

WVR Operator must submit a Request for a Waiver to Regulation

N / I No Impact. Does not violate, or is not applicable to, Regulation

―Some Range Practices have been operating under the 1997 EWR 127-1 "Range Safety Requirements" (last updated 1999), and have been "grandfathered" by 14 CFR Part 417, when the Rule was first published on 25 Aug 2007. The LSSAs that 

assessed those grandfathered practices as having met current FAA requirements, remain valid. As such, those range practices that are still grandfathered under EWR 127-1, are not included in this matrix.

LEGEND of DETERMINATIONS

Individual and Collective Aggregated Risk for Personnel in Waterborne Vessels 

(Concerning ship protection on day of launch.) 

Requirements establish launch commit criteria for waterborne vessels that are 

based on cumulative hit probabilities. 

 Implementation of the newer requirements prior to release of the updated 

regulation will result in non-compliance with the FAA's current requirements

 

417.213(d) [Constructing Impact Limit Lines] Designated debris

impact limits. The analysis must establish designated impact limit 

lines to bound the area where debris with a ballistic coefficient of 

three or more is allowed to impact if the flight safety system functions 

properly. 

Construct Impact 

Limit Lines

2016

W

02

WVR

WVR

§ 417.107 (b) Flight Safety - Public risk criteria. A launch

operator may initiate the flight of a launch vehicle only if flight safety

analysis performed under paragraph (f) of this section demonstrates 

that any risk to the public satisfies the following public risk criteria: ... 

(3) A launch operator must implement water borne vessel hazard 

areas that provide an equivalent level of safety to that provided by 

water borne vessel hazard areas implemented for launch from a 

Federal launch range. 

Apx B (B417.5(a)): Launch site hazard area. (a) General. A launch

operator must perform a launch site hazard area analysis that protects 

the public, aircraft, and ships from the hazardous activities in the vicinity 

of the launch site. The launch operator must evacuate and monitor each 

launch site hazard area to ensure compliance with §§ 417.107(b)(2) — 

(b)(3).

Ship Protection

2015

W

01

The Range Safety practices follow an internal range safety requirements 

document, AFSPCM 91-711 (Launch Safety Requirements for AFSPC 

Organizations, Feb 2007 ), directing that methodology for calculating ILLs on the 

ER and WR sets the boundary solution using a mean ballistic coefficient (beta) 

value for determining ILLs. 

Criteria are set for debris with a beta of 3 psf, but since it is a mean value, some 

debris with a beta greater than 3 psf can achieve range beyond the ILLs. 

Thus, the definition of "Flight Safety Limit" in 14 CFR 417.3 as well the 417.213(d) 

regulation cannot technically be met on either Range. 

 

LSSreAssess Matrix for Changes in Federal Launch Range Practices, Rev 1 (09_27_2016) (links to ref sheets inactivated).xlsx LSSA of ID'd Chgs in Rng Prctcs 3 of 21
Range Docs - Item N01

Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.111(b)(6) & (j) 

Vol 6, Atch 7: Range Safety Launch Commit Criteria

A7.2.8. Launch Area Air And Sea Surveillance:

A7.2.8.1, General Description. Areas to be cleared of boats and ships are defined by Flight Analysis and based on probability contours and/or

Toxic Hazard Zones, including known impact areas of jettisoned stages/bodies and destruct debris resulting from malfunction scenarios plus 

the areas and altitudes in which Toxic Hazards will exist. Areas defined by Notice to Airmen (NOTAM) and Notice to Mariners (NTM) are 

surveyed on launch day. 

A7.2.8.3.1.1 At the ER, if the sum total of the individual hit probabilities of all targets plotted within, or predicted to be within, the established

probability contours exceed 10-5, a launch hold or scrub may be initiated.

AFSPCMAN 91-711 (2007)

5.4. Launch Area Air and Sea Surveillance.

5.4.2.1. Surveillance Aircraft. Aircraft support for surveillance control is required for all launches at the ER and all pad launches at the WR.

5.4.2.2. Radar Surveillance. Where available, land-based range radars or other assets from assisting government agencies are required to

perform air and sea surveillance of the hazardous launch area.5.4.2. Hazardous Area Surveillance and Control.

AFSPCMAN 91-710 (2004), Vol 6, Atch 7

5.4.2. Hazardous Area Surveillance and Control.

LSSreAssess Matrix for Changes in Federal Launch Range Practices, Rev 1 (09_27_2016) (links to ref sheets inactivated).xlsx 4 of 21
Range Docs - Item E01

Sec. 4.6.6 SaRequirements Documents for Range Current Practices, as assessed under 14 CFR §417.107(e) 

Air Force Instruction (AFI) 91-217, Space Safety and Mishap Prevention Program (18 Feb 2010): Ch 4, Launch & Range Safety

4.6. Launch Safety.

4.6.6.1. The COLA process will be developed based on assessments that account for launch vehicle flight from launch through orbit insertion 

plus the required number of revolutions of the launched objects. The COLA process will account for:

4.6.6.1.1. The type of orbit the vehicle or component is injected into, operating in or passing through, and;

4.6.6.1.2. Its altitude exceeding the manned spacecraft or space asset altitude by the appropriate miss distance, and; 

4.6.6.1.3. Sufficient time for the launched objects to be cataloged in the Satellite Catalog. Launch objects include the launch vehicle, payload, 

jettisoned components and planned debris.

4.6.6.2. The Space Wings, in conjunction with the JSpOC, will protect on-orbit manned spacecraft and active satellites from collision with 

launched objects IAW DoDD 3100.10 and MAJCOM requirements. Space wings will obtain CAs from the JSpOC to establish COLA holds in 

the launch windows to ensure safe separation criteria from manned and active orbital objects based on the risk criteria specified in the following 

paragraphs.

4.6.6.2.1. This CA/COLA process will be used for all launch vehicles, ballistic missions and propagated debris with an altitude capability equal 

to or greater than 150 km.

4.6.6.2.2. A CA/COLA process will also be used for each launch vehicle component that does not immediately reenter after separation from 

the launch vehicle and/or spacecraft. 

4.6.6.2.3. The CA/COLA process will be used prior to the planned launch to protect cataloged manned and active orbiting objects from 

collision with launched objects. This process includes the computation of launch times that would result in violating either the appropriate miss 

distance or probability of collision IAW RCC 321.

4.6.6.2.4. Safe Separation for launch (CA/COLA) will cover the period of time from when the launched objects achieve an altitude greater 

than 150 km, and until they are catalogued by the JSpOC and become part of the orbital CA process or until surface impact for suborbital 

launches.

4.6.6.2.5. If there is a deviation beyond the planned three-sigma trajectory, the launch wing is relieved of responsibility for any resulting 

collision with active or manned orbiting objects.

4.6.6.3. Safe Separation Criteria for Launch.

4.6.6.3.1. Manned Spacecraft. The risk to each on-orbit manned spacecraft from launched objects will not exceed a collision probability of 1  ́ 

10-6 (one in one million).

4.6.6.3.2. Active Satellites. The acceptable risk to active satellites from launched objects will be established by 14 AF, but should not exceed 

a collision probability of 10 x 10-6 (ten in one million).

4.6.6.3.3. Probability. Since CA and COLA based collision probability determinations require considerably higher fidelity range user data and 

can be costly, an acceptable alternative to the above criteria is to perform the assessment using more conservative miss distance volumes.

4.6.6.3.3.1. To mitigate the risk to manned spacecraft, either ellipsoidal miss distance volumes of 200 km in-track and 50 km cross-track 

and radially, or spherical volumes of 200 km may be used.

4.6.6. Safe Separation – CA and COLA [Conjunction Assessments and Collision Avoidance]. The appropriate wing commander is responsible for 

precluding any activity that would adversely affect active or manned spacecraft, based on a pre-launch COLA process identified by the MAJCOM. 

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4.6.6.3.3.2. For active satellites, 14 AF shall provide the appropriate conjunction assessment data to the launch wings to establish launch 

hold periods. A spherical miss distance volume of 25 km may be used to determine the appropriate launch hold periods. 

4.6.6.3.3.3. These criteria may be waived based on national need and operational considerations by a MAJCOM-approved authority.

4.6.6.4. The launching agency is responsible for the protection of manned spacecraft and active satellites from the end of the appropriate wing 

commander's (or equivalent) responsibility as defined above in paragraph 4.6.6.2 until separation of the last launch component, if there are 

additional orbital changes during this time.

AFI 91-217 UPDATE (17 April 2014): Ch 4, Launch & Range Safety

4.4 Launch Safety

4.4.3.1. Responsibilities. Launch operators/range users shall provide the launch wings and the Joint Space Operations Center (JSpOC) with 

planned flight profile data for all space launch vehicle and jettisoned components (to include upper stages pre-programmed for a controlled 

reentry, up until atmospheric reentry). Space Wing Commanders shall establish and enforce launch window hold periods, based on the LCOLA 

conjunction assessments computed by JSpOC against catalogued objects, and on safe separation of launched objects as defined by 

USSTRATCOM, IAW SD 505-1 V2, Space Surveillance Operations – Event Processing. For Air Force launches from non-Air Force ranges, the 

senior Air Force representative involved with the launch assumes responsibility of LCOLA risk management.

4.4.3.2. Timeframe. LCOLA shall cover the period of time from when launched objects achieve an altitude equal to or greater than 150 km, until 

location uncertainty makes performing a pre-launch safety COLA infeasible, or until the suborbital or reentry components descend to less than 

150 km.

4.4.3.2.1. There is currently a gap between the end of the launch COLA and the time when JSpOC can establish a reliable track of orbital 

components, plus the time when an active asset can respond to a JSpOC conjunction assessment. This is known as the “COLA gap” and is a 

recognized deficiency in LCOLA assessments. Programs shall use industry best practices to mitigate the COLA gap risk to manned objects.

4.4.3.3. Launch window hold periods. Determine the launch window hold periods based on one or a combination of the following methodologies 

and criteria:

4.4.3.3.1. Probability of Collision. The probability of collision between the launch components and manned objects shall not exceed 1 10-6 (one 

in one million). The probability of collision between the launch components and unmanned objects (to include active satellites and orbital 

debris) shall not exceed 10 x 10-6 (ten in one million). Reference RCC 321.

