Commercial Space Launches: FAA Needs Continued Planning and Monitoring to Oversee the Safety of the Emerging Space Tourism Industry
Published: 2006-10-20T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2004, the successful launches of SpaceShipOne raised the possibility of an emerging U.S. commercial space tourism industry that would make human space travel available to the public. The Federal Aviation Administration (FAA), which has responsibility for safety and industry promotion, licenses operations of commercial space launches and launch sites. To allow the industry to grow, Congress prohibited FAA from regulating crew and passenger safety before 2012, except in response to high-risk events. GAO evaluated FAA's (1) safety oversight of commercial space launches, (2) response to emerging issues, and (3) challenges in regulating and promoting space tourism and responding to competitive issues affecting the industry. GAO reviewed FAA's applicable safety oversight processes and interviewed federal and industry officials.
section_title: What GAO Found
paragraphs: Several measures indicate that FAA has provided a reasonable level of safety oversight for commercial launches. For example, none of the 179 commercial launches that FAA licensed over the past 17 years resulted in fatalities, serious injuries, or significant property damage. However, FAA shared safety oversight with the Department of Defense (DOD) for most of these launches because they took place at federal launch sites operated by DOD. In addition, FAA's licensing activities incorporate a system safety process, which GAO recognizes as effective in identifying and mitigating risks. GAO's analysis of FAA records indicates that the agency is appropriately applying management controls in its licensing activities, thereby helping to ensure that the licensees meet FAA's safety requirements. In response to emerging issues in the commercial space launch industry, such as the potential development of space tourism, FAA has developed safety regulations and training for agency employees. The industry has raised concerns about the costs of complying with regulations and about the flexibility of the regulations to accommodate launch differences. However, FAA believes it has minimized compliance costs by basing its regulations on common safety standards and has allowed for flexibility by taking a case-by-case approach to licensing and by providing waivers in certain circumstances. FAA faces several challenges and competitive issues in regulating and promoting space tourism. For example, FAA expects to need more experienced staff for safety oversight as new technologies for space tourism evolve, but has not estimated its future resource needs. Other challenges for FAA include determining the specific circumstances under which it would regulate space flight crew and passenger safety before 2012 and balancing its responsibilities for safety and promotion to avoid conflicts. Recognizing the potential conflict in the oversight of commercial space launches, Congress required the Department of Transportation (DOT) to commission a report by December 2008 on several issues, including whether the promotion of human space flight should be separate from the regulation of such activity. In addition, U.S. commercial space launch industry representatives said that they face competitive issues concerning high launch costs and export controls that can affect their ability to sell services overseas. The federal government has provided support to the industry to help lower launch costs.

section_title: Letter
paragraphs: In 2004, the successful launches of SpaceShipOne raised the possibility of  an emerging commercial space tourism industry that would make human  space travel available to the public for the first time. Previously, human  space travel in the United States was limited to the National Aeronautics  and Space Administration’s (NASA) flights. SpaceShipOne is a reusable  launch vehicle that resembles an airplane. It was launched from an  airplane into space, where it traveled nearly 70 miles above the earth (an  altitude known as suborbital space), and returned to the original launch  site. Designed to carry two crew members and one passenger,  SpaceShipOne is the first commercial reusable launch vehicle licensed by  the Federal Aviation Administration (FAA). Several companies in addition  to SpaceShipOne’s designer, Scaled Composites, LLC, are developing  reusable launch vehicles for commercial space tourism and plan to start  operations within the next few years. Historically, commercial space  launches carried payloads, generally satellites, into orbit using expendable  launch vehicles that did not return to earth.
In 2004, the U.S. commercial space launch industry accounted for $1.7  billion in economic impact, according to FAA. At that time, the industry  consisted of a few FAA-licensed launch companies that operated primarily  from Department of the Air Force launch sites. Currently, the industry  appears to be expanding—more firms are applying to FAA for launch  licenses, and several commercial spaceports are being planned. One space  tourism company, Virgin Galactic, which intends to start operations in  2009 and to initially charge $200,000 per passenger, plans to carry 3,000  passengers over the subsequent 5 years on space flights, with 100  individuals having already paid the full fare. In addition, the U.S.  commercial space launch industry faces strong competition from  international companies, primarily from Russia and Europe, offering  satellite launches on expendable launch vehicles. Russia is also the only  nation that has commercially launched humans into space, with four  individuals having paid an estimated $20 million each for orbital space  flights.
The federal government regulates and supports the commercial space  launch industry to varying degrees. In 1984, the Commercial Space Launch  Act gave the Department of Transportation (DOT) the authority to license  and monitor the safety of commercial space launches and to promote the  industry. In 2004, the Commercial Space Launch Amendments Act gave  FAA the specific responsibility of overseeing the safety of space tourism,  but the act prohibits FAA from regulating crew and passenger safety  before 2012, except in response to high-risk incidents, serious injuries, or  fatalities. The Department of Defense (DOD), through the Air Force,  provides infrastructure, operations support, and safety oversight for  government and commercial launches at its launch sites. The Department  of Commerce (Commerce) is also responsible for promoting the  commercial space industry.
This report discusses the federal role in commercial space launches and  the government’s response to emerging industry trends—both  domestically and internationally. In this review, we addressed the  following questions:    How well does FAA oversee the safety of commercial space launches?
To what extent is FAA responding to key emerging issues in the  commercial space launch industry?
What challenges does FAA face in regulating and promoting the  commercial space launch industry?
What are the key competitive issues affecting the U.S. commercial space  launch industry, and to what extent are the industry and government  responding to them?
To determine how well FAA is overseeing the safety of commercial space  launches, we reviewed the agency’s safety oversight processes, including  the documentation of its licensing and safety monitoring processes,  internal guidance and policies, applicable regulations, and memoranda of  agreement with other federal agencies. We also reviewed FAA’s use of  system safety procedures and interviewed industry experts and FAA  officials. Because FAA relies on the Air Force to conduct safety oversight  at the Air Force’s two primary launch sites in Florida and California, we  reviewed Air Force launch safety requirements and interviewed FAA and  Air Force officials about their respective responsibilities and interaction.  In addition, we examined FAA’s application of certain management  controls in its licensing and monitoring processes using our guidelines for  management controls at federal agencies, such as documentation and  timeliness of the review process and communication and consultation  with relevant federal agencies. To determine the extent to which FAA is  responding to key emerging issues in the commercial space launch  industry, such as space tourism, we identified these issues through  literature reviews and assessed the extent of FAA’s response through  interviews with federal government officials and industry representatives.  These industry representatives were from associations that represent the  commercial space launch industry and from entities that had received  launch or launch-site licenses from FAA or were consulting with FAA  about receiving such licenses as of September 2005. We also interviewed  these officials and representatives to identify the challenges FAA faces in  regulating and promoting the commercial space launch industry. To  determine the key competitive issues affecting the U.S commercial space  launch industry and the extent to which the industry and the federal  government are responding to them, we conducted a literature review that  included applicable laws affecting industry competitiveness and  interviewed agency officials, industry representatives, and industry  experts to obtain their views. We conducted our review from August 2005  through October 2006 in accordance with generally accepted government  auditing standards. Appendix I contains additional information about our  objective, scope, and methodology.
subsections: section_title: Background
paragraphs: There are three main types of space launches—national security, civil, and  commercial. National security launches are by DOD for defense purposes,  and civil launches are by NASA for scientific and exploratory purposes.  Many commercial launches are internationally competed and carry  payloads, such as satellites, that generate revenue. In 1984, the  Commercial Space Launch Act required the Secretary of Transportation to  “encourage, facilitate, and promote commercial space launches by the  private sector.” At that time, the U.S. government was the sole entity  launching civil and commercial payloads into orbit from the United States.  However, as a result of the Space Shuttle Challenger accident in January  1986, the U.S. government transferred responsibilities for commercial  payload launches to the private sector. Space launches by private sector  companies grew as U.S. commercial launch companies responded to the  increase in global demand for commercial satellite launch services in the  mid-1990s. Nonetheless, following a downturn at the beginning of this  century in the business of the commercial space launch industry’s primary  commercial customer, the telecommunications services industry, the  demand for commercial space launches has generally declined. As shown  in figure 1, the total number of U.S. and worldwide commercial orbital  launches has declined from a peak of 41 launches in 1998.
The U.S. commercial space launch industry, comprising a few launch  companies, has historically used federal sites to launch satellites using  expendable vehicles, which are designed to be launched once. According  to FAA, the launch vehicle manufacturing and services sector of the  commercial space industry had $1.7 billion in economic impact on the U.S.  economy for 2004, with the greatest economic impacts to enabling  industry sectors such as satellite manufacturing and services. (See app. II  for more information on the industry and its economic impact.)
The commercial space launch industry is changing with the emergence of  suborbital reusable launch vehicles that enable space tourism from state- sponsored or private launch sites, known as spaceports. (See fig. 2 for  examples of expendable and reusable launch vehicles.)
The prospect for commercial space tourism materialized in 2004 when  SpaceShipOne, developed by Scaled Composites, flew to space twice,  achieving a peak altitude of about 70 miles to win the Ansari X Prize.  Several entrepreneurial launch companies are planning to start taking  paying passengers, also known as space flight participants, on suborbital  flights within the next few years. Virgin Galactic intends to enter  commercial suborbital space flight service around 2009, launching from a  spaceport in New Mexico, and according to the company, plans to carry  3,000 passengers over the subsequent 5 years, with 100 individuals having  already paid the full fare of $200,000. In addition, 4 individuals have  already paid an estimated $20 million each for space flights to the  International Space Station on a Russian vehicle that launches from  Kazakhstan. According to a Futron Corporation market study on space  tourism, the orbital and suborbital space tourism market could attract up  to 15,000 passengers and generate revenues in excess of $1 billion per year  by 2021, with suborbital space tourism likely generating the most  demand. Several other companies in the United States and elsewhere,  including former Ansari X Prize competitors, continue to develop their  vehicles for space tourism. For example, Russia is developing a reusable  launch vehicle, Cosmopolis 21, for space tourism flights.
Spaceports are being developed to accommodate anticipated commercial  space tourism flights and are expanding the nation’s launch capacity. As of  August 2006, the United States had five federal launch sites, six spaceports  with an FAA launch site operator’s license, and an additional eight  spaceports have been proposed (see fig. 3). Although their individual  capabilities and level of infrastructure development vary, these facilities  may house launch pads and runways as well as the buildings, equipment,  and fuels needed to prepare vehicles and payloads before launch. The  spaceports are operated by state or local governments and authorities and  by private entities. These spaceports also face competition from abroad.  Space Adventures, a U.S.-based space tourism broker, in partnership with  other investors, plans to develop a $115 million spaceport near Changi  Airport in Singapore and a $265 million spaceport in Ras Al-Khaimah near  Dubai in the United Arab Emirates.
subsections: section_title: Federal Agencies’ Roles and Responsibilities in the Commercial Space Launch Industry
paragraphs: Several federal agencies regulate and support the commercial space  launch industry. FAA oversees the safety of all commercial launches— both expendable and reusable launch vehicles from federal launch sites  and spaceports—through its licensing, compliance monitoring, and safety  inspection activities. FAA licenses launches to ensure the health and  safety of the public and the safety of property. The agency licenses all  commercial launches that take place in the United States. In addition, it  licenses all overseas launches by U.S. citizens or companies. FAA  generally does not license launches by the U.S. government, nor does it  license the operation of federal launch sites. In issuing launch and  launch-site operator licenses, FAA does not certify the launch vehicle as  safe; in contrast, FAA’s Office of Aviation Safety provides initial  certification of aircraft and periodically inspects an aircraft and certifies it  as safe to fly. FAA can also issue experimental permits for launches of  reusable vehicles conducted for research and development, for  demonstrations of compliance with licensing requirements, or for crew  training before obtaining a license. During commercial launches, FAA  aerospace engineers are on-site to monitor licensees’ compliance with  license and permit requirements. For 179 commercial launches conducted  between March 1989 and August 2006, FAA has issued licenses for 63  launch vehicles and six spaceports. In addition, FAA has issued one  experimental permit for a suborbital reusable vehicle. (See app. III for  more information about FAA’s launch licensing process.) Furthermore,  FAA is responsible for promoting the industry, which the agency said it  accomplishes by sponsoring an annual industry forecast conference,  publishing industry studies, and conducting outreach to potential launch  companies. FAA also consults with industry through its advisory  committee, the Commercial Space Transportation Advisory Committee,  which provides advice and recommendations to the FAA Administrator.  This advisory committee has working groups comprising industry  representatives who consult on reusable launch vehicle development and  launch operations and support, among other commercial space subjects.
Other federal agencies support the commercial space launch industry to  varying degrees. DOD provides guidance and safety oversight for  government and commercial launches at federal launch sites. The Air  Force also operates the government’s two primary commercial launch  sites—Cape Canaveral Air Force Station in Florida and Vandenberg Air  Force Base in California—and provides infrastructure and operations  support. In addition, the Department of the Army operates a launch site at  the White Sands Missile Range in New Mexico and at the Ronald Reagan  Ballistic Missile Test Site in the Marshall Islands. Commercial launches at  federal launch sites occur when “excess capacity” is available and the  launch company reimburses DOD for the direct use of government  services. Three U.S. companies—Boeing, Lockheed Martin, and Orbital  Sciences—have been the primary commercial users of DOD launch  facilities. In support of its mission to have assured access to space, DOD  also has supported the industry through investments in the design and  development of small, medium, and heavy lift launch vehicles, which have  been used for both government and commercial launches.
Under the Technology Administration Act of 1998, Commerce is to serve  as an advocate for the commercial space industry. Its Office of Space  Commercialization, established in 1988 within the Office of the Secretary  of Commerce and now located within the National Oceanic and  Atmospheric Administration, is responsible for promoting commercial  investment in the industry by, among many activities, collecting and  disseminating information on space markets; conducting workshops on  commercial space opportunities; promoting space-related exports; and  seeking the removal of legal, policy, and institutional impediments to  space activities. Commerce’s International Trade Administration also  promotes the commercial space industry in matters concerning  international trade through such activities as trade events, advocacy  programs, and the development of policies to further U.S. industry  competitiveness. In addition, Commerce regulates export of space  technologies that are considered dual-use items—that is, items with  military and civilian uses—and is a customer of satellite launches.
NASA’s support for the commercial space launch industry includes   (1) providing infrastructure and range support from its Wallops Flight  Facility in Virginia and radar support for commercial launches from DOD  launch sites and (2) encouraging private sector investment in NASA  launches and other activities. Since the 1985 National Aeronautics and  Space Administration Authorization Act, Congress has required NASA to  “seek and encourage, to the maximum extent possible, the fullest  commercial use of space.” In January 2004, the President announced the  Vision for U.S. Space Exploration, which directed NASA to pursue  commercial opportunities for providing transportation and other services  supporting the International Space Station and exploration missions  beyond low-Earth orbit. Congress supported this direction in the NASA  Authorization Act of 2005 by requiring NASA to develop a  commercialization plan that (1) identifies opportunities for the private  sector to participate in NASA missions and activities in space and (2)  emphasizes the use of advancements made by the private sector in  developing launch vehicles. One such opportunity is NASA’s Commercial  Orbital Transportation Services demonstration program, for which NASA  solicited proposals from private industry in March 2006 to demonstrate  cargo and crew space transportation to low-Earth orbit and awarded two  contracts in August 2006.
Other federal agencies support commercial launches in various ways.  DHS’s Transportation Security Administration (TSA) is responsible for  security policy, compliance, and related issues for commercial space  transportation. TSA also is responsible for establishing national standards  for transportation and infrastructure security for commercial space  transportation. The Department of State ensures that domestic space  policies support U.S. foreign policy objectives and international  commitments. State also regulates the export of space technology and  represents the United States on the United Nations Committee on the  Peaceful Uses of Outer Space. The White House Office of Science and  Technology Policy (OSTP) and the National Security Council (NSC)  develop and manage commercial space launch policymaking by mediating  among federal agencies and reporting to the President on space policy  issues, among other duties. The Office of the U.S. Trade Representative  (USTR) negotiates and monitors commercial space launch industry trade  agreements as needed. (See fig. 4 for a summary of federal agencies’ roles  and responsibilities.)
section_title: FAA Has Met Its Safety Performance Goal While Using a System Safety Process and Management Controls
paragraphs: FAA has met its safety performance goal of no fatalities, serious injuries,  or significant property damage to the public; however, the Air Force’s  oversight of its launch sites has contributed to this achievement. FAA’s  oversight of launches includes the use of a system safety process in its  licensing and monitoring process and incorporation of management  controls, which we have reported to be effective means of providing safety  oversight and program management.
subsections: section_title: FAA Has Met Its Safety Performance Goal of No Fatalities or Substantial Property Damage
paragraphs: FAA has met its annual performance goal to have no fatalities, serious  injuries, or significant property damage to the public during licensed space  launches and reentries since establishing this goal in 2003. Moreover,  according to FAA, none of the 179 commercial launches that occurred  between March 1989 and August 2006 resulted in casualties or substantial  property damage. Of these 179 launches, FAA had joint oversight  responsibility with other federal agencies for 152 (about 85 percent) and  sole responsibility for 27 (about 15 percent) that included sea launches  and the launches of SpaceShipOne from Mojave Spaceport. FAA shared  responsibility with the Air Force for 132 launches at Air Force launch sites  and with NASA, the Army, or foreign governments for 20 launches at  NASA’s Wallops Flight Facility in Virginia, the Army’s White Sands Missile  Range in New Mexico, and other facilities. Thus, the majority of  commercial space launches during this period took place at Air Force  launch sites where the Air Force had primary responsibility for safety  oversight. We discuss later in this report the challenges that FAA faces in  the future in assuming sole responsibility for launch safety oversight at  spaceports.
section_title: FAA’s Licensing Process Incorporates System Safety
paragraphs: FAA incorporates a system safety process in its oversight of commercial  launches by requiring the launch company to use system safety in the  development and operation of its vehicle and in applying system safety  methodologies to calculate the risk posed by a launch. As we have  reported, a system safety process is an effective evaluative method of  identifying and mitigating risks. Specifically, system safety relies on the  application of technical and managerial skills to identify, analyze, and  control hazards and risks. An objective of a system safety process is to  identify hazard trends to spot and correct problems at their root cause  before an incident occurs.