4.4.3.3.2. Safe Separation Distance. The safe separation distance for manned objects shall consist of either ellipsoidal miss distance volumes 

with semi-axes of 200 km in-track, 50 km cross-track, and 50 km radial; or spherical volumes with a radius of 200 km. The safe separation 

distance for unmanned objects shall consist of three-sigma ellipsoidal miss distance volumes calculated from the covariance data. Where the 

covariance data are not available, utilize a spherical miss distance volume with a radius of 25 km for active satellites and 2.5 km for debris.

4.4.3. Launch Collision Avoidance (LCOLA). All launches from Air Force ranges and all Air Force launches from non-Air Force ranges shall 

accomplish LCOLA procedures accounting for all launched objects (e.g., booster segments, payloads, jettisoned components, and debris) with an 

altitude capability equal to or greater than 150 km.

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Vol 6, Atch 7: Range Safety Launch Commit Criteria

A7.2.3. Collision Avoidance:

A7.2.3.1. General Description. A collision avoidance (COLA) analysis is used in the minus count to protect manned/mannable orbiting objects

from collision with a launch vehicle or its jettisoned components.

A7.2.3.2. Applicability. All launch vehicles with the potential to collide with manned/mannable

orbiting objects shall meet the following criteria:

A7.2.3.3. Collision Avoidance Launch Commit Criteria:

A7.2.3.3.1. The COLA program computes the closest approach between the launch vehicle and an orbiting object based on a miss distance 

screening criteria of 200 kilometers for manned/mannable objects.

A7.2.3.3.2. A COLA (no launch) closure time period is calculated for the defined miss distance for any object approaching within distances less 

than the above criteria.

A7.2.3.4. Offices of Primary Responsibility. 30 SW/SEY and 45 SW/SEO are the OPRs for determining COLA launch commit criteria.

A7.2.3.5. Reference Documents. Mission-specific COLA criteria shall be documented in the COLA Requirements letter by 45 SW/SEO and 30

SW/SEY.

AFSPCMAN 91-711 (2007)

3.8.18.1. Orbital Launch. For an orbital launch, the COLA analysis shall establish any launch waits needed to ensure that the launch vehicle, any

jettisoned components or propagated debris, and payloads do not violate the criteria in 3.6.1.6. for manned orbiting spacecraft during ascent to 

orbital insertion plus an analyst defined number of revolutions to account for the objects’ orbit type, its altitude exceeding the manned spacecraft 

altitude by the appropriate miss distance; and sufficient time for the object to be catalogued by the JSpOC (1 SPCS).

3.8.18.2. Suborbital Launch. For a suborbital launch, the COLA analysis shall establish any launch waits needed to ensure that the launch

vehicle, any jettisoned components or propagated debris, and any payload do not violate the criteria in 3.6.1.6. for manned orbiting objects 

throughout the flight.

3.8.18.3. Wing Safety shall document and provide to the SW Operations Group (Range) the mission-specific COLA results. This documentation

shall identify mission-specific launch wait periods and mission-specific COLA criteria including items such as the operations number, operation 

description, spacecraft evaluated, and encounter results.

3.8.18.4. Analysis Not Required. COLA analysis may not be required if the three-sigma maximum altitude capability of the launch vehicle,

jettisoned components or planned debris is greater than 50 km below the orbital perigee of a manned object.

AFSPCMAN 91-710 (2004, cert'd current 2014)

3.8 Flight Safety Analysis (FSA) 

3.8.18. Collision Avoidance (COLA) Analysis. A FSA shall include a COLA analysis that establishes each launch wait in a planned launch

window during which a Range User shall not initiate flight in order to protect any manned orbiting object. The analysis shall be performed on all 

components or propagated debris achieving altitudes greater than 150 km. Based on the COLA analysis, the FSA shall identify “launch wait” periods 

within the launch widow. The launch wait periods are no launch periods. Wing Safety shall ensure that the Range Users account for uncertainties 

associated with launch vehicle performance and timing and ensure that any calculated launch waits incorporate all additional time periods 

associated with such uncertainties. A Range User shall implement any launch waits as flight commit criteria.

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Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.203(d)

Vol 1, Chap 2. Flight Safety Requirements, Responsibilities and Authorities:

2.3 Space Wing Responsibilities:

2.3.5. Range Safety Offices. Unless otherwise noted, the use of the term Range Safety in this publication refers to 30 SW/SE and 45 SW/SE. 

The Range Safety Offices provide Systems Safety, Flight Safety Analysis, Pad Safety (45 SW), Mission Flight Control (30 SW), and direct 

support to the 1st Range Operations Squadron (1 ROPS) and 2nd Range Operations Squadron (2 ROPS) mission flight control function for all 

missions from the ranges. The Safety Offices also provide traditional Air Force ground safety programs. The responsibilities of the Chiefs of 

Safety or their designated representatives apply throughout all phases of a launch program (planning, generation, execution, and recovery) 

and include, but are not limited to, the following:

2.3.5.1. Enforcing safety requirements to ensure that public safety, launch area safety, and launch complex safety are adequately provided 

by and for all programs using the ranges

2.3.5.2. Evaluating, training, and approving Range Users who wish to assume “control authority” for launch complex safety in accordance 

with Attachment 7 of this volume

2.3.5.3. Providing oversight, review, approval, and monitoring for all public safety and launch area safety concerns during prelaunch 

operations at the launch complex and launch vehicle or payload processing facilities

2.3.5.4. Auditing operations at a launch complex and associated support facilities for launch complex safety concerns in accordance with a 

jointly accepted Launch Complex Safety Training and Certification program (Attachment 7 of this volume). If the Range User control 

authority decides not to or cannot implement the plan, Range Safety shall assume complete safety responsibility.

2.3.5.5. Reviewing and approving flight plans, design, inspection, procedures, testing, and documentation of all hazardous and safety critical 

launch vehicles, payloads, and ground support equipment, systems, subsystems, facilities, and material to be used at the ER and WR. 

Review and approval shall be in accordance with the requirements of volumes 2 through 6 of this publication. 

2.3.5.6. Flight Safety Review with the SW/CC. Prior to each launch, Range Safety shall brief the SW/CC of the safety status of the launch 

vehicle. The briefing shall include vehicle hazards, the status of any applicable waivers and any other issues that contribute to the risk of the 

flight. The briefing shall be in the format chosen by the SW/CC and may be accomplished at the Launch Readiness Review (LRR) or via a 

separate safety briefing.

2.3.5.7. Determining the need for and approving the airborne Flight Safety System (FSS); reviewing and approving the design, test, and 

documentation for airborne FSSs; monitoring and verifying the installation, checkout, and status of the flight termination system (FTS) in 

accordance with Range Safety instructions at locations designated by Range Safety

2.3.5.8. Determining criteria for flight termination action; assessing risks to protect the general public, launch area, and launch complex 

personnel and property; developing and using mathematical models to increase the effectiveness of errant vehicle control while minimizing 

restrictions on launch vehicle flight; establishing mission rules and criteria for flight termination action in conjunction with the Range User

2.3.5.9. Determining collision avoidance (COLA) launch hold requirements for mannable orbiting objects and providing the COLA 

requirements letter documenting mission specific criteria. AFI 91-202 provides additional requirements for minimizing risk of collision with 

other objects and for on-orbit collision avoidance; however, neither of these issues is the responsibility of the ranges. At present, the Safety 

Office is only interested in COLAs to mannable vehicle such as the International Space Station and the Space Transportation System from 

launch to orbital insertion.

AFSPCMAN 91-710 (2004), Vol 1

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2.3.5.10. Providing applicable Range Safety Operations Requirement (RSOR) and Operations Supplement (Ops Sup) documents; providing 

a Range Safety Launch Operations Approval Letter no later than the Launch Readiness Review (LRR) (45 SW/SE may provide a verbal GO 

instead); evaluating and issuing safety approval for personnel authorized to remain in hazardous launch areas; and providing the final Range 

Safety approval to launch

2.3.5.11. Providing certified Mission Flight Control Officers (MFCOs) and associated Range Safety support personnel for launch operations 

and, together with qualified personnel from 1 ROPS and 2 ROPS, exercise safety operations waiver authority as delegated by the SW 

Commander, monitor real-time launch vehicle progress, and act as the sole authority for the real-time determination and execution of flight 

termination

2.3.5.12. Supporting the Launch Disaster Control Group (LDCG ER)/Launch Support Team (LST WR) and advising the onsite commander 

regarding disaster preparedness and response and, as necessary or as requested, providing technical assistance in the event of failures 

and mishaps

2.3.5.13. Assessing Range Safety Critical Launch Commit Criteria for launch operations

2.3.5.14. Establishing a configuration control process for maintaining Range Safety documentation in a timely, technically correct, easily 

understood manner that is accessible to Range Users, including tailored Range Safety Requirements and standards developed jointly with 

other agencies

2.3.5.15. Ensuring safety is consistent with operational requirements, including the prevention of test objects from violating established limits 

through impact for vehicles with suborbital trajectories and through orbital injection/insertion or escape velocity for space vehicles (DoDD 

3200.11, paragraph 4.2.9.8.)

2.3.5.16. Ensuring public safety up until the time of flight at which the launch vehicle/spacecraft achieves a sustainable orbit or escape 

velocity for space vehicles, or through final impact for vehicles with suborbital trajectories and can be shown to pose no statistically 

significant additional safety risk

2.3.5.17. Approving or disapproving equivalent level of safety (ELS) requests.

AFSPCMAN 91-711 (2007)

Ch 3, FSA Policy and Processes

AFSPC operates two USAF-owned national ranges established under DoDD 3200.11, Major Range and Test Facility Base, for all users 

having a valid need for launch and test range capabilities. Operation of AFSPC ranges carries with it specific responsibilities for public and 

Launch Safety. The objective of this chapter is to codify the policy and requirements for the AFSPC ranges to ensure completion of the 

necessary flight safety analyses and associated approvals as a prerequisite for the launch of any vehicle or the conduct of any test from the 

ER or the WR.

3.1. AFSPC Launch Safety Program. 

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Requirements Documents for Range Current Practices, as assessed under Apx G to 14 CFR part 

Vol 6, Atch 7: Range Safety Launch Commit Criteria

A7.2.5. Natural and Triggered Lightning:

A7.2.5.1 General Description. Both natural and triggered lightning can cause launch vehicle malfunction and/or destruction. Triggered lightning is 

the phenomena associated with launch vehicles affecting the atmosphere during flight so that, under certain meteorological conditions, lightning is 

triggered and attracted to the launch vehicle.

. . . 