During the licensing process, the launch company is responsible for  system safety by demonstrating that it has assessed all hazards and risks  posed by its launch operations and has proposed how to mitigate them.  The assessment is focused on safety critical systems, such as a vehicle’s  main structure, propulsion system, and flight safety systems, whose  performance or reliability can affect public safety and the safety of  property. Through the development of a system safety program plan, the  launch company applicant demonstrates that the proposed vehicle design  and operations satisfy regulatory requirements, and that the system is  capable of performing safely during all flight phases, including launch and  reentry. The plan provides a description of the strategy by which  recognized and accepted safety standards and requirements, including  organizational responsibilities, resources, methods of accomplishment,  milestones, and levels of effort, are to be tailored and integrated with other  system engineering functions. FAA consults with an applicant early in its  launch vehicle development to help the applicant understand what must  be included in the system safety program plan. In addition, FAA reviews  the final system safety program plan as part of its safety review of the  license application.
Another way in which FAA incorporates system safety in its oversight of  commercial launches is by conducting a risk analysis for each launch. FAA  calculates, for each launch, the expected average number of casualties  (deaths or serious injuries) to the public from debris hazards in the  proposed flight path. This risk level—no more than 30 per million for the  public and no more than 1 per million for an individual—is consistent with  the launch standards used at federal launch sites. According to FAA, the  risk to the public from commercial launches should not exceed “normal  background risk”—that is, no greater risk than is voluntarily accepted in  the course of normal day-to-day activities. For licensing launch-site  operations, FAA performs a similar safety review that includes a risk  analysis, which considers the site’s proximity to populated areas and a  review of security planned at the facility. The risk analysis is both site- specific and vehicle-specific, and FAA reviews the results on a case-by- case basis because of differences between launch sites and vehicle  designs.
An expert on system safety confirmed our assessment that FAA has  appropriately applied a system safety process to its launch license  activities. In particular, the expert said that FAA has identified all of the  safety systems that are critical to commercial space launches, made the  proper assumptions of risk, and used proper validation methodologies. He  also noted that FAA has used a higher factor of safety for commercial  space launches than is commonly used in other industries, which is  appropriate given that the space launch industry has a high-risk profile.  However, the expert said that FAA should update its system safety  handbook as the space tourism sector matures to incorporate different  launch methods, such as launches from land, sea, and air, which may have  different safety implications.
section_title: FAA Has Applied Management Controls in Its Licensing Process
paragraphs: FAA is applying relevant management controls in its licensing process.  Management controls that we reviewed include the documentation of the  review and approval of licenses, compliance with timely review  requirements, communication with other federal agencies, and reliability  and verification of data. According to our review of the 19 applications for  launch and launch-site licenses that were active as of January 2006, FAA is  applying these management controls. FAA accurately documented the  review and approval process and completed its reviews of license  applications within 180 days, as required by the Commercial Space Launch  Act. However, FAA starts counting the 180 days after deciding that an  application is sufficiently complete. Our analysis showed that FAA  communicated and consulted on an as-needed basis with other federal  agencies that are members of an interagency advisory group on  expendable launch vehicles, as required by an executive order that  designates DOT as lead agency within the federal government for  commercial space launches. This communication includes coordinating  with other federal agencies during the licensing process. Representatives  from the majority of agencies serving on the group told us that FAA had  periodically contacted them during its review of license applications. For  example, agency representatives told us that FAA had checked with DOD  on whether certain launches would negatively affect national security, and  with State on whether launches were consistent with international  treaties. In addition, our analysis showed that FAA verified the  information in the applications for accuracy.
section_title: FAA Has Developed Regulations and Training to Respond to Emerging Issues
paragraphs: In response to changes in the commercial space launch industry, including  the emerging issues of anticipated growth in space tourism, FAA issued  regulations in 2000 for the licensing of launch and reentry of reusable  launch vehicles. The regulations for reusable launch vehicles require  launch operators to obtain a safety approval from FAA in order to receive  a license. In August 2006, FAA issued regulations that include safety  requirements that applicants must meet to obtain a license for operations  of expendable launch vehicles. The 2006 regulations cover license  requirements for any launch of a commercial expendable launch vehicle  from any launch site, whether a federal launch site or a spaceport.  However, some industry experts raised questions about the  appropriateness of the regulations for operations at spaceports and also  expressed concern about both existing and potential future safety  requirements for reusable launch vehicles, which can vary widely in design  and operation. In addition, FAA has developed training for its aerospace  engineers to help prepare them to assume safety oversight responsibility at  spaceports.
subsections: section_title: FAA Has Developed Safety Regulations for Launch Vehicles and Launch Sites
paragraphs: FAA’s regulations for operations of launch vehicles and launch sites are  based on common safety standards, which were developed jointly by FAA  and the Air Force to harmonize the respective agencies’ safety practices.  (See app. IV for a timeline and list of FAA’s commercial space launch  rulemaking and guidance.) These safety standards cover vehicle design  and operations and criteria for acceptable risks for launch and launch-site  operations, such as the siting of hazardous materials. The regulations  build on those common standards with the goal of promoting consistent,  streamlined safety reviews of launch operations.
However, concerns have been raised regarding the suitability of the 2006  regulations, which are based on the experience of expendable launch  vehicles at federal launch sites, for launches at spaceports. Some industry  experts that we interviewed noted that differences in spaceports from  which vehicles are or will be launched raise questions about the  appropriateness of the regulations. Additionally, while the 2006  regulations only apply to expendable launch vehicles, industry experts  expressed concern about safety regulation of reusable launch vehicles,  given the difference in the design of vehicles and the methods for  launching them. FAA stated that it addresses these concerns by (1) making  license determinations on a case-by-case basis using common  performance standards and (2) providing waivers in special  circumstances. Performance standards require launch companies to meet  certain performance thresholds—a risk level, calculated by an expected  casualty analysis, of no more than 30 per million for the public and 1 per  million for an individual—while allowing these companies to develop their  own specific launch vehicle design. FAA said that it uses performance  standards to encourage innovation in vehicle design, rather than being  prescriptive on how the vehicle should be designed. FAA said that its  ability to issue waivers of license requirements for special circumstances  allows it to assess the unique characteristics of a launch and its impact on  safety. FAA, for example, granted a waiver at Mojave Spaceport that  allowed for the storage and handling of liquid propellants closer to the  runway—which would be used for a horizontal launch, such as  SpaceShipOne—than would have been allowed for a vertical launch. Later  in this report, we discuss the challenges that FAA faces in ensuring that its  regulations are suitable for the emerging space tourism sector.
In addition, industry officials and one expert with whom we spoke raised  concerns about the costs that expendable launch vehicle companies would  incur to comply with the proposed regulations, because they believe that  FAA’s safety requirements at federal launch sites will be in addition to the  Air Force’s requirements. However, according to FAA, it has minimized  these companies’ costs by ensuring that its safety standards are the same  as the Air Force’s, and that waivers issued by FAA or the Air Force are  accepted by both agencies. FAA officials also noted that they have the  authority to implement an option that they said could potentially reduce  costs for both launch companies and the agency—namely, to issue a safety  approval that is separate from a licensing determination. For example,  they said that FAA could approve a component of a vehicle, such as a  flight termination system, which could then be used for multiple licenses.  This approval could reduce uncertainty and costs for the vehicle  manufacturer and save FAA the cost of evaluating the component for each  license. As of August 2006, FAA had not made any such approvals.
section_title: FAA Has Developed Training to Respond to Space Tourism
paragraphs: FAA has developed training for its aerospace engineers that focuses on  oversight duties and technical areas. According to FAA, the oversight  training addresses evaluations of license and permit applications; safety  inspections of launch, reentry, and site operations; and mishap  investigations of launch and reentry vehicles. Technical training addresses  system safety, flight safety analyses, and flight safety systems. The training  is either provided in-house or obtained from commercially available  sources and other government agencies. In addition, to help its aerospace  engineers develop expertise that will be applicable to reusable launch  vehicles, employees from FAA’s Office of Commercial Space  Transportation who are pilots and familiar with aircraft certification  systems share their expertise with other staff. FAA also has sent its  aerospace engineers to NASA and Air Force courses on launch and space  flight operations, which include procedures for the launch and recovery of  vehicles; FAA courses on avionics and aircraft operations, which are  relevant because reusable launch vehicles have aircraft characteristics;  and National Transportation Safety Board courses on aviation accident  investigation, which includes procedures that would be useful in the event  of a launch incident. While this training will help FAA to respond to  current emerging issues, it will be important for FAA to keep abreast of  industry changes and train their aerospace engineers accordingly.
section_title: FAA Faces Challenges in Fulfilling Its Responsibilities for Regulating the Emerging Space Tourism Sector
paragraphs: FAA faces multiple challenges in responding to the emergence of the  space tourism sector. Those challenges include obtaining the expertise  and resources needed to provide safety oversight of the sector, ensuring  that its various regulations are suitable for the different launches and  launch sites it licenses, determining the circumstances under which it  would regulate passengers and crew, and ensuring that its industry  promotion responsibilities do not conflict with its safety oversight  responsibilities.
subsections: section_title: FAA Faces Human Resources and Workload Challenges in Addressing Its Responsibilities for Licensing Reusable Vehicles
paragraphs: If the space tourism industry develops as rapidly as some industry  representatives suggest, FAA’s responsibility for licensing reusable launch  vehicles will greatly expand. However, FAA’s experience in this area is  limited because its launch safety oversight has focused primarily on  unmanned orbital launches. From 1989 to 2005, FAA issued two reusable  launch vehicle licenses that were mission-specific and conducted  compliance monitoring and safety inspections for five reusable launch  vehicle missions. Although FAA gained some experience and expertise  from these missions, some industry representatives and experts with  whom we spoke questioned whether FAA is prepared for its expanded role  and raised concerns about whether FAA has sufficient experience and  expertise. Experts also indicated that FAA must stay ahead of the  development of the reusable launch vehicle industry to fulfill its safety  oversight responsibilities, because many companies are developing space  hardware for the first time and are producing different designs that have  not been tested. For example, a safety incident occurred during a  SpaceShipOne flight when the vehicle deviated from the launch trajectory  and flew over a populated area. FAA evaluated this incident and required  Scaled Composites, the developer of SpaceShipOne, to take corrective  measures to continue its licensed flights. During its next flight,  SpaceShipOne unexpectedly rolled 29 times, which FAA did not classify as  an incident. In addition, retaining staff expertise may also be a challenge,  given federal funding constraints and competition within the industry for  qualified aerospace engineers. We have reported on the challenges the  aerospace industry faces in attracting, training, and retaining new workers  with the engineering, science, and technical capabilities it needs, given  recent trends in the decline of the future supply of such workers. In  FAA’s case, two of the five aerospace engineers who worked on the  licensing and monitoring of SpaceShipOne flights are no longer with the  agency. However, FAA said that it has since filled these positions.
To help evaluate the safety of reusable vehicle launches, FAA’s Office of  Commercial Space Transportation has obtained expertise from outside  firms and other FAA offices. For example, FAA contracted with a  consulting firm to verify the expected casualty analysis involving  SpaceShipOne’s flights. In addition, because of certain similarities  between reusable launch vehicles and aircraft, the Office of Commercial  Space Transportation has consulted with FAA’s Office of Aviation Safety.  Both of these FAA offices, for example, worked on SpaceShipOne’s  license application and had a documented agreement that described how  the offices would work together. However, according to Scaled  Composites, confusion existed during the licensing process regarding the  respective authorities of the FAA offices. For instance, Scaled Composites  was required to have two authorizations—one for its vehicle and one for  its launch operations. Initial vehicle flight tests to demonstrate “proof of  concept” were conducted by the Office of Aviation Safety. Once Scaled  Composites was ready to conduct launch operations, the Office of  Aviation Safety transferred the vehicle review to the Office of Commercial  Space Transportation, which reviewed the launch for licensing. According  to an Office of Aviation Safety inspector, communication between the two  offices, especially during the transfer stage of the review of SpaceShipOne,  was not clear. In addition, an FAA engineer stated that distinctions  between the two offices’ respective authorities had to be made so that  there was no overlap and disagreement between the offices. Since the  licensing of SpaceShipOne, the Commercial Space Launch Amendments  Act of 2004 clarified responsibility by stating that only one license would  be required by DOT to approve commercial space launches, and this  responsibility has been designated to the Office of Commercial Space  Transportation. However, the two offices still need to coordinate on  license reviews for operations of hybrid vehicles having both aircraft and  rocket-like characteristics, according to officials in both offices.  Nonetheless, no formal process exists between the two offices that  outlines when and under what circumstances the offices should consult.  While the documented agreement between the offices described how they  would authorize flights of SpaceShipOne, this document is specific to  those flights and is not generic for future reusable launch vehicle licenses.
FAA’s safety oversight of the commercial space launch industry may be  further challenged, in part, because of the expected increase in workload  demands facing agency staff. FAA is anticipating a substantial increase in  the number of permit and launch applications that could be submitted for  reusable launch vehicle and launch-site operations in the near future, but  FAA has not quantified the magnitude of applications. For example, FAA’s  annual industry forecast does not include projected reusable vehicle  launches. FAA said that its anticipated increase in applications is based on  preapplication consultations that FAA has conducted with reusable launch  vehicle companies and spaceports. In addition, an FAA official noted that  companies with existing reusable launch vehicle licenses are likely to  apply for additional permits or licenses for the new vehicles they are  developing. Furthermore, launch companies participating in NASA’s Lunar  Lander Challenge and Commercial Orbital Transportation Services  demonstration program and Commerce’s Geostationary Operational  Environmental Satellite Program are required to obtain commercial launch  permits or licenses from FAA. FAA initially plans to be present for every  licensed launch of a reusable vehicle. If FAA carries out this plan, its staff  workload would increase, since the proposed spaceports for space  tourism flights are located throughout the country and space tourism  companies are planning frequent launches. FAA has not determined the  level of resources needed to meet this expected increase in responsibilities  involving reusable launch vehicles. Agency officials said that they monitor  the industry to assess how its development could impact resource  requirements and will not make a budget request for additional resources  until the workload has grown to justify the request. However, the agency  has not conducted scenarios of different workload projections on the  basis of increased space tourism launches.
section_title: FAA Faces the Challenge of Ensuring That Its Various Regulations Are Suitable for Launches
paragraphs: FAA faces the challenge of ensuring that its 2006 regulations on licensing  and safety requirements for launch, which are based on the Air Force’s  safety requirements for expendable launch vehicle operations at federal  launch sites, will be suitable not only for operations at federal launch sites,  but also for operations at spaceports. As we previously mentioned,  industry representatives and experts are concerned that the safety  regulations for reusable launch vehicles may not be suitable for space  tourism flights because of differences in vehicle types and launch  operations. Table 1 contains a comparison of some of the differences  between expendable and reusable launch vehicles.
Three of the six operators of licensed spaceports and six of the eight  operators of spaceports in the licensing process told us they did not  believe that FAA’s regulations should apply to the new spaceports. Five of  these spaceport officials said that since reusable vehicles can be launched  differently from expendable vehicles and can return to earth, the reusable  vehicles present different safety implications.
In addition, concerns about the suitability of the safety regulations were  raised by experts we interviewed and by comments filed in the public  docket for these regulations. While it was noted that the regulations were  appropriate to spaceports if the vehicles launching from them are using  exotic or dangerous fuels, concerns were raised that the rules may be too  stringent for the currently proposed and operating reusable launch  vehicles. Although the safety regulations applicable to expendable launch  vehicles are separate from the safety approvals required to obtain a  reusable launch vehicle license, some experts are concerned about  similarities in the safety rules. For example, two experts noted that the  expected casualty analysis that is the same for launches of expendable  and reusable vehicles might be too high for reusable vehicles, given the  vehicles’ different safety implications. Experts also said that safety  regulations should be customized for each spaceport to address the  different safety issues raised by different orbital trajectories and the  differences in the way that vehicles launch and return to Earth—whether  vertically or horizontally. (See fig. 5 for examples of vertical federal launch  sites and spaceports.) To address these concerns, experts have noted that  it will be important to measure and track safety information and use it to  determine if the regulations should be revised. For example, an expert  noted that FAA should identify and track safety indicators for launch  companies and spaceports and, as the industry matures, conduct trend  analyses with the objective of eliminating negative situations  representative in the trends. Another expert noted that any safety  performance measure should account for different launch and trajectory  tracks, such as over land or over water. Yet another expert noted that  FAA’s proposed regulations for experimental permits allow FAA to collect  statistical data that could then be applied to develop safety standards  criteria. FAA says that it collects data on anomalies and failures of safety- critical systems, which will allow it to analyze safety trends and determine  potential precursors to accidents. However, the agency has not conducted  trend analyses of that information. Other industry experts noted that the  regulations should be revisited when the space tourism sector has further  developed. Meanwhile, the Commercial Space Launch Amendments Act of  2004 requires DOT to commission an independent report to be issued to  Congress and completed by December 2008. This report is to analyze  whether expendable and reusable vehicles should be regulated differently  from each other, and whether either of the vehicles should be regulated  differently if carrying passengers. This report could provide FAA with  information to address industry concerns about the suitability of its  regulations to space tourism.
section_title: FAA Faces the Challenge of Determining the Circumstances under Which It Would Regulate Crew and Flight Participant Safety on Space Tourism Flights before 2012
paragraphs: The Commercial Space Launch Amendments Act of 2004 requires that a  phased approach be used in regulating commercial human space flight,  and that regulatory standards evolve as the industry matures. The act  prohibits FAA from regulating crew and space flight participant safety  before 2012, except in response to incidents that either pose a high risk or  result in serious or fatal injury. However, the act maintains FAA’s  authority over protecting the uninvolved public, and FAA stated that it has  the authority to regulate crew and passenger safety to the extent that the  public would be affected. According to FAA, it is only prohibited from  issuing regulations that apply solely to crew and passenger safety, and any  situation that implicates the public would allow FAA to regulate. FAA  asserts that it has the authority to protect the crew because they are part  of the flight safety system that protects the general public. FAA’s proposed  regulations for human space flight would establish requirements for crew  qualifications and training and space flight participant training and  informed consent. Although these proposed regulations address passenger  and crew behavior, FAA believes that the regulations are within its  authority because they are intended to protect the public—not space flight  participants. For example, the proposed regulations would require an  operator to train each space flight participant before the flight on how to  respond to emergency situations, including loss of cabin pressure, fire,  smoke, and emergency egress. The proposed training requirement is aimed  at protecting public safety, because if a space flight participant did not  receive this training, he or she might interfere with the crew’s ability to  protect public safety.
The proposed regulations are not aimed solely at crew and passenger  safety and, as a result, there have been instances in which FAA has not  stepped in and imposed additional regulations or requirements for safety  reasons because the public was not implicated. For example, Scaled  Composites’ SpaceShipOne rolled 29 times, and, according to FAA, it did  not impose additional requirements because the flight was over a  unpopulated area, and because FAA concluded that the pilot was in  control of the vehicle. FAA monitored and reviewed the corrective actions  taken by Scaled Composites prior to its next flight. Additionally, FAA has  not developed specific criteria regarding when an incident would qualify  as contributing to “an unplanned event or series of events…that pose a  high risk of causing a serious or fatal injury” that would trigger FAA’s  authority to issue regulations specific to crew and passenger safety.