A7.2.5.4. Natural and Triggered Lightning Launch Commit Criteria:

A7.2.5.4.1. Lightning:

A7.2.5.4.1.1. Do not launch for 30 minutes after any type of lightning occurs in a thunderstorm if the flight path will carry the vehicle within 10 

nautical miles of that thunderstorm.

A7.2.5.4.1.2. Do not launch for 30 minutes after any type of lightning occurs within 10 nautical miles of the flight path. Unless:

A7.2.5.4.1.2.1. The cloud that produced the lightning is not within 10 nautical miles of the flight path; and

A7.2.5.4.1.2.2. There is at least one working field mill within 5 nautical miles of each such lightning flash; and

A7.2.5.4.1.2.3. The absolute values of all electric field measurements at the surface within 5 nautical miles of the flight path and at the mills(s) 

specified in A7.2.5.4.1.2.2 above have been less than 1,000 V/m (volts per meter) for 15 minutes. 

A7.2.5.4.1.3. Anvil clouds are covered in A7.2.5.4.3 below.

A7.2.5.4.1.4. If a cumulus cloud remains 30 minutes after the last lightning occurs in a thunderstorm, then the criteria in A7.2.5.4.2 apply.

A7.2.5.4.2. Cumulus Clouds. Cumulus clouds discussed below do not include altocumulus, cirrocumulus, or stratocumulus.

A7.2.5.4.2.1. Do not launch if the flight path will carry the vehicle within 10 nautical miles of any cumulus cloud with its cloud top higher than the 

–20oC level.

A7.2.5.4.2.2. Do not launch if the flight path will carry the vehicle within 5 nautical miles of any cumulus cloud with its cloud top higher than the 

–10oC level.

A7.2.5.4.2.3. Do not launch if the flight path will carry the vehicle through any cumulus cloud with its cloud top higher than the –5oC level.

A7.2.5.4.2.4. Do not launch if the flight path will carry the vehicle through any cumulus cloud with its cloud top between the +5oC and –5oC 

levels. Unless:

A7.2.5.4.2.4.1. The cloud top is not producing precipitation; and

A7.2.5.4.2.4.2. The horizontal distance from the center of the cloud top to at least one working field mill is less than 2 nautical miles; and

A7.2.5.4.2.4.3. All electric field measurements at the surface within 5 nautical miles of the flight path and at the mills(s) specified in 

A7.2.5.4.2.4.2 above have been between –100 V/m and +500 V/m for 15 minutes.

A7.2.5.4.3. Anvil Clouds:

A7.2.5.4.3.1. Attached Anvils:

A7.2.5.4.3.1.1. Do not launch if the flight path will carry the vehicle through nontransparent parts of attached anvil clouds.

A7.2.5.4.3.1.2. Do not launch if the flight path will carry the vehicle within 5 nautical miles of nontransparent parts of attached anvil clouds for 

the first 3 hours after the time of the last lightning discharge that occurs in the parent cloud or anvil cloud.

A7.2.5.4.3.1.3. Do not launch if the flight path will carry the vehicle within 10 nautical miles of nontransparent parts of attached anvil clouds for 

the first 30 minutes after the time of the last lightning discharge that occurs in the parent cloud or anvil cloud.

AFSPCMAN 91-710 (2004)

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A7.2.5.4.3.2. Detached Anvils. Detached anvil clouds are never considered debris clouds , nor are they covered by the criteria in A7.2.5.4.4.

A7.2.5.4.3.2.1. Do not launch if the flight path will carry the vehicle through nontransparent parts of a detached anvil cloud for the first 3 hours 

after the time that the anvil cloud is observed to have detached from the parent cloud.

A7.2.5.4.3.2.2. Do not launch if the flight path will carry the vehicle through nontransparent parts of a detached anvil cloud for the first 4 hours 

after the time of the last lightning discharge that occurs in the detached anvil cloud.

A7.2.5.4.3.2.3. Do not launch if the flight path will carry the vehicle within 5 nautical miles of nontransparent parts of a detached anvil cloud for 

the first 3 hours after the time of the last lightning discharge that occurs in the parent cloud or anvil cloud before detachment or in the 

detached anvil cloud after detachment. Unless:

A7.2.5.4.3.2.3.1. There is at least one working field mill within 5 nautical miles of the detached anvil cloud; and

A7.2.5.4.3.2.3.2. The absolute values of all electric field measurements at the surface within 5 nautical miles of the flight path and at the 

mill(s) specified in A72.5.4.3.2.3.1. above have been less that 1,000 V/m for 15 minutes; and

A7.2.5.4.3.2.3.3. The maximum radar return from any part of the detached anvil cloud within 5 nautical miles of the flight path has been less 

than 10 dBZ for 15 minutes.

A7.2.5.4.3.2.4. Do not launch if the flight path will carry the vehicle within 10 nautical miles of nontransparent parts of a detached anvil cloud 

for the first 30 minutes after the time of the last lightning discharge that occurs in the parent cloud or anvil cloud before detachment or in the 

detached anvil cloud after detachment.

A7.2.5.4.4. Debris Cloud:

A7.2.5.4.4.1. Do not launch if the flight path will carry the vehicle through any nontransparent parts of a debris cloud during the 3-hour period 

defined in the A7.2.5.4.4.3 below.

A7.2.5.4.4.2. Do not launch if the flight path will carry the vehicle within 5 nautical miles of any nontransparent parts of a debris cloud during the 

3-hour period defined in the A7.2.5.4.4.3 below. Unless:

A7.2.5.4.4.2.1. There is at least one working field mill within 5 nautical miles of the debris cloud; and

A7.2.5.4.4.2.2. The absolute values of all electric field measurements at the surface within 5 nautical miles of the flight path and at the mill(s) 

specified in a. above have been less that 1,000 V/m for 15 minutes; and

A7.2.5.4.4.2.3. The maximum radar return from any part of the debris cloud within 5 nautical miles of the flight path has been less than 10 dBZ 

for 15 minutes.

A7.2.5.4.4.3. The 3-hour period cited in A7.2.5.4.4.1 and A7.2.5.4.4.2 above begins at the time when the debris cloud is observed to have 

detached from the parent cloud or when the debris cloud is observed to have formed from the decay of the parent cloud top below the altitude of 

the –100C level. The 3-hour period begins anew at the time of any lightning discharge that occurs in the debris cloud.

A7.2.5.4.5. Disturbed Weather. Do not launch if the flight path will carry the vehicle through any nontransparent clouds that are associated with a 

weather disturbance having clouds that extend to altitudes at or above the 0oC level and contain moderate or greater precipitation or a radar bright 

band or other evidence of melting precipitation within 5 nautical miles of the flight path.

A7.2.5.4.6. Thick Cloud Layers:

A7.2.5.4.6.1. Do not launch if the flight path will carry the vehicle through nontransparent parts of a cloud layer that is:

A7.2.5.4.6.1.1. Greater than 4,500 feet thick and any part of the cloud layer along the flight path is located between the 0oC and the –20oC 

levels or

A7.2.5.4.6.1.2. Connected to a cloud layer that, within 5 nautical miles of the flightpath, is greater than 4,500 feet thick and has any part 

located between the 0oC and the –20oC levels.

Exception: The following exception applies to both A7.2.5.4.6.1.1 and A7.2.5.4.61.2 above: The cloud is a cirriform cloud that has never been associated 

with convective clouds, and is located entirely at temperatures of –15oC or colder, and shows no evidence of containing liquid water (e.g., aircraft icing).

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A7.2.5.4.7. Smoke Plumes. Do not launch if the flight path will carry the vehicle through any cumulus cloud that has developed from a smoke 

plume while the cloud is attached to the smoke plume, or for the first 60 minutes after the cumulus cloud is observed to have detached from the 

smoke plume. Cumulus clouds that have formed above a fire but have been detached from the smoke plume for more than 60 minutes are 

considered cumulus clouds and are covered in A7.2.5.4.2.

A7.2.5.4.8. Surface Electric Fields (ER Only):

A7.2.5.4.8.1. Do not launch for 15 minutes after the absolute value of any electric field measurement at the surface within 5 nautical miles of the 

flight path has been greater that 1,500 V/m.

A7.2.5.4.8.2. Do not launch for 15 minutes after the absolute value of any electric field measurement at the surface within 5 nautical miles of the 

flight path has been greater that 1,000 V/m. Unless:

A7.2.5.4.8.2.1. All clouds within 10 nautical miles of the flight path are transparent; or

A7.2.5.4.8.2.2. All nontransparent clouds within 10 nautical miles of the flight path have cloud tops below the +5oC level and have not been 

part of convective clouds with cloud tops above the –10oC level within the last 3 hours.

A7.2.5.4.8.3. Electric field measurements at the surface are used to increase safety by detecting electric fields caused by unforeseen or 

unrecognized hazards. For confirmed failure of one or more field mill sensors, the countdown and launch may continue.

A7.2.5.4.9. Electric Fields Aloft (ER Only). The criteria cited in A7.2.5.4.3, A7.2.5.4.4, A7.2.5.4.5, A7.2.5.4.6, A7.2.5.4.7, and A7.2.5.4.8.2 need 

not be applied if, during the 15 minutes prior to launch time, the instantaneous electric field aloft throughout the volume of air expected to be along 

the flight path, does not exceed EC where EC is shown as a function of altitude in Figure A7.1. The thresholds on electric field measurements at 

the surface in A7.2.5.4.8 and elsewhere in these LCC are lower than 5 kV/m (kilovolts per meter) to allow for the effect of the surface screening 

layer.

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A7.2.5.4.10. Triboelectrification. Do not launch if a vehicle has not been treated for surface electrification and the flight path will go through any 

clouds above the –10oC level up to the altitude at which the vehicle’s velocity exceeds 3,000ft/sec. A vehicle is considered “treated” for surface 

electrification if:

A7.2.5.4.10.1. All surfaces of the vehicle susceptible to precipitation particle impact have been treated to assure

A7.2.5.4.10.1.1. That the surface resistivity is less than 109 ohms/square; and

A7.2.5.4.10.1.2. That all conductors on surface (including dielectric surfaces that have been treated with conductive coatings) are bonded to 

the vehicle by a resistance that is less than 105 ohms; or

A7.2.5.4.10.2. It has been shown by test or analysis that electrostatic discharges (ESDs) on the surface of the vehicle caused by 

triboelectrification by ice particle impact will not be hazardous to the launch vehicle or the mission. In A7.2.5.4.10.1.1 above, the correct unit for 

surface resistivity is ohms/square. This means that any square area of any size measured in any units has the same resistance in ohms when 

the measurement is made from an electrode extending the length of one side of the square to an electrode extending the length of the opposite 

side of the square. The area-independence is literally valid only for squares; it is not true for other shapes such as rectangles and circles.

A7.2.5.5. Offices of Primary Responsibility. 30 SW/SEY and 45 SW/SESE along with 30 WS and 45 WS are the OPRs for natural and 

triggered lightning launch commit criteria. 30 SW/SE and 45 SW/SE are the OCRs.

A7.2.5.6. Reference Documents. Additional or different mission specific lightning launch commit criteria shall be documented in the RSOR.

45 Weather Squadron (45 WS) Lightning Launch Commit Criteria 

6.7. Range Safety Natural and Triggered Lightning Launch Commit Criteria (LCC). The Lightning Flight Commit Criteria are a set of rules 

developed by the Lightning Advisory Panel consisting of leading scientists in atmospheric electricity. These rules were accepted by Range Safety to 

ensure the avoidance of natural and/or triggered lightning during space/ballistic launch operations. See Attachment 14 and/or AFSPCMAN 91-710, 

Attachment 7. [shown above]

Attachment 14 LIGHTNING LAUNCH COMMIT CRITERIA, LAP RECOMMENDATION 08/20/14

A14.1. PREAMBLE

A14.1.1. The launch safety rules include launch-commit criteria that identify each condition that must be met in order to launch. These include 

criteria for trained weather personnel to monitor the meteorological conditions and implement each launch constraint developed using the following 

Natural and Triggered Lightning Launch-Commit Criteria. The launch operator must have clear and convincing evidence that none of these criteria 

is violated at the time of launch. Whenever there is ambiguity about which of several LLCC applies to a particular situation, all potentially applicable 

LLCC must be applied. If any other hazardous conditions exist, other than those identified below, the launch weather team will report the hazardous 

condition to the final approval authority for launch, who will determine whether launching would expose the launch vehicle to a lightning hazard and 

not launch in the presence of the hazard.

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A14.1.1.1. NATURAL AND TRIGGERED LIGHTNING LAUNCH-COMMIT CRITERIA

A14.1.1.2. GENERAL. These are the launch-commit criteria for mitigating against natural lightning strikes and lightning triggered by the flight of a 

launch vehicle through or near an electrified environment. A launch operator may not launch unless the weather conditions satisfy all of these 

Natural and Triggered Lightning Launch-Commit Criteria (LLCC).

A14.1.1.3. In order to meet the LLCC, a launch operator must employ any:

A14.1.1.4. Weather monitoring and measuring equipment needed, and

A14.1.1.5. Procedures needed to verify compliance.

A14.1.2. When equipment or procedures, such as a field mill or calculation of the maximum radar reflectivity (MRR) of clouds, are used with the 

lightning launch-commit criteria to increase launch opportunities, a launch operator must evaluate all applicable measurements to determine 

whether the measurements satisfy the criteria. A launch operator may not turn off available instrumentation to create the appearance of meeting a 

requirement and must use all radar reflectivity measurements within a specified volume for a MRR calculation.

A14.1.3. If a launch operator proposes any alternative lightning launch-commit criteria, the launch operator must clearly and convincingly 

demonstrate that the alternative provides an equivalent level of safety to that required here.

A14.2. DEFINITIONS. [Listing only the added/edited definitions]

Maximum radar reflectivity (MRR) means the largest radar reflectivity within a specified volume that is associated with an evaluation point.

 [Note: Section 25(b) provides full details on how to calculate MRR.] [Note 2: This term shows up in the Anvil Cloud (attached & detached) and Debris cloud rule.]

Thick cloud layer means one or more cloud layers whose combined vertical extent from the base of the bottom cloud layer to the top of the 

uppermost cloud layer exceeds 1.4 km (4,500 feet). Cloud layers are combined with neighboring layers for determining total thickness only when 

they are physically connected by vertically continuous clouds.

A14.10. THICK CLOUD LAYERS.

A14.10.1. This section does not apply to either attached or detached anvil clouds. Two or more cloud layers must be combined if they are physically 

connected by towering cumuliform clouds, but a cumulus cloud is never combined with cloud layers to increase the total thickness beyond the 

combined thickness of the layered clouds.

A14.10.2. A launch operator may not launch if the flight path will carry the launch vehicle through a non-transparent cloud layer that is:

A14.10.2.1. Greater than or equal to 1.4 km (4,500 feet) thick and any part of the cloud layer within the flight path is located at an altitude where 

the temperature is between 0 degrees Celsius and -20 degrees Celsius, inclusive; or

A14.10.2.2. Connected to a thick cloud layer that, at a slant distance of less than or equal to 5 nautical miles from the flight path, is greater than or 

equal to 1.4 km (4,500 feet) thick and has any part located at any altitude where the temperature is between 0 degrees Celsius and -20 degrees 

Celsius, inclusive.

A14.10.3. A launch operator may launch despite paragraphs A14.10.2.1 and A14.10.2.2 if the thick cloud layer:

A14.10.3.1. Is a cirriform cloud layer that has never been associated with convective clouds,

A14.10.3.2. Is located entirely at altitudes where the temperature is colder than or equal to -15 degrees Celsius, and

A14.10.3.3. Shows no evidence of containing liquid water.

A14.10.4. A launch operator need not apply the lightning launch-commit criteria in paragraphs A14.10.2.1 and A14.10.2.2 if the cloud layer does not 

contain a radar reflectivity of 0 dBZ or greater at any location that is less than or equal to 5 nautical miles from the flight path.

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Range Docs - Item E04

Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.113(c)(2)(iii) 

Vol 2 Flight Safety Requirements (certified current 17 June 2013), Chapter 1: Ground Rules

1.6. Ground Rules, Range User Responsibilities

1.6.9 Range User Range Tracking System Performance Requirements. 

The following requirements apply to Range Users who use other than AFSPC range assets for range tracking. The range tracking system 

(RTS) consists of the hardware, software, and personnel required to transmit, receive, process, and display launch vehicle data for Range 

Safety purposes.

1.6.9.1 General. An RTS, including at least two adequate and independent instrumentation data sources shall be provided and shall be 

maintained from T-0 through each phase of powered flight up to the end of Range Safety responsibility.

Vol. 6 (certified current 3 April 2014), Attachment 7: Range Safety Launch Commit Criteria:

A7.2.1. Flight Safety Systems. 

Flight safety systems are those ground and airborne systems required to monitor, track, aid decision making, and, if necessary, destroy errant 

launch vehicles in flight.

A7.2.1.1. Ground Range Safety Systems: 

A7.2.1.1.3. Ground Range Safety System Launch Commit Criteria:

A7.2.1.1.3.1. Range tracking systems include radars, optics, and telemetered inertial guidance downlinks.

A7.2.1.1.3.1.1. Two adequate and independent tracking sources shall be available throughout powered flight.

A7.2.1.1.3.1.1.1. Adequate is defined by error statistics for each source.

A7.2.1.1.3.1.1.2. Independent is defined as having no common components or systems between the vehicle and the front-end 

computers in the Range Operations Control Center (ROCC) such as to create a common failure mode.

AFSPCMAN 91-710 (2004):

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Range Docs - Item E05

Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.107(b)(1) 

Air Force Instruction (AFI) 91-217 (18 Feb 2010): 

4.6.5 Launch Safety, Public and Launch Personnel Risk: 

4.6.5.1. The risk to the public will not exceed the criteria listed below for mission operations (to include launch processing, space and suborbital 

launches, and subsequent controlled reentry); 

4.6.5.1.1. Public. The general public will not be exposed to a collective Expectation of Casualty (Ec) greater than 100 10-6 (one-hundred in one 

million) for all hazards associated with a mission (ref. RCC 321 for guidance on assigning mission risk).

AFI 91-217 update (17 Apr 2014): 

AFSPCMAN 91-710 (2004)

Vol 1, Atch 4: Acceptable Risk Criteria

AFSPCMAN 91-711 (2007)

Chap 3 Flight Safety Analysis Policy and Processes

3.6. Risk to General Public. 

4.4 Launch Safety 

4.4.1. The following outlines acceptable risk levels for hazards associated with launches. Launch operations risk management shall apply risk 

analysis consistent with DOD, RCC, Air Force, and industry standards and practices. . . .

4.4.2. Personnel Risk The risk criteria listed below applies to all launches. For FAA-licensed launches from Air Force ranges, the Air Force shall 

enforce FAA public risk criteria.

4.4.2.1. Public. The risk to the general public shall not exceed an individual Probability of Casualty (Pc) of 1 x 10-6 (one in one million), and the 

collective risk to the general public shall not exceed a casualty expectation (Ec) of 100 x 10-6 (one hundred in one million). These risk levels shall 

apply for all hazards from lift-off to orbital insertion, including planned debris impacts, and from lift-off to final impact for a suborbital mission. 

Reference RCC 321, Common Risk Criteria Standards for National Test Range s.

A4.3.5. The risk associated with the total flight to all members of the general public, excluding persons in waterborne vessels and aircraft, shall not 

exceed an expected average number of 0.00003 casualties (Ec < 30 x 10-6) from impacting inert and explosive debris, Ec < 30 x 10-6 for toxic release 

(exposure to rocket propellant effluent), and Ec < 30 x 10-6 for far field blast overpressure. The Ec criterion for each hazard applies to each launch 

from liftoff through orbital insertion, including planned impact for an orbital launch, and through final impact for a suborbital launch. Range Safety 

shall determine the public risk due to other hazards associated with the proposed flight of a launch vehicle on a case-by-case basis. 

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No hazardous condition is acceptable (acceptable hazard) if mission objectives can be reasonably obtained from a safer approach, methodology, 

or position. Containment of the hazard shall be accomplished when possible. When containment of the hazard is not possible, a risk analysis shall 

be performed. When the decision maker has agreed that the risk is within acceptable levels acceptable launch risk), and cannot be further 

reduced by reasonable methods, the hazardous operation may proceed. Launch area and downrange overflight shall be evaluated and the total 

risk accumulated. Individual hazardous activities may only exceed guidance levels based on national need.

3.6.1. Launch Vehicles. Initiation of launch vehicle flight may be accomplished if the FSA satisfies all of the following public risk criteria

. . . 

3.6.1.2. Risk associated with the flight to all members of the general public (collective risk), excluding persons in waterborne vessels and aircraft, 

does not exceed a casualty expectation of 30 x 10-6 for each hazard per launch.