Experts and industry representatives that we interviewed expressed  different opinions about whether FAA should regulate crew and flight  participant safety and, if so, when. Some industry representatives and  experts we interviewed agreed that the Commercial Space Launch  Amendments Act of 2004 provides the industry with the flexibility needed  to innovate and grow. However, other experts said that there is too much  flexibility in the act. One of these experts noted that FAA should publish  the criteria that would cause it to regulate crew and flight participant  safety before 2012. Another expert said that FAA’s having the discretion to  decide when it would regulate crew and flight participant safety creates  uncertainty for the industry, noting that without published criteria, the  industry does not know how FAA would react to an incident involving a  space tourism company, which could seriously hurt the industry. The  designer of a reusable launch vehicle told us that FAA should regulate  crew and flight participant safety for commercial space flight because he  believes that space tourism needs to be as safe as commercial aviation.
Meanwhile, a trade association made up of space tourism companies and  spaceports—called the Personal Spaceflight Federation—plans to  commission standards for vehicles and their operation, including space  flight participant safety, as the space tourism industry develops. The  federation believes that ensuring the highest-possible level of safety for the  industry and sharing best practices will be essential to promote the safety  and growth of the industry. The federation intends to commission an  independent standards organization, such as the American Society for  Testing and Materials, to develop accredited industry standards for  voluntary testing and approval, much as Underwriters Laboratories, an  independent organization that tests electrical devices, has done. According  to an expert, while companies do not have to submit their products to  Underwriters Laboratories for testing, market acceptance is low and  liability exposure is high without the Underwriters Laboratories’ stamp of  approval. The expert believes that a similar approach will work for space  flight participants, who are more likely to choose to fly on a launch vehicle  that has been approved according to industry standards than on one that  has not been approved.
section_title: FAA’s Dual Role of Promotion and Safety May Pose a Challenge
paragraphs: FAA faces the potential challenge of overseeing the safety of commercial  space launches while promoting the industry as the space tourism sector  develops. According to our analysis, FAA’s current promotional activities  have not conflicted with its safety regulatory role; however, industry  experts have noted that potential challenges may arise as the space  tourism sector develops. FAA is mandated to regulate the commercial  space transportation industry to protect public safety and property while  encouraging, facilitating, and promoting commercial space launches.  According to FAA, its promotional activities include sponsoring an annual  industry conference, sponsoring Commercial Space Transportation  Advisory Committee meetings and work groups, presenting space-related  topics at various aerospace professional association conferences, creating  forums at which industry elements network, publishing economic impact  studies and launch forecast reports, and conducting outreach to potential  license applicants. These are all activities that experts say, and we agree,  do not conflict with FAA’s safety oversight responsibilities. According to  some experts, FAA’s promotional activities have not conflicted with the  agency’s role as a safety regulator because the activities do not involve  advocacy for the industry, nor do they increase demand in the industry.  Furthermore, experts noted that some of these activities promote FAA’s  safety role. For example, outreach to potential license applicants is a  means of ensuring that new launch companies know about and adhere to  federal safety regulations. Experts also noted that industry conferences  are a means by which FAA can have a dialogue with industry to ascertain  new industry trends and issues. FAA also has provided an estimated  $200,000 for Mojave Spaceport to complete its environmental impact  study, which FAA deems a promotional activity. According to its statutory  responsibility, FAA can take action to facilitate private sector involvement  in spaceport infrastructure.
However, as the commercial space launch industry matures, there is a  greater risk that FAA’s role as both the regulator and a promoter of the  industry may pose a conflict of interest. Experts told us, and we agree, that  as the commercial space launch industry evolves, it may be necessary to  separate FAA’s regulatory and promotional activities. For example, one  expert indicated that with the emergence of space tourism, FAA’s dual role  could pose a potential conflict of interest between creating an enabling  business environment and not compromising safety with regard to the  agency’s determining when and if it would regulate crew and passenger  safety on space launches. Other experts cited Congress’s removal of FAA’s  promotional responsibilities for commercial aviation in 1996 as evidence  of the importance of maintaining FAA’s focus on safety oversight. In  response to the ValuJet accident of May 11, 1996, the DOT Secretary asked  Congress to restrict FAA’s mandate to safety, eliminating its role in  promoting the airline industry. According to the conference report that  accompanied the legislative change, Congress withdrew FAA’s  promotional role in commercial aviation to address public perceptions  that might exist that the promotion of air commerce by FAA could create a  conflict with its safety regulatory mandate. Congress also has withdrawn  promotional responsibilities from other transportation entities. In 1961,  the Federal Maritime Board was dissolved and its promotion and safety  responsibilities were transferred to Commerce and the Federal Maritime  Commission, respectively. In proposing the legislative change, the  President stated that this change was made to eliminate the intermingling  of regulatory and promotional functions that had diluted responsibility and  led to serious inadequacies, particularly in the administration of regulatory  functions. Recognizing the potential conflict in the oversight of  commercial space launches, Congress required DOT to report by  December 2008, among other things, on whether the federal government  should separate the promotion of human space flight from the regulation  of such activity.
Furthermore, FAA’s promotional role has the potential to overlap with that  of Commerce’s role—given the broad definition of FAA’s statutory  promotional responsibilities, the more detailed definition of Commerce’s  promotional responsibilities, and the efforts of Commerce to fully staff its  Office of Space Commercialization. Commerce’s International Trade  Administration, which is responsible for promoting U.S. exports and  competitiveness of U.S. companies in foreign markets, has remained fully  staffed and provides assistance to the U.S. commercial space industry.  However, the Office of Space Commercialization within NOAA did not  have a permanent director from 1999 through January 2006 and had been  staffed with one permanent employee who had been charged with work  related to satellite services. In February 2006, a new director was  appointed, and, as of June 2006, the office has been fully staffed. The  Office of Space Commercialization is currently developing a strategic plan  that is to be completed by the end of 2006. Some of FAA’s promotional  activities, such as publishing economic impact studies on the industry,  have been undertaken due to past understaffing at Commerce, according  to an FAA official. FAA has not revisited which promotional activities it  should continue to undertake in light of these new developments at  Commerce. (Fig. 6 describes FAA’s and Commerce’s statutory promotional  responsibilities.)
section_title: To Help Address Key Competitive Issues Facing the Industry, the U.S. Government Has Played an Important Role
paragraphs: The U.S. commercial space launch industry faces key competitive issues  concerning high launch costs and export controls. Space launches incur  high costs for launch vehicle development and for launch facility  operations and maintenance. The U.S. government has responded by  providing support, such as launch contracts, the use of its launch facilities,  and launch vehicle development infrastructure.
Some foreign competitors have historically offered lower launch prices  than U.S. launch providers. During the rise of the commercial launch  industry in Russia, Ukraine, and China in the 1980s and 1990s, bilateral  agreements between these countries and the United States (1) limited the  number of launches in those countries of commercial satellites containing  U.S. licensed components and (2) imposed pricing restrictions. According  to a Commerce official, the United States entered into these agreements  because foreign countries were nonmarket economies and there was the  potential to employ nonmarket-based practices or offer prices  substantially below international market value. According to an USTR  official, which negotiated these agreements, the agreements required the  countries to price their commercial launch services “on a par” with  Western companies, which allowed the nonmarket economies to evolve  their industries while competing on a fair basis. These foreign  governments were required to sign the agreements with the United States  as a condition of launching U.S. satellites or of launching any satellites  containing U.S. licensed parts. According to an USTR official, these  agreements were intended to be transitional to allow time for U.S.  competitors to adjust to the entry of new launch companies from  nonmarket economies. The bilateral agreement with Ukraine was  terminated in 2000, while agreements with Russia and China were allowed  to expire in 2000 and 2001, respectively, because of the changing dynamics  in the marketplace—including, for example, the emergence of  international partnerships in the expendable launch vehicle industry.
subsections: section_title: U.S. Industry Formed International Partnerships in Response to Foreign Price Competition
paragraphs: The creation of international partnerships in the commercial space launch  industry could allow expendable launch vehicle companies to offer  commercial launches at lower prices. International Launch Services,  formed in 1995, is an international partnership of Lockheed Martin and a  Russian launch company that markets launches of the U.S. Atlas vehicle  from Cape Canaveral and the Russian Proton vehicle from Baikonur in  Kazakhstan. According to representatives from International Launch  Services, between 1995 and 2005, the company contracted for 48  commercial launches from Cape Canaveral and Baikonur. Sea Launch,  formed in 1995, is an international partnership between the Boeing  Commercial Space Company and companies from Ukraine, Russia, and  Norway that launches from a sea platform near the equator. Between 1999  and 2005, Sea Launch conducted 18 launches on a Ukrainian launch  vehicle. Sea Launch has also partnered with Russia’s Space International  Services to form Land Launch, which will offer launches on the same  Ukrainian vehicle from Baikonur beginning in 2007.
section_title: U.S. Government Supports the Industry through Launch Vehicle Development Contracts, Access to Infrastructure, Industry Competitions, and Indemnification
paragraphs: The United States, like foreign governments, supports its commercial  launch industry in several ways. The U.S. government encourages federal  agencies to acquire space transportation from U.S. commercial launch  companies. Some of these companies have also received DOD funds to  develop new launch vehicles that are intended to provide low-cost access  to space for government purposes. Once developed, these vehicles could  also be used for commercial purposes. For example, DOD’s Evolved  Expendable Launch Vehicle Program, a government-industry partnership  whose objective is to lower the cost of medium-to-heavy lift vehicle  launches, has led to the development of Lockheed Martin’s Atlas V vehicle  and Boeing’s Delta IV vehicle. DOD has provided $1.4 billion to the  program as of fiscal year 2006, with an additional investment of $4.6 billion  provided by Lockheed Martin and Boeing. With the objective of reducing  U.S. government launch costs, Lockheed Martin and Boeing have  proposed a joint venture of their vehicle programs, called the United  Launch Alliance, for which DOD gave conditional approval in January 2006  and for which the Federal Trade Commission gave conditional clearance  in October 2006. In addition, DOD has funded small vehicle development.  For example, SpaceX, which has received DOD funding, has developed  and is testing its Falcon I vehicle that will carry a small government  payload and will launch from the Army’s Ronald Reagan Ballistic Missile  Test Site on Kwajalein Atoll in the Marshall Islands. SpaceX then plans on  launching a small commercial payload to low-Earth orbit from Kwajalein  at an estimated cost of under $7 million (in 2006 dollars). This cost is in  contrast to launch prices for small payloads averaging $15 million,  according to a report on space transportation costs. Furthermore,  whereas international competitors launch prices for medium-to-heavy  payloads to geosynchronous transfer orbit average $56 million for  medium and $87.5 million for heavy payloads, SpaceX plans to launch  medium payloads on its Falcon 9 vehicle from $27 million and heavy  payloads from $78 million. SpaceX said that it has reduced launch costs in  a number of ways, including the simplification of vehicle design akin to  Russian vehicles. Another example of new lower-cost vehicles that have  been developed with DOD support is AirLaunch, LLC, which has  developed a small lift vehicle that launches from the air from a military  cargo aircraft and is intended to put a small payload into orbit for less than  $5 million. A representative from AirLaunch said that it plans to use this  technology in partnership with t/Space to develop a vehicle that will  compete in NASA’s Commercial Orbital Transportation Services  demonstration program.
The U.S. government also supports the industry by making infrastructure  and support staff available at its launch sites. Air Force launch pads leased  by launch companies may be used for government or commercial  launches. The commercial launch company pays the Air Force the direct  costs associated with its use of facilities and services for a commercial  launch. The Air Force is not reimbursed for indirect costs such as  infrastructure improvements or base support that involves the use of Air  Force active-duty personnel. NASA provides launch vehicle development  facilities, including rocket propulsion test stands, wind tunnels, and  thermal vacuum chambers to vehicle developers. Other types of  government support include prize competitions and indemnification. (See  table 2.)
Demonstration programs, such as NASA’s Commercial Orbital  Transportation Services, have received positive feedback from launch  vehicle developers, according to a NASA official. In addition, the official  said that the agency’s prize competitions, such as the Lunar Lander  Challenge competition, have inspired many new launch vehicle companies  to design vehicles using different launch approaches that could be used for  human space flight. According to a launch company, the Commercial  Orbital Transportation Services demonstration program allows for  solicitations that encourage innovation and investment in the space  industry by specifying an objective, such as carrying payloads to the  International Space Station, rather than detailed requirements for a  particular aircraft type.
section_title: States Are Offering Economic Incentives to Develop Spaceports for Space Tourism
paragraphs: States are offering economic incentives to develop spaceports to attract  space tourism and provide economic benefits to localities. The New  Mexico legislature approved $100 million in February 2006 for  construction of the Southwest Regional Spaceport in Upham, New Mexico.  The spaceport is expected to be completed in 2008 or 2009, with three  vertical launch pads; two runways; and service facilities for fuel service,  payload processing, launch control, and mission control. Currently, the  Southwest Regional Spaceport has 5 signed customers, including Virgin  Galactic, which plans to launch its initial commercial space flights from  the spaceport and expects to fly 3,000 passengers within five years after  commercial launches begin. According to an official from the Oklahoma  spaceport, Oklahoma provides approximately $500,000 annually to the  spaceport for operations, and the state paid for the environmental impact  statement and the safety analysis needed to apply for an FAA license.  Existing infrastructure includes a 13,500-foot runway capable of  accommodating the Space Shuttle, maintenance and repair hangars, and a  rail spur. Furthermore, the Oklahoma spaceport has offered incentives  valued at over $128 million over 10 years to attract space companies.  Rocketplane Kistler, which has developed a reusable vehicle, plans to  launch from the Oklahoma spaceport starting in mid-2007.
The Florida Space Authority, a state agency, has an arrangement with the  Cape Canaveral Air Force Station to use a launch pad for expendable  vehicle launches when excess capacity exists. The Florida Space Authority  has invested over $500 million in new space industry infrastructure  development, including upgrades to the launch pad, a new space  operations support complex, and a reusable launch vehicle support  complex. Lockheed Martin’s Athena and Atlas vehicles and Boeing’s Delta  vehicle launch from the spaceport. Although a launch site primarily for  vertical launches, the Florida Space Authority is also considering the  development of a commercial spaceport at a Florida airport to  accommodate horizontally launched space tourism flights. The Mid- Atlantic Regional Spaceport, colocated at NASA’s Wallops Flight Facility,  owns two launch pads for expendable vehicle launches and has access to  three runways. The spaceport receives half of its funding from Virginia and  Maryland, with the remainder coming from revenue from operations.  According to the spaceport’s executive director, the spaceport will  compete for Commercial Orbital Transportation Services demonstration  program launches. The Mojave Spaceport in Mojave, California, is owned  and operated by the East Kern Airport District and consists of three  runways with associated taxiways and other support facilities. With an  FAA Airport Improvement Program grant of $7.5 million, one of these  runways will be extended to allow for the reentry of horizontally landing  reusable vehicles. The spaceport also received FAA financial support to  conduct its environmental assessment. Scaled Composites, XCOR  Aerospace, and Interorbital Systems—companies that plan to enter the  space tourism business—are tenants at the airport. Officials from  spaceports told us the competition among the spaceports is positive. One  licensed spaceport official mentioned that because each spaceport will  attract a market unique to its launch capability; this competition will help  the overall industry to grow.
section_title: Industry Raised Concerns about Export Controls
paragraphs: Industry representatives that we interviewed identified export licensing  requirements under the International Traffic in Arms Regulations as a  competitive issue facing the U.S. space launch industry. The regulations  establish controls to ensure that arms exports are consistent with national  security and foreign policy interests. Launch vehicles are included on  State’s munitions list that is part of these regulations because these  vehicles can deliver chemical, biological, and nuclear weapons. In the  1990s, U.S. space technology was divulged to a foreign country, which led  to improvements of the reliability of its ballistic missiles that could be  used against the United States. Industry representatives said that they  would like fewer items to be regulated or a streamlined process for  obtaining authorization to export launch vehicles. While we have not  examined the issue of which specific items should be subject to export  controls, we have examined the export control system and have  recommended ways to improve its overall efficiency.
section_title: Conclusions
paragraphs: As the commercial space launch industry expands to include the  transportation of humans as well as satellites and other payloads into  space and the use of inland as well as coastal launch sites, FAA’s safety  oversight responsibilities will grow. To carry out these responsibilities and  address the serious safety implications of the industry’s expansion for  people both on the ground and in the launch vehicles, FAA will need  sufficient expertise, either in-house or available from an impartial source,  to evaluate a range of highly complex launch technologies. Such expertise  may be difficult for FAA to obtain and maintain, given federal funding  constraints and competition from the industry for qualified aerospace  engineers. While FAA’s decision not to request additional safety oversight  resources until the space tourism industry materializes is prudent in light  of the industry’s uncertain pace of development, FAA also needs to be  prepared to provide competent safety oversight if and when its workload  increases in order to continue to provide timely license approvals and  monitoring.
Experience has not yet shown whether FAA’s regulations will be  appropriate for the space tourism industry, given the differences in the  operations of launch vehicles and the launch sites used to transport  humans and payloads into space. FAA’s plan to address these differences  through case-by-case evaluations of individual launch license applications  is reasonable for an emerging industry with a wide variety of products. A  DOT commissioned report to be issued to Congress and completed by  December 2008, which will analyze whether expendable and reusable  launch vehicles should be regulated differently from each other, could  provide FAA with information about the suitability of its regulations to  space tourism.
FAA is prohibited from regulating crew and passenger safety before 2012,  except in response to incidents that either pose a high risk or result in  serious or fatal injury. FAA has interpreted this limited authority to allow  it to regulate crew safety in certain circumstances and has been proactive  in proposing regulations concerning emergency training for crews and  passengers. However, FAA has not developed safety indicators by which it  would monitor the developing space tourism sector and determine when  to step in and regulate human space flight.