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Range Docs - Item W01

Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.107(b)

AFSPCMAN 91-710 (2004)

Vol 1, Atch 4: Acceptable Risk Criteria

Vol 6, Atch 7: Range Safety Launch Commit Criteria

A7.2.2.1. General Description. The BLAST model addresses intermediate hazardous range effects of a shock wave from an inadvertent 

detonation, such as from a launch vehicle malfunction, impact, or destruction. Near-in areas of overpressure above one pound per square inch 

(psi) are evacuated of personnel and are not considered in the assessment. At far-out distances, with overpressures of less than 0.1 psi, there are 

relatively small hazards. It is the intermediate distance with overpressures of 0.1 to 0.5 psi that are of concern. The area encompassing 

overpressures in this range varies considerably with local meteorological conditions. 

A7.2.2.2. Applicability. This launch commit criteria is generally applicable to large launch vehicles with large amounts of propellants, solid rocket 

motor launch vehicles with high energy propellants, and launch vehicles using launch complexes near the borders of general population.

A7.2.2.3. Blast Launch Commit Criteria. If the expected casualties of a potential blast overpressure exceed those limits defined in Volume 1 of 

this publication, Range Safety recommends the range go “red” until another BLAST model run can be made with updated meteorological data.

A7.2.2.4. Offices of Primary Responsibility. 30 SW/SEY is the OPR for launch commit criteria associated with the Blast C model; 45 SW/SESE 

is the OPR for launch commit criteria associated with the Blast X (tailored version of Blast C) model.

A7.2.2.5. Reference Documents. Mission-specific blast launch commit criteria shall be addressed in the RSOR.

A7.2.7. Safety Clearance Zones.

A7.2.7.2. Hazardous Launch Areas:

A7.2.7.2.3. Hazardous Launch Area Launch Commit Criteria:

A7.2.7.2.3.3. VEA/BEA. Ships and aircraft shall remain outside this area during launch. Ships/boats are protected to a Pi level of 1 x 10-5. Aircraft 

are protected to a Pi level of 1 x 10-8. (See Volume 7 for definitions of vessel exclusion area and boat exclusion area.) 

A7.2.8. Launch Area Air And Sea Surveillance:

A4.3.5. The risk associated with the total flight to all members of the general public, excluding persons in waterborne vessels and aircraft, shall not 

exceed an expected average number of 0.00003 casualties (Ec < 30 x 10-6) from impacting inert and explosive debris, Ec < 30 x 10-6 for toxic release 

(exposure to rocket propellant effluent), and Ec < 30 x 10-6 for far field blast overpressure. The Ec criterion for each hazard applies to each launch 

from liftoff through orbital insertion, including planned impact for an orbital launch, and through final impact for a suborbital launch. Range Safety 

shall determine the public risk due to other hazards associated with the proposed flight of a launch vehicle on a case-by-case basis. 

A4.3.7. The probability of debris impact to all waterborne vessels (Piv) shall not exceed 0.00001 (Piv < x 10-5) in each debris impact hazard area 

identified by Range Safety.

A7.2.2.: Blast

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A7.2.8.1, General Description. Areas to be cleared of boats and ships are defined by Flight Analysis and based on probability contours and/or 

Toxic Hazard Zones, including known impact areas of jettisoned stages/bodies and destruct debris resulting from malfunction scenarios plus the 

areas and altitudes in which Toxic Hazards will exist. Areas defined by Notice to Airmen (NOTAM) and Notice to Mariners (NTM) are surveyed on 

launch day. 

A7.2.8.3.1.1 At the ER, if the sum total of the individual hit probabilities of all targets plotted within, or predicted to be within, the established 

probability contours exceed 10-5, a launch hold or scrub may be initiated.

AFSPCMAN 91-711 (2007)

3.6.1. Launch Vehicles. Initiation of launch vehicle flight may be accomplished if the FSA satisfies all of the following public risk criteria:

3.6.1.1. Risk to any individual member (individual risk) of the general public does not exceed a casualty expectation of 1 x 10-6 for each hazard 

per launch.

3.6.1.2. Risk associated with the flight to all members of the general public (collective risk), excluding persons in waterborne vessels and 

aircraft, does not exceed a casualty expectation of 30 x 10-6 for each hazard per launch.

3.6.1.3. The cumulative hit probability of inert and explosive debris impact for each group of public and mission support waterborne vessels in 

all impact areas identified by Wing Safety does not exceed 1 x 10-5.

3.6.1.4. Aircraft shall not be exposed above 1 x 10-6 collective probability of impact. A more conservative criterion of a 1 x 10-8 collective 

probability of impact (that is also used for ships) may be used for aircraft to account for risk uncertainty caused by variability in aircraft type, 

position, altitude, and speed.

3.6.1.5. Trains shall not be exposed above 1 x 10-6 probability of impact.

3.6.1.6. For all launch vehicles, jettisoned components, propagated debris, and payloads with the potential to collide with manned orbiting 

objects, the level of protection provided to the spacecraft shall be: (1) ensuring a spherical miss distance of 200 km or (2) ensuring an 

ellipsoidal miss distance of 200 km in-track and 50 km perpendicular to the in-track axis or (3) not exceeding a probability of impact greater 

than 1 x 10-6 per spacecraft. COLA analysis is used in the minus count to protect orbiting objects from collision with a launch vehicle or its 

jettisoned components. A COLA closure time period (no launch) is calculated for any object violating the criteria described below. A COLA 

closure time period shall result in a launch hold for that time period. A mission/launch scrub occurs only if the closure time period conflicts 

with any remaining time for the mission launch window. At present, Wing Safety only requires COLAs for manned objects such as the 

International Space Station, Space Transportation System, and critical supply vehicles to manned objects.

3.7. Risk to LEP and NOP. Initiation of the flight of a launch vehicle may only be approved if the FSA satisfies the following risk criteria for LEP and 

NOP for the following hazards:

3.6. Risk to General Public No hazardous condition is acceptable (acceptable hazard) if mission objectives can be reasonably obtained from a safer 

approach, methodology, or position. Containment of the hazard shall be accomplished when possible. When containment of the hazard is not possible, a 

risk analysis shall be performed. When the decision maker has agreed that the risk is within acceptable levels (acceptable launch risk), and cannot be 

further reduced by reasonable methods, the hazardous operation may proceed. Launch area and downrange overflight shall be evaluated and the total 

risk accumulated. Individual hazardous activities may only exceed guidance levels based on national need.

3.7.4. The cumulative hit probability criteria to waterborne vessels and aircraft as stated in paragraphs 3.6.1.3. and 3.6.1.4. apply to LEP, NOP, and 

mission support vessels in all impact areas identified by Wing Safety.

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5.4. Launch Area Air and Sea Surveillance.

5.4.3.2. Boat and Ship Traffic LCC. If the sum total of the individual hit probabilities of all targets plotted within, or predicted to be within, the 

established probability contours exceeds acceptable risk criteria as stated in AFSPCMAN 91-710 Volume 1, a launch hold or mission/launch scrub 

may be initiated.

5.4.3. Launch Area Air, Land, and Sea Surveillance Launch Commit Criteria (LCC). Areas to be cleared of boats, ships, and trains are defined 

by Flight Analysis and based on hit probability contours and/or THZs, including known impact areas of jettisoned stages/bodies and destruct debris 

resulting from malfunction scenarios plus the areas and altitudes in which toxic hazards will exist. Hazardous Launch Areas are defined by NOTAM 

and those areas within the coverage capabilities of local land based radars or support aircraft are surveyed on launch day for intruder aircraft and are 

analyzed as a potential for risk to the launch vehicle or the aircraft.

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Requirements Documents for Range Current Practices, as assessed under 14 CFR §417.213(d)

Vol 2, Atch 3: Fragment Data

A3.3. Fragment Data Items.

These requirements provide a description of the data items required for each fragment or fragment group for each potential mode of vehicle 

breakup. The variation of the fragment characteristics with flight time shall be defined. Normally this is accomplished by specifying multiple 

fragment lists, each of which is applicable over a specified period of flight.

A3.3.6. Ballistic Coefficient (beta). Nominal, plus three-sigma, and minus three-sigma values (psf) for each fragment or group; including graphs 

of the coefficient of drag (Cd) versus Mach number for the nominal and three-sigma beta variations for each fragment or group. Each graph shall 

be labeled with the shape represented by the curve and reference area used to develop the curve. A Cd versus Mach curve for axial, transverse, 

and tumble orientations (when applicable) shall be provided for fragments not expected to stabilize during free-fall conditions. For fragments that 

may stabilize during free-fall, Cd versus Mach curves should be provided for the stability angle of attack. If the angle of attack where the 

fragment stabilizes is other than 0 degrees, both the coefficient of lift (CL) versus Mach number and the Cd versus Mach number curves should 

be provided. If available, equations for Cd versus Mach curves should be provided. The difficulty of estimating drag coefficient curves and 

weights for vehicle pieces is fully realized. If this cannot be done satisfactorily, an estimate of the subsonic and supersonic W/ Cd A for each 

major piece may be provided instead. In either case, three-sigma tolerance limits

AFSPCMAN 91-711 (2007, cert'd 24 Jan 2013)

 Ch 3. Flight Safety Analysis Policy and Processes

A FSA assessment shall demonstrate that an AFSPC range will, for each launch, control the risk to the public from hazards associated with 

normal and malfunctioning launch vehicle flight. The analysis shall employ hazard isolation, risk assessment, or a combination of risk 

assessment and partial isolation of the hazards, to demonstrate control of risk to the public. 

Sec 3.8.7. Flight Safety Limits Analysis. A FSA shall identify the location of populated or other protected areas, and establish flight safety limits 

(destruct lines) that define when an FSS shall terminate a launch vehicle’s flight to prevent the hazardous effects of the resulting inert and 

explosive debris impacts from reaching any populated or other protected area and ensure that the launch satisfies the public risk criteria. The 

population used for analysis shall take variations due to growth in the local populous and temporary changes due to seasonal or special 

circumstances.

Sec 3.8.7.2. Designated Inert and Explosive Debris Impact Limits. The analysis shall establish designated impact limit lines (ILLs) to bound the 

area where debris with a ballistic coefficient of three or more is allowed to impact if the FSS functions properly.

AFSPCMAN 91-710 (2004, cert'd 17 Jun 2013), Vol 2 Flight Safety Requirements

Sec 3.8. Flight Safety Analysis (FSA)

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Technical Document

REVIEW OF CHANGES TO 

FEDERAL RANGE CURRENT PRACTICES 

FOR DETERMINATIONS OF

EQUIVALENT LEVEL OF SAFETY

(Revision 0)

Prepared by the

LICENSING AND EVALUATION DIVISION

of the

OFFICE OF 

COMMERCIAL SPACE TRANSPORTATION

September 27, 2016
1

TABLE OF CONTENTS 

E-01: Regarding Changes to Collision Avoidance Criteria ...........................................2

E-02: Regarding Flight Safety Analysis as Conducted by USAF and 

NASA Launch Ranges .............................................................................................5

E-03: Regarding Changes to Lightning Flight Commit Criteria at CCAFS ................7

E-04: Regarding Changes to Launch Area Tracking on the Eastern Range .............10

E-05: Regarding Flight Safety, Public Risk Criteria (Expected Casualty) ................14

E-##: Future ELS Determinations Will Be Placed Here Over Time ..........................15
2

FAA REVIEW OF 

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-01: Regarding Changes to Collision Avoidance Criteria

As applied to Launch Site Safety Assessment Matrix Item E-01. 

 

Intent 

This report assesses the approach by both the Eastern and Western Range (EWR) for 

determining Collision Avoidance parameters, and documents the FAA’s resulting 

determination of an equivalent level of safety (ELS) in its usage. 

Introduction 

The Air Force ranges have increased the stringency of its calculation for Collision 

Avoidance (COLA) to protect on-orbit manned spacecraft and active satellites from 

collision with launched objects with an altitude capability equal to or greater than 150 

km. This change moves beyond the AF ranges’ previous practice, which had been 

parallel to FAA requirements for COLA, under 14 CFR part 417. The possible impact 

would be the narrowing of available launch windows. 

Background 

Current FAA regulations require that a licensed launch operator obtain a collision 

avoidance analysis from the US Air Force, in order to assure inhabited or habitable 

spacecraft are not jeopardized during the licensed launch operations. 

From 14 CFR § 417.107(e) Flight safety, Collision avoidance: 

“(1) A launch operator must ensure that a launch vehicle, any jettisoned components, and its 

payload do not pass closer than 200 kilometers to a manned or mannable orbital object —

(i) Throughout a sub-orbital launch; or 

(ii) For an orbital launch: 

(A) During ascent to initial orbital insertion and through at least one complete orbit; 

and 

(B) During each subsequent orbital maneuver or burn from initial park orbit, or direct 

ascent to a higher or interplanetary orbit or until clear of all manned or mannable 

objects, whichever occurs first. 

(2) A launch operator must obtain a collision avoidance analysis for each launch from United 

States Strategic Command or from a Federal range having an approved launch site safety 

assessment. United States Strategic Command calls this analysis a conjunction on launch 

assessment. Sections 417.231 and A417.31 of appendix A of this part contain the 

requirements for obtaining a collision avoidance analysis. A launch operator must use the 

results of the collision avoidance analysis to develop flight commit criteria for collision 

avoidance as required by § 417.113(b).”
3

Also, from § 417.231 Collision avoidance analysis: 

“(a) General. A flight safety analysis must include a collision avoidance analysis that 

establishes each launch wait in a planned launch window during which a launch operator 

must not initiate flight, in order to protect any manned or mannable orbiting object. A 

launch operator must account for uncertainties associated with launch vehicle 

performance and timing and ensure that any calculated launch waits incorporate all 

additional time periods associated with such uncertainties. A launch operator must 

implement any launch waits as flight commit criteria according to § 417.113(b). 

 (b) Orbital launch. For an orbital launch, the analysis must establish any launch waits 

needed to ensure that the launch vehicle, any jettisoned components, and its payload do 

not pass closer than 200 kilometers to a manned or mannable orbiting object during 

ascent to initial orbital insertion through at least one complete orbit. 

 (c) Suborbital launch. For a suborbital launch, the analysis must establish any launch 

waits needed to ensure that the launch vehicle, any jettisoned components, and any 

payload do not pass closer than 200 kilometers to a manned or mannable orbital object 

throughout the flight. 

(d) Analysis not required. A collision avoidance analysis is not required if the maximum 

altitude attainable by a launch operator’s unguided suborbital launch vehicle is less than 

the altitude of the lowest manned or mannable orbiting object. The maximum altitude 

attainable must be obtained using an optimized trajectory, assuming 3-sigma maximum 

performance.”

Finally, from 14 CFR 417, Appendix A (A417.31) Collision: 

“(a) General. A flight safety analysis must include a collision avoidance analysis that 

satisfies the requirements of § 417.231. This section applies to a launch operator 

obtaining a collision avoidance assessment from United States Strategic Command as 

required by § 417.231 and to the analysis products that the launch operator must file with 

the FAA as required by § 417.203(e). United States Strategic Command refers to a 

collision avoidance analysis for a space launch as a conjunction on launch assessment.”

[The rest of the reference § A417.31 is a descriptive guidance on an acceptable 

method of acquiring a COLA analysis and is not included here, for brevity] 

The FAA assessment of the Range practices at the time of the part 417 Rule’s 

publishing in 2007, was that they satisfied the FAA requirements. On 18 February 

2010, the U.S. Air Force published AF Instruction 91-217, Space Safety and Mishap 

Prevention Program (later updated, 17 April 2014). This document implements space 

safety, mishap prevention and mission effectiveness guidance for AF space systems, and is 

applicable to all AF organizations and personnel that develop, test, or operate any space 

system or who provide launch/range services for space systems.

Herein, the AF tightened its COLA criteria; for instance, under Section 6.6.4 Safe 

Separation – CA and COLA: 

“The appropriate wing commander is responsible for precluding any activity that 

would adversely affect active or manned spacecraft, based on a pre-launch COLA 

process identified by the MAJCOM”
4

Thus, in accordance with the 2014 AFI 91-217, the Air Force’s Space wings, in 

conjunction with the Joint Space Operations Center (JSpOC, USSTRATCOM) were 

instructed to protect on-orbit manned spacecraft and active satellites from collision with 

launched objects. Later, on 22 July 2016, the responsibility for the COLA function was 

reassigned from the JSpOC to the 18th Space Control Squadron (18 SPCS, AFSPC). 

Space wings were to obtain Conjunction Assessments (CAs) from the 18 SPCS to 

establish COLA holds in the launch windows to ensure safe separation criteria from 

manned and active orbital objects. 

The 2014 update to AFI 91-712 further clarified the stringent criteria for COLA. Under 

Section 4.4.3 Launch Collision Avoidance: 

“All launches from Air Force ranges and all Air Force launches from non-Air Force 

ranges shall accomplish LCOLA procedures accounting for all launched objects (e.g., 

booster segments, payloads, jettisoned components, and debris) with an altitude 

capability equal to or greater than 150 km. ...”

While both the Eastern and Western Ranges still follow their original AFSPCMAN 91-

710 (Range Safety User Requirements Manual, 2004) and 91-711 (Launch Safety 

Requirements for AF Space Command Organizations, 2007), their higher headquarters 

requirements do not allow for a less restrictive COLA, therefore the ranges now abide by 

the more stringent criteria laid out in AFI 91-217. 

Discussion 

By the new AF direction, the current practice now is for both ER and WR to comply with 

AFI 91-217 for launch COLA requirements. The commercial launch operator launching 

from the federal ranges (ER & WR) will have a required minimum COLA analysis that is 

consistent with FAA regulation § 417.107 (e). The commercial launch operator may 

request more stringent analysis at its discretion. 

The analysis of Launch Collision Avoidance is consolidated at the 18 SPCS, which works 

with both ER & WR. The ER and WR requirements meet or exceed FAA regulation § 

417.107 (e), because they also protect for active satellites in addition to manned spacecraft. 

Each federal range also enforces COLA closures, as a launch commit criteria. In addition, it 

should be noted that the AF COLA process also includes screening for orbital debris, as 

well as manned/mannable and active satellites; this is current practice as levied by AFI 91-

217 (2014). As a result of this, the newer practice is an equivalent level of safety with the 

FAA’s requirement.

Conclusion 

The changes made by both Air Force ranges (ER and WR) do not impact FAA 

requirements and provide an equivalent level of safety. 
5

FAA REVIEW OF 

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-02: Regarding Flight Safety Analysis as Conducted by USAF and 

NASA Launch Ranges

As applied to Launch Site Safety Assessment Matrix Item E-02. 

 

Intent 

This report assesses the current practices by federal (Air Force and NASA) launch 

ranges on how they conduct their respective Flight Safety Analysis (FSA) calculations, 

and documents the FAA’s resulting determination of an equivalent level of safety (ELS) 

for each respective range. 

Introduction 

Since the publishing of the FAA’s Launch Rule, 14 CFR part 417, on 25 August 2006, the 

Federal ranges have continued to refine and improve on their method of calculating the 

Flight Safety Analysis. Likewise, the FAA has also worked to improve its method of 

determining better quality FSA’s. This report reviews the ranges’ FSA practices to 

determine whether in the drive to continually improve the process, still meets the FAA 

requirements. 

Background 

The development of the FAA’s Launch Rule, 14 CFR part 417 was done in near-parallel 

to the requirements of the developing US Air Force’s AFSPCMAN 91-710, and with an 

understanding of the then current NASA Range Safety Manual (in particular for the 

Wallops Flight Facility). From that period, the analytical practice by the ranges and the 

FAA were similar if not identical, with regards to the calculations that would go into the 

Flight Safety Analysis for each mission. 

 

From 14 CFR Part 417, Subpart C – Flight Safety Analysis 

“§ 417.203 Compliance,(d) Analyses performed by a Federal launch range. FAA will 

accept a flight safety analysis used by a Federal launch range without need for further 

demonstration of compliance to the FAA, if: 

(1) Launch operator contracted with Federal launch range for provision of flight 

safety analysis; and 

(2) the FAA assessed the Federal launch range [via LSSA], and found range's 

analysis methods satisfy requirements ... 

In this case, FAA will treat Fed range's analysis as that of a launch operator.”
6

The focus on the FAA in this particular case is more on the quality of methods and tools 

the ranges use that may have changes notably in the last 10 years, and whether these 

changes may have inadvertently deviated from FAA requirements. 