Because FAA is a regulatory agency, it is important that its statutory  responsibility to promote the commercial space launch industry not  interfere with its safety oversight of the industry. We have no evidence  that FAA’s promotional activities have conflicted thus far with its safety  regulatory role, but conflicts could occur as the industry matures. For  example, such conflicts may have occurred or appeared to occur when  FAA was responsible for promoting as well as regulating the airline  industry. Recognizing the potential conflict in the oversight of commercial  space launches, Congress required DOT to report by December 2008 on  whether the federal government should separate the promotion of human  space flight from the regulation of such activity. Furthermore, Commerce  now has the staff resources to promote the commercial space industry,  possibly eliminating the need for FAA to play a promotional role.
section_title: Matter for Congressional Consideration
paragraphs: If DOT’s 2008 commissioned report on the dual safety and promotion roles  does not fully address the potential for a conflict of interest, Congress  should revisit the granting of FAA’s dual mandate for safety and promotion  and decide whether the elimination of FAA’s promotional role is necessary  to alleviate the potential conflict.
section_title: Recommendations for Executive Action
paragraphs: To prepare for a possible major expansion in its safety oversight  responsibilities resulting from the emergence of the space tourism  industry and spaceports, we recommend that the Secretary of  Transportation direct the FAA Administrator to implement the following  three recommendations:    As part of its strategic planning effort, FAA needs to assess the level of  expertise and resources that will be needed to oversee the safety of the  space tourism industry and the new spaceports under various scenarios  and timetables. In addition, the Office of Commercial Space  Transportation should develop a formal process for consulting with the  Office of Aviation Safety about licensing reusable launch vehicles. The  process should include the criteria under which the consultation takes  place.
To allow the agency to be proactive about safety, rather than responding  only after a fatality or serious incident occurs, FAA should identify and  continually monitor space tourism industry safety indicators that might  trigger the need to regulate crew and flight participant safety before 2012.  As part of this effort, FAA should develop and issue guidance on the  circumstances under which it would regulate crew and flight participant  safety before 2012.
As long as FAA has a promotional role, it should work with the  Department of Commerce to develop a memorandum of understanding  that clearly delineates the two agencies’ respective promotional roles in  line with their statutory obligations and larger agency missions. This  memorandum of understanding should reflect Commerce’s role as an  advocate of the industry, with the objective of increasing U.S.  competitiveness and FAA’s focus on providing a safe environment in  which the emerging space tourism sector could operate.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of the report to Commerce, DHS, DOD, DOT, NASA,  OSTP, State, and USTR. Commerce and NASA provided written comments  (see apps. V and VI). State, DOD, and DHS had no comments. The four  agencies that provided comments generally agreed with the findings  presented in the report and FAA (within DOT) and Commerce agreed with  the report’s recommendations. FAA, Commerce, OSTP, and USTR  provided technical corrections, which we incorporated as appropriate.
In response to the draft report’s discussion of resource challenges, FAA  stated that it monitors commercial space launch developments to assess  the impact on agency resources, and that it will request additional  resources when they can be justified through the annual budget process.  We agreed that FAA assesses resource requirements annually and added  this information to the report; however, we have not seen evidence that it  does so on a longer-term, strategic basis. In response to the draft report’s  discussion of the suitability of FAA’s expendable launch vehicle  regulations for reusable launch vehicles, FAA explained that the regulation  is not intended to apply to reusable vehicles. We agreed with this comment  and revised the draft to indicate the specific reusable launch vehicle  regulation to which we were referring. Commerce agreed with our  recommendation concerning the need for a memorandum of  understanding between it and DOT that clearly delineates the two  agencies’ respective promotional roles. In addition, Commerce pointed out  that the draft report did not reflect the industry advocacy role played by its  International Trade Administration. We agreed and added that information  to the report. OSTP stated that the report should include more discussion  of competition challenges facing the industry. Although we agree that such  challenges are important and addressed some competitive issues, such as  foreign price competition, a larger study of these issues was beyond the  scope of the report. Finally, NASA noted that the draft report did not  reflect the infrastructure support, such as wind tunnels and rocket  propulsion test stands, that it provides to the commercial space launch  industry. We agreed that this information should be included and modified  the text accordingly.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution of this report until 5  days after the date of this letter. At that time, we will send copies of this  report to interested congressional committees, the Secretary of  Transportation, the Administrator of FAA, the Secretary of Defense, the  Secretary of Commerce, the Secretary of State, the Administrator of the  National Aeronautics and Space Administration, the Secretary of  Homeland Security, the Assistant Secretary of Homeland Security for the  Transportation Security Administration, the Director of the White House  Office of Science and Technology Policy, and the Assistant U.S. Trade  Representative for Policy Coordination. We will also make copies  available to others upon request. In addition, the report will be available at  no cost on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  on (202) 512-2834 or at dillinghamg@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made major contributions to this  report are listed in appendix VII.
section_title: Appendix I: Objective, Scope, and Methodology
paragraphs: Our objective was to assess the federal role regarding commercial space  launches and the government’s response to emerging industry trends  both—domestically and internationally. To accomplish this, we addressed  the following questions: (1) how well does the Federal Aviation  Administration (FAA) oversee the safety of commercial space launches?  (2) To what extent is FAA responding to key emerging issues in the  commercial space launch industry? (3) What challenges does FAA face in  regulating and promoting the commercial space launch industry? and (4)  What are the key competitive issues affecting the U.S. commercial space  launch industry, and to what extent are the industry and government  responding to them?
For background information on the commercial space launch industry, we  reviewed reports prepared by the Congressional Research Service, FAA,  the Department of Commerce (Commerce), and other sources to  determine the composition of the industry and its role in the economy. We  also obtained data on historical commercial launch activity worldwide,  including the number of commercial space launches conducted, by  country, from 1997 through 2005; the types of vehicles used; and the types  of payloads launched. We did not independently verify this information  because it was used for background purposes only. In addition, we  identified the commercial launch infrastructure in the United States and  observed the commercial launch facilities at Cape Canaveral Air Force  Station and Vandenberg Air Force Base, which are the two main federal  launch facilities. We also determined the roles and responsibilities of  various federal agencies involved in commercial space launch activities by  reviewing their respective statutory authorities and interviewing agency  officials. These included officials from FAA, Commerce, the National  Aeronautics and Space Administration (NASA), the Department of  Defense (DOD), the Department of State, the Department of Homeland  Security, the Office of the United States Trade Representative, and the  Office of Science and Technology Policy.
To determine how well FAA has overseen the safety of commercial space  launches to date and to what extent it is responding to key emerging  issues in the commercial space launch industry, we reviewed FAA’s safety  oversight processes, identified key emerging issues in the commercial  space launch industry, and reviewed FAA’s response to those issues. We  reviewed FAA’s safety oversight process by interviewing agency officials  about their safety oversight activities and reviewed documentation on  FAA’s licensing and safety monitoring processes, including internal  guidance and policies, applicable regulations, and memorandums of  agreement with other federal agencies. Because FAA shares responsibility  with the Department of the Air Force to conduct safety oversight at the Air  Force’s launch sites, we interviewed FAA and Air Force officials at Cape  Canaveral Air Force Station and Vandenberg Air Force Base about their  interaction and respective responsibilities, and reviewed Air Force launch  safety requirements. We also interviewed representatives from eight  commercial space launch companies that had received launch licenses  from FAA and six launch companies that were consulting with FAA about  obtaining licenses as of September 2005 about FAA’s licensing process. We  also interviewed an official heading a working group on reusable launch  vehicles from the Commercial Space Transportation Advisory Committee,  which is an industry group that provides advice to FAA on commercial  launch issues. This official is also a key principal of the Personal  Spaceflight Federation, which is an industry group. When we found that  some companies were offering to sell tickets for flights into space, we also  interviewed two firms that were selling such tickets or were planning to  sell them about their services and related safety issues. In addition,  because security is a component of safety, we interviewed officials from  the Transportation Security Administration about its future role in  securing new spaceports.
To further assess how well FAA has overseen the safety of commercial  space launches and because FAA conducts its safety oversight largely  through its licensing process, we reviewed its application files for the  licenses that were in effect in January 2006, which consisted of 13 launch  licenses and five launch-site licenses. In addition, although its license was  no longer in effect at the time of our review, we reviewed the application  file for Scaled Composites’ launch of SpaceShipOne because the company  had received the first license from FAA for a reusable vehicle. We  reviewed these application files to determine the types of FAA safety  issues that the agency examined and how it conducted those  examinations. Because we were evaluating the management of a  government program, we examined (1) how FAA applied certain  management controls in its license approval process using our guidelines  for management controls at federal agencies and (2) whether FAA met the  180-day review criteria established by the 1984 Commercial Space Launch  Act. The management controls included documentation of the review  process, effective communication, reliability and verification of data,  supervisory review, and documentation of the approval process, which we  determined from consulting Standards for Internal Control in the Federal  Government for the elements needed for effective management of the  licensing approval process. Furthermore, we assessed the extent to which  FAA interacted with other federal agencies participating in an interagency  advisory group on expendable vehicles, which was part of the application  review process in some cases, by interviewing the interagency group  members about their interaction with FAA on commercial launch issues.  In addition, we reviewed FAA’s safety monitoring process by examining its  most recent compliance-monitoring reports that corresponded to the  licenses that were in effect as of January 2006, as well as enforcement  actions taken against commercial launch companies for noncompliance  with safety issues. Moreover, to obtain an independent perspective on how  well FAA has conducted launch safety oversight and responded to key  emerging issues, we interviewed 11 experts from academia and industry  that we selected with the assistance of the National Academy of Sciences.  (See table 3 for a list of these experts.)
We identified key emerging issues through literature reviews and  interviews with agency officials and industry representatives, including  associations representing the commercial space launch industry and  entities that had received launch or launch-site licenses from FAA or were  consulting with FAA about receiving such licenses as of September 2005.  To assess the extent to which FAA has responded to emerging issues in  the commercial space launch industry, we interviewed federal government  officials, including FAA officials and representatives from federal launch  sites and FAA-licensed and proposed spaceports, launch companies,  industry experts, and trade associations to obtain their views. See table 4  for a list of the organizations that we interviewed.