Discussion 

The FAA Flight Safety Analysts and representatives from FAA Offices at both ER and 

WR, performed a brief investigation on what the Air Force ranges of Cape Canaveral Air 

Force Station, Vandenberg Air Force Base, and also NASA’s Wallops Flight Facility, 

currently use in their respective FSA processes. The results from the FAA group’s quick 

look are as follows: 

The 45th Space Wing at CCAFS now uses the Trajectory Toolkit (TTK) to pre-process 

the trajectories received from the launch operators and creates the input files for their 

Range Risk Analysis Tool (RRAT). With regard to the FAA requirements, 45 SW's 

newer practice to pre-process the trajectories is also used by the FAA. The practice is 

an equivalent level of safety. With regard to RRAT, the FAA has been using the same 

program as well. 

The 30th Space Wing at VAFB is now performing the Flight Safety Analysis in-house, 

as opposed to it being done previously by a contractor. The 30 SW incorporation of 

previously contracted tasks onto the Government side is transparent to how it conduct 

trajectory analysis. The 30 SW conducts its FSA in accordance with its most current 

FSA Handbook, and its approach is consistent with those of the 45 SW, WFF and the 

FAA. The practice is an equivalent level of safety.

WFF uses the following analysis tools: Joint Advanced Range Safety System 

(JARSS), BlastDFO (for Distance Focus Overpressure), and Launch Area Toxic Risk 

Assessment (LATRA). Here too, WFF's processes are consistent with that used by 

FAA. Whereas JARSS might be considered medium fidelity when compared to 

RRAT, the FAA has accepted that for ELV launches from WFF, the JARSS analysis 

is acceptable and meets the regulations. The practice is an equivalent level of safety. 

Conclusion 

The current practices used by all three federal launch ranges listed here, using their most 

up-to-date approaches, were found to be an equivalent level of safety for each respective 

range. Both FAA and the ranges have adopted like, if not identical, analysis practices, at 

around the same time. 
7

FAA REVIEW OF 

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-03: Regarding Changes to Lightning Flight Commit Criteria at 

CCAFS

As applied to Launch Site Safety Assessment Matrix Item E-03. 

 

Intent 

This report assesses changes to lightning flight commit criteria and documents the FAA’s 

resulting determination of an equivalent level of safety (ELS) in its usage. 

Purpose and Background 

On December 2, 2013, the Federal Aviation Administration’s Office of Commercial Space 

Transportation (AST) was notified of the Lightning Advisory Panel (LAP) recommended 

updates to the Lightning Launch Commit Criteria (LLCC). 

This change replaced the Volume Averaged Height Integrated Radar Reflectivity 

(VAHIRR) with the Maximum Radar Reflectivity (MRR), easing calculation of radar 

reflectivity from existing radar imagery. A second update involved a change to the Thick 

Cloud Layer rule that will allow launch within 5 nm of a thick cloud layer if it is 

determined that the radar reflectivity is below 0 dBZ. 

The FAA coordinated with the USAF and NASA weather teams, reviewed the changes in 

the LLCC, and determined that these changes provide an equivalent level of safety to 14 

CFR part 417, Appendix G (Lightning Flight Commit Criteria). Therefore, FAA licensed 

launches from the Federal Ranges (Eastern, Western, Wallops Flight Facility, or Reagan 

Test Site), that utilize the approaches described above do not impact FAA requirements and 

do provide an equivalent level of safety. 

Discussion 

The federal ranges develop AF Safety launch commit criteria (LCC), based on operations 

requirements whose intent is to protect the public from hazards associated with launching 

missiles or space launch vehicles. 

What the range describes as “Lightning Launch Commit Criteria” (LLCC, shortened to 

LCC), the FAA uses “Lightning Flight Commit Criteria” (LFCC), for Natural and 

Triggered Lightning Flight Commit Criteria. Both LCC and LFCCs are natural and 

triggered lightning avoidance rules, and the range’s LCCs have recently been updated. As 

such, these changes to range practices must be assessed to see if they provide an equivalent 

level of safety in meeting with the FAA’s requirements. These labels sometimes become 

interchanged, but to avoid confusion, this report will use the FAA’s designation for 

Lightning FCC (LFCC.). 
8

The LFCC launch safety rules are natural and triggered lightning avoidance rules that 

identify each condition that must be met in order to initiate safe flight. These include 

criteria for trained weather personnel to monitor the meteorological conditions and 

implement each flight constraint developed using the following Natural and Triggered 

Lightning Flight Commit Criteria (LFCC). The launch operator must have clear and 

convincing evidence that none of these criteria is violated at the time of launch. Whenever 

there is ambiguity about which of several LFCC applies to a particular situation, all 

potentially applicable LFCC must be applied. 

From part 417, Apx G, G417.1 General: 

(a) This ... provides flight commit criteria to protect against natural lightning and 

lightning triggered by the flight of a launch vehicle. A launch operator must apply these 

criteria under § 417.113 (c) for any launch vehicle that utilizes a flight safety system. 

(b) The launch operator must employ: 

(1) Any weather monitoring and measuring equipment needed to satisfy the 

lightning flight commit criteria; and 

(2) Any procedures needed to satisfy the lightning flight commit criteria. 

(c) If a launch operator proposes any alternative lightning flight commit criteria, the 

launch operator must clearly and convincingly demonstrate that the alternative provides 

an equivalent level of safety. 

The 45th Weather Squadron (45 WS) updates involve language that nearly parallels the 

above FAA rule, where the flight commit criteria are for mitigating against natural 

lightning strikes and lightning triggered by the flight of a launch vehicle through or near 

an electrified environment. One notable difference of the two is where the range 

documentation also includes an additional criterion: 

“When equipment or procedures, such as a field mill or calculation of the maximum 

radar reflectivity (MRR) of clouds, are used with the lightning flight commit criteria to 

increase launch opportunities, a launch operator must evaluate all applicable 

measurements to determine whether the measurements satisfy the criteria. A launch 

operator may not turn off available instrumentation to create the appearance of meeting 

a requirement and must use all radar reflectivity measurements within a specified 

volume for a MRR calculation.”

Likewise, the range documentation has included the definition of the MRR in its list (“the 

largest radar reflectivity within a specified volume that is associated with an evaluation 

point”), while replacing the Volume Average Height Integrated Radar Reflectivity 

(VAHIRR) technique as listed in the current FAA regulations. 

In reviewing the description of LLCC changes, it became apparent that these new 

approaches, if found to be an ELS could likewise be applicable to other federal ranges 

(e.g., Wallops Flight Facility (NASA), or Reagan Test Site (US Army)), if and when they 

so choose to adopt these for their respective operations. It should be noted that 

Vandenberg AFB, as part of the EWR, is already implementing these changes. As such, 
9

any potential finding of ELS for CCAFS operations would be equally applicable to like 

operations at the other ranges. 

Because the updated criteria involves weather, and its potential impact on a launch 

vehicle’s Flight Termination System, a small group of reviewers were included in this 

reassessment of the range’s approach, with regard to the current FAA regulation. The 

FAA coordinated with USAF and NASA weather teams, reviewed the changes in the 

LLCC and determined that these changes provide an equivalent level of safety to 14 CFR 

Part 417, Appendix G (Lightning Flight Commit Criterial): 

 The MRR is a new technique that can be directly calculated from the radar screen. 

This technique provides an equivalent level of safety as it a radar based technique 

similar to the VAHIRR technique that allows a launch operator to launch during an 

anvil cloud or debris cloud is present as long as the calculated value is lower than 

or equal to the threshold value that was derived for low threat. This method is 

much simpler to calculate than the VAHIRR and is just as safe. 

 The Thick Cloud layer Rule change provides additional launch availability, if there 

is a situation when there is a thick cloud layer but it is showing up as 0dBZ on the 

radar. The Lightning Advisory Panel has deemed that "a 0 dBZ" reading indicates 

that it is safe to launch into a thick cloud layer. 

 Implementing this change does not result in additional risk but does provide 

increased launch availability. 

Conclusion 

The changes made by the 45 WS for the Eastern Range do not impact FAA requirements 

and provide an equivalent level of safety. As part of the EWR, Vandenberg AFB will 

update its respective LLCC’s to reflect these changes. Also, the updated approaches as 

described here are easily transferable to any other federal launch range (e.g., Wallops 

Flight Facility, or Reagan Test Site), if they choose to adopt these approaches for their 

respective operations. In all instances, the approaches as described by the range do not 

impact FAA requirements and they do provide an equivalent level of safety. 

Formalizing changes to the FAA's Lightning Flight Commit Criteria requires the FAA to 

initiate a rulemaking activity. The equivalent level of safety evaluation and process will 

suffice for these and future changes until a rulemaking activity is completed. 
10

FAA REVIEW OF 

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-04: Regarding Changes to Launch Area Tracking

on the Eastern Range

As applied to Launch Site Safety Assessment Matrix Item E-04. 

 

Intent 

This report assesses an approach by a federal launch range, for launch vehicle tracking 

prior to lift-off and up to 3 seconds prior to Minimum Time to Endanger (MTE), and 

documents the FAA’s resulting determination of an equivalent level of safety (ELS) in 

its usage. 

Introduction 

On 15 January 2015, the Federal Aviation Administration’s Office of Commercial Space

Transportation (AST) was notified by its Patrick AFB Field Office, of a change in 

practice on the Eastern Range (ER) located at Cape Canaveral Air Force Station 

(CCAFS), FL, regarding how it conducts launch area tracking and the effect this change 

may have on the range being in compliance with FAA requirements concerning flight 

commit criteria for an expendable launch vehicle that uses a flight safety system. 

Current FAA regulations require that an expendable launch vehicle have two tracking 

sources prior to lift off and no less than one verified tracking source at all times from 

lift-off to orbital insertion for an orbital launch. A previous modification to this practice 

by the range was evaluated in October 2012, and had been found to meet the intent of 

the regulation via an equivalent level of safety. 

However, in 2015, the FAA received word that the ER was revising its launch area 

tracking requirements. This came after an engineering evaluation review of historical 

GPS metric tracking performance data of the CCAFS pads, which showed acceptable 

coverage, and the MFCOs determination that with no source at T-0, the Minimum Time to 

Endanger minus 3-seconds (MTE1

-3 secs) does not provide sufficient reaction time. 

Below are the previous and current ER requirements. 

Previous: Two tracking sources mandatory by 3 seconds prior to MTE for GPS/TMIG 

(Global Positioning System/Telemetry Inertial Guidance) equipped 

vehicles. 