We also reviewed the proposed and issued regulations relating to  commercial space launches and comments published in the Federal  Register on those regulations to assess how the agency had responded to  the emerging issues.
To determine the challenges that FAA faces in responding to emerging  issues in the commercial space launch industry, we interviewed FAA  officials, industry representatives, industry experts, and trade associations  to obtain their views on how FAA would need to respond and the level of  expertise and resources that would be required. This included considering  the challenges that FAA may face in complying with requirements  contained in both proposed regulations and under existing law to provide  safety oversight over a new industry sector involving reusable launch  vehicles.
To determine the key competitive issues affecting the U.S commercial  space launch industry and the extent to which the industry and federal  government are responding to them, we conducted a literature review that  included applicable laws affecting industry competitiveness and  interviewed FAA officials, industry representatives, industry experts, and  trade associations to obtain their views. This included interviewing  officials from the Office of the U.S. Trade Representative about the U.S.  government’s past use of bilateral treaties with foreign governments  regarding the commercial space market and from the Commercial Space  Transportation Advisory Committee, which is an industry group that  provides advice to FAA on commercial launch issues, about industry  concerns regarding insurance and liability matters. We also interviewed  U.S. commercial space launch companies, including U.S. partners in  international partnerships. In addition, to obtain the perspective of a  foreign commercial launch company on international competitive issues,  we interviewed an official from Arianespace, which is a French  commercial space launch company. To obtain the perspective of a  domestic commercial launch company, we interviewed SpaceX. We also  reviewed regulations affecting the competitiveness of the commercial  space launch industry, such as the International Traffic in Arms  Regulations, and reports on competitive issues prepared by the  Congressional Research Service, FAA, Commerce, Futron, and others. We  attempted to compare the extent to which countries were providing  financial assistance to their commercial space launch industries, but we  were unable to obtain transparent and quantifiable data. We conducted  our review from August 2005 through October 2006 in accordance with  generally accepted government auditing standards.
section_title: Appendix II: Economic Impact of the Commercial Space Industry
paragraphs: The commercial space transportation industry as a whole represents a  significant sector of the U.S. economy. The industry consists of the  commercial launch industry as well as the industries that commercial  space enables, such as satellite manufacturing and services, ground  equipment manufacturing, remote sensing, distribution industries, and  launch vehicle manufacturing and services (see fig. 7).
According to FAA, the commercial space transportation and enabled  industries were responsible for approximately 550,000 total jobs and   $98 billion in economic activity in the United States in 2004, with the  satellite services industry, such as direct-to-home television services,  having the largest economic activity impact (see fig. 8). Of this, launch  vehicle manufacturing and services had $1.7 billion in economic impact.
section_title: Appendix III: FAA’s Launch and Reentry Licensing Process
paragraphs: FAA evaluates applications for launch licenses by reviewing the safety,  environmental, payload, and policy implications of a launch and  determining the launch company’s insurance liability or financial  responsibility. Figure 9 illustrates this process.
FAA’s safety review includes an analysis of the reliability and functions of  the vehicle, an assessment of the risk and hazards it poses to public  property and individuals, and a review of the launch company’s policies  and practices to demonstrate that the operations “pose no unacceptable  threat to the public.” FAA conducts environmental reviews to fulfill its  obligations under the National Environmental Policy Act, and FAA  ensures that proposed commercial space transportation activities present  “no unacceptable danger to the natural environment.” In addition, FAA  reviews a proposed payload to determine whether its launch or reentry  would jeopardize public health and safety, safety of property, U.S. national  security or foreign policy interests, or international obligations of the  United States. During the policy review, FAA consults with other federal  agencies to determine whether the launch license presents any issues  affecting U.S. national security, foreign policy, or international obligations.  FAA also determines the amount of liability insurance required to  compensate third-parties for activities carried out under a license, up to a  maximum of $500 million or the maximum liability insurance available on  the world market at a reasonable cost as determined by FAA. FAA also  sets insurance requirements for U.S. government range property on the  basis of its determination of the maximum probable loss that would result  from licensed launch or reentry activities, not to exceed the lesser of $100  million or the maximum available on the world market at reasonable cost.
FAA’s launch-site safety requirements are similar to those for launches of  vehicles. FAA reviews a launch-site’s application for environmental,  policy, operations, and safety considerations that include the location of  the spaceport and its siting of explosives. Applicants also are required to  address how they will control public access to their sites, which would  include the use of security personnel, surveillance systems, physical  barriers, or other means approved during the licensing process.
section_title: Appendix IV: Timeline and List of FAA Commercial Space Launch Rulemaking and Guidance
subsections: section_title: August 25, 2006
paragraphs: Licensing and Safety Requirements for Launch; Final Rule (to amend 14  C.F.R. parts 413, 415, 417). 71 Fed. Reg. 50508.
section_title: March 31, 2006
paragraphs: Experimental Permits for Reusable Suborbital Rockets; Notice of  Proposed Rulemaking (to amend 14 C.F.R. parts 401, 404, 405, 406, 413,  420, 431, 437). 71 Fed. Reg. 16251.
section_title: December 29, 2005
paragraphs: Human Space Flight Requirements for Crew and Space Flight Participants;  Proposed Rule (to amend 14 C.F.R. parts 401, 431, 435, 440, 450, 460). 70  Fed. Reg. 77262.
section_title: July 20, 2005
paragraphs: Reusable Launch and Reentry Vehicle System Safety Process, AC 431.35- 2A; Advisory Circular.
section_title: June 1, 2005
paragraphs: Safety Approvals; Proposed Rule (to amend 14 C.F.R. part 414). 70 Fed.  Reg. 32912.
section_title: May 19, 2005
paragraphs: Miscellaneous Changes to Commercial Space Transportation Regulations;  Proposed Rule (to amend 14 C.F.R. parts 401, 404, 413, 415, 420). 70 Fed.  Reg. 29164.
section_title: March 1, 2005
paragraphs: Licensing and Safety Requirements for Launch; Availability of Draft  Regulatory Language and Notice of Public Meeting (to amend 14 C.F.R.  parts 415, 417). 70 Fed. Reg. 9885.
section_title: October 20, 2003
paragraphs: Commercial Space Transportation; Suborbital Rocket Launch; Notice and  Request for Comments. 68 Fed. Reg. 59977.
section_title: August 15, 2002
paragraphs: Licensing Test Flight Reusable Vehicle Missions, AC 431.35-3; Advisory  Circular.
section_title: July 30, 2002
paragraphs: Licensing and Safety Requirements for Launch; Proposed Rule (to amend  14 C.F.R. parts 413, 415, 417). 67 Fed. Reg. 49456.  (This is a supplemental  Notice of Proposed Rulemaking to the October 25, 2000, Proposed Rule.)
section_title: January 10, 2001
paragraphs: Civil Penalty Actions in Commercial Space Transportation; Final Rule (14  C.F.R. parts 405, 406). 66 Fed. Reg. 2176.
section_title: October 25, 2000
paragraphs: Licensing and Safety Requirements for Launch; Proposed Rule (to amend  14 C.F.R. parts 413, 415, 417). 65 Fed. Reg. 63921.
section_title: October 19, 2000
paragraphs: Licensing and Safety Requirements for Operation of a Launch Site; Final  Rule (14 C.F.R. parts 401, 417, 420). 65 Fed. Reg. 62812.
section_title: September 19, 2000
paragraphs: Commercial Space Transportation Reusable Vehicle and Reentry Licensing  Regulations; Final Rule (14 C.F.R. parts 400-435). 65 Fed. Reg. 56618.
section_title: September 19, 2000
paragraphs: Financial Responsibility Requirements for Licensed Reentry Activities;  Final Rule (14 C.F.R. part 450). 65 Fed. Reg. 56670.
section_title: August 30, 2000
paragraphs: Expected Casualty Calculations for Commercial Space Launch and  Reentry Missions, AC 431.35-1; Advisory Circular.
section_title: December 30, 1999
paragraphs: Small-Scale Rockets; Notice of Public Meeting (to solicit comments on  possible FAA regulation of small-scale rocket launches). 64 Fed. Reg.  73597.
section_title: August 16, 1999
paragraphs: License Application Procedures, AC 413-1; Advisory Circular.
section_title: April 21, 1999
paragraphs: Commercial Space Transportation Licensing Regulations; Final Rule (14  CFR parts 401, 411, 413, 415, 417). 64 Fed. Reg. 19586.
section_title: November 3, 1998
paragraphs: Part 440 Insurance Conditions, AC 440-1; Advisory Circular.
section_title: August 26, 1998
paragraphs: Commercial Space Transportation Financial Responsibility Requirements  for Licensed Launch Activities; Final Rule (14 C.F.R. part 440). 63 Fed.  Reg. 45592.
section_title: April 4, 1988
paragraphs: Commercial Space Transportation Licensing Regulations; Final Rule (14  C.F.R. Ch. III). 53 Fed. Reg. 11004.
section_title: Appendix V: Comments from the Department of Commerce
section_title: Appendix VI: Comments from the National Aeronautics and Space Administration
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Teresa Spisak (Assistant  Director), Maureen Luna-Long, Bob Homan, Ashley Alley, Elizabeth  Eisenstadt, Jim Geibel, Dave Hooper, Rosa Leung, Sara Ann Moessbauer,  Josh Ormond, and Sandra Sokol made key contributions to this report.