 

1

 MTE - Minimum Time to Endanger is defined as the first time that a missile has sufficient time to 

hazard an area outside of the impact limit line. If no sensor has acquired track of the launch vehicle 

by the MTE, the MFCO is authorized to terminate the flight. MTE is calculated by Range Safety for 

each launch.
11

Current: One tracking source mandatory at T-0; two tracking sources mandatory by 3 

seconds prior to MTE 

The purpose of this review is to document this approach, which was implemented in 

2015 by the range, and the resulting determination of an equivalent level of safety

(ELS) in its usage. Furthermore, this will provide the basis for updating the Launch 

Site Safety Assessment (LSSA) to reflect this ELS. 

Background 

Current FAA regulations require that an expendable launch vehicle have two tracking 

sources prior to lift off and no less than one verified tracking source at all times from 

lift-off to orbital insertion for an orbital launch. 

From 14 CFR § 417.113(c) Flight commit criteria: 

“(2) For a launch that uses a flight safety system, the flight-commit criteria must 

ensure that the flight safety system is ready for flight. This must include criteria for 

ensuring that: 

(iii) The launch vehicle tracking system has no less than two tracking sources prior 

to lift-off. The launch vehicle tracking system has no less than one verified tracking 

source at all times from lift-off to orbit insertion for an orbital launch, to the end of 

powered flight for a suborbital launch; ...”

Prior to Air Force Space Command (AFSPC) taking charge of the Eastern Range in 1991, 

the tracking requirement was for two (2) tracking sources from 3 seconds prior to MTE 

throughout each phase of powered flight from launch to establishment of the final impact 

point for launch vehicles with suborbital trajectories or to orbital insertion for space 

launch vehicles. In 1992, AFSPC changed the standard range tracking requirement to at 

least two adequate and independent instrumentation data sources is mandatory and shall 

be maintained from T-0 throughout each phase of powered flight up to the end of Range 

Safety responsibility 

In 2008, Air Force Space Command endorsed the Launch Enterprise Transformation 

(LET), a way ahead for Evolved Expendable Launch Vehicle (EELV) acquisition and 

launch range infrastructure. The plan directed transforming launch services acquisition, 

deploying a range architecture built on GPS Metric Tracking by 2011 and Autonomous 

Flight Termination by 2018, and finally leveraging Total Force Integration within the 

Enterprise. 

Based on findings from LET, a Fragmentary Order (FRAGO) was implemented in 2010 

directing which instrumentation to keep, decommission, mothball or transfer. The result 

was the loss of a number of radars, all ER metric optics sites and down-range assets at 

Antigua, Argentia and Ascension. The Ascension radar was not affected by the LET 

FRAGO due to a support agreement between the US Navy and US Air Force. 

In 2012 beacon transponders were removed from Delta IV and Atlas V launch vehicles 

and replaced with GPS receivers for tracking. Additional tracking was provided via radar 
12

skin track and TMIG as adequate and independent tracking sources. It was at this time the 

ER transitioned from a two source off the pad to two (2) sources three (3) seconds prior to 

MTE for GPS/TMIG equipped vehicles. This policy provided greater launch availability 

with no increase to public safety risk. 

Then in Jan 2015, the ER revised its previous policy to allow a launch to proceed with 

only one tracking source from T-0 through 3 seconds prior to MTE shall be mandatory. 

Two sources shall be mandatory from 3 seconds prior to MTE to the end of period of 

Range Safety responsibility. Requiring two tracking sources by 3 seconds prior to the 

Minimum Time to Endanger (MTE) and one tracking source at T-0 continued to provide 

acceptable launch availability with no impact to public safety. Additionally, it ensured 

adequate response time for MFCOs to evaluate late presentation of in-flight data and take 

appropriate actions to protect public safety and mission assurance. 

The Air Force had clarified back to AST then, that the two tracking systems must be 

‘adequate’ and they consider adequate to mean that tracking system provides enough 

support for the Mission Flight Control Officer (MFCO) to make a real-time 

determination necessary to protect the public, i.e. sufficient information in sufficient 

time to decide if a mission rule is being violated and to send functions to terminate the 

vehicle. The Air Force believes that two independent sources of tracking are not 

required until MTE minus three seconds. There would be no increase to public safety as 

the MFCO would still have the necessary time and information to contain a vehicle 

inside the impact limit lines even with a worst case failure scenario. Additional tracking 

assets would be able to acquire the vehicle by MTE minus three seconds. 

An FAA internal meeting took place on 26 September 2012 to discuss the FAA tracking 

regulation and the ER tracking policy. Attendees included managers from the Office of 

Commercial Space Transportation (AST), AST safety inspectors, subject matter experts 

and engineering team members from the Licensing & Evaluation Division and the Safety 

Inspectors Division. The discussion’s focus included tracking adequacy, and 

independence, radar beacon and skin track, launch vehicle telemetry, precedence and 

public safety. The conclusion drawn was that the ER tracking policy met the intent of 

§417.113(c)(2)(iii) and posed no increase to public safety. A memorandum was sent on 1 

October 2012 to the 45 SW to clarify the FAA’s acceptance of the ER tracking policy. 

Now, in accordance with 14 CFR §417.1(c), “meets intent” certification: 

“For a licensed launch from a Federal launch range, a launch operator need not 

demonstrate to the FAA that an alternative means of satisfying a requirement of this part 

provides an equivalent level of safety for a launch if written evidence demonstrates that a 

Federal launch range has, by the effective date of this part [italics added], granted a 

“meets intent certification,” including through “tailoring,” that applies to the 

requirement and that launch. ...”

The text “by the effective date of this part” in the above requirement refers to the “meets 

intent” evidence being demonstrated to the FAA no later than the effective date of part 

417’s publishing (25 August 2006). So while the term is still used by the Air Force, the 

use of “meets intent” is, by this text, not in the FAA current parlance. However, the 
13

underlying result is still valid; that is, this practice had demonstrated an equivalent level of 

safety that would satisfy the FAA requirement §417.113(c)(2)(iii). 

On 15 January 2016, the Patrick AFB Field Office for AST notified the AST management 

and subject matter experts in Washington, DC, that the ER is now revising its previous 

launch area tracking requirements. This comes after an engineering evaluation of 

historical GPS metric tracking performance off the CCAFS pads, which shows acceptable 

coverage, and the MFCOs determination that the MTE-3 seconds does not provide 

sufficient reaction time. 

Discussion 

Whereas the previously determined “meets intent” practice by the range was for two (2) 

tracking sources to be mandatory by 3 seconds prior to MTE, for GPS/TMIG equipped 

vehicles; the proposed newer practice is now to have one (1) tracking source mandatory at 

T-0, and two (2) tracking sources mandatory by 3 seconds prior to MTE. A potential 

consequence of this change is that at T-0, a loss of one tracking source may mean 

violation to FAA requirements (the FAA still requires no less than two tracking sources 

prior to lift-off). 

 

It should be noted that it is not a full reversal to exactly the same way as was done prior to 

the original 2012 range policy, in particular because some of the original range tracking 

assets used at the time of the original assessment have been retired and some even 

removed. However, this practice would follow essentially the same tracking requirements 

as required by the FAA, but with the utilization of different range assets. 

The result is that the current practice is actually more conservative than its predecessor 

that the FAA had previously determined to be an ELS. As such, with a more conservative 

practice that in the end would result in a safer operation, this proposed change would, like 

its predecessor be considered a “meets intent”, and result in being considered also an 

equivalent level of safety. 

Conclusion 

The approaches as described by the ER do not impact FAA requirements and provide an 

equivalent level of safety. Formalizing these changes will require the FAA to initiate a 

rulemaking activity. The equivalent level of safety evaluation and process will suffice for 

these and future changes until a rulemaking activity is completed. 
14

FAA REVIEW OF 

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-05: Regarding Flight Safety, Public Risk Criteria (Expected Casualty)

As applied to Launch Site Safety Assessment Matrix Item E-05. 

 

Intent 

This report documents the assessment of changes to risk criteria for flight safety, by US 

Federal Ranges and documents the FAA’s rule making leading to a published revision in its 

launch rules, permitting a determination of an equivalent level of safety (ELS) for the range. 

Background

In accordance with Air Force Instruction (AFI) 91-217, published 18 February 2010, the 

Air Force modified its requirements for public risk on Air Force launch ranges for 

government launches to now be 0.0001 (100 x 10-6). The direction by that AFI 

necessitated an amendment to the AFSPCMAN 91-710 (2004), which resulted in its 

revised requirements no longer being in sync with the then current FAA requirements. 

The FAA’s risk threshold was under 14 CFR § 417.107(b)(1), dated 25 August 2006. 

The FAA criteria was for the risk associated with the total flight to all members of the 

public does not exceed an expected average number of 0.00003 casualties (Ec≤ 30 × 10-6) 

from impacting inert and impacting explosive debris, (Ec ≤ 30 × 10-6) for toxic release, 

and (Ec ≤ 30 × 10-6) for far field blast overpressure. Originally, licensed launches with 

such risks exceeding FAA criteria would require the licensed operator to request a waiver 

to that requirement. 

Discussion

On 20 July 2016, the FAA published a revision to its requirements for risk, where it no 

longer lags behind AF ranges. The final rule revises the acceptable risk threshold for 

launch from the previous Ec requirement of 30 × 10-6 for each hazard to an Ec of 1 × 10-4

for all three hazards combined. Furthermore, this final rule expresses the revised Ec 

limit using the correct number of significant digits to properly represent the uncertainty 

in Ec calculations. This final rule changes the FAA’s collective risk limits for launch 

and reentry to more closely match the Ec standard currently used by the US Air Force 

and NASA for government missions, and to account for the level of uncertainty that 

exists in the Ec calculations. The revision with supportive preamble is found in the 

Federal Register, published on 20 July 2016. 

(Link: Federal Register/Vol. 81, No. 139/Wednesday, July 20, 2016).

Conclusion

The Range current practices are now in sync with the FAA’s revised requirements, 

allowing a determination of an Equivalent Level of Safety. 
15

FAA REVIEW OF

CHANGES TO FEDERAL RANGE CURRENT PRACTICES FOR 

DETERMINATION OF EQUIVALENT LEVEL OF SAFETY

(Revision 0)

E-##: Future ELS Determinations Will Be Placed Here Over Time 

As applied to Launch Site Safety Assessment Matrix Item E-##. 

 

[Placeholder for Additional ELS Determinations of Changes in Federal Range Practices in 

the Future. This Document will grow along with the LSSA Matrix for which it supports].