Some thoughts on regulation and certification
Mitchell Burnside Clapp
this reason that I'm increasingly convinced as the years go by that
"aerospace" is an oxymoron.
I am firmly of the opinion that shopping around for the most
convenient set of rules is a recipe for investment-dampening
confusion. I also think that there's a lot of good on both sides of
the argument about who regulates what. But any kid who doesn't like
the answer he gets from Mom and goes to ask Dad will be in a world of
pain when the two compare notes.
Ultimately, I think, the problem is a definitional one. "What is a
space transport?" Anything that flies on a suborbital trajectory falls
into AST's field and that means that every time I take a jump shot
shooting hoops at the Y, I'm breaking the law. Heck, I don't think
there's a black letter law definition of "space."
For me, the bright-line test is this: If it is under the sole control
of a pilot, physically present aboard the vehicle, who is able to take
corrective action at all phases of flight if something breaks, then it
is an aircraft, regardless of whether the lift comes from aerodynamic
forces, propulsive forces, inertial forces, buoyant forces, or
supernatural forces. I think the same is true of control and it's not
consequently helpful to draw a distinction between "needs reaction
control" and "needs aerodynamic control." All such vehicles should be
certificated by AVR, in a category appropriate to their design. I
think Jeff Greason and I probably disagree on this point, so talking
about it in here might be helpful.
(Let me stress, by the way, that control is not used here to mean
"real time control loop closure", or hand-flying. Some designs just
don't permit that. It does, however, mean that there ought to be
actions the pilot can take at every instant of the trajectory to
assure vehicle and public safety. Systems that contain a person with a
stick that isn't hooked up to anything don't count. Systems that have
unabortable flight phases where the crew's only recourse is to make
their peace with their Maker don't count. An occupant is not a pilot).
If the jettison of stages is contemplated, then it becomes an AST
responsibility. Calculating things like expected casualties and so on
becomes an appropriate thing to do in those circumstances. I think
this is true for systems like the ones we're working on at Pioneer
Rocketplane that imagine very high-speed over-water release of upper
stages. There's no chance such a stage could survive intact to the
ground, and there's precedent for "no range safety" package for
Pegasus Stage III, which releases at a similar flight condition to
what we imaging, but I think we are obliged to prove that to a
competent regulator, and that's AST.
Remotely operated vehicles, and I'm thinking in particular of Kistler
here, have an interesting problem under these sets of rules. Aviators
necessarily become a little apprehensive at the "who's flying this
thing?" concerns of remotely operated vehicles. It isn't common to see
vehicles without occupants in normal airspace whatever type of vehicle
they are, and in this case I think you're essentially tackling the UAV
problem. That means that the fidelity and security of your
communications link is a safety of flight item. That in turn means
that if it fails you are flying an unpiloted, possibly internally
guided, space vehicle, and that means that you are back in AST's area
of responsibility. Again, if the system has an architecture choice
that could lead to an AST-like vehicle configuration, then it's
reasonable to expect them to sign off on what you're doing.
Finally, I understand that advocating this approach does raise the
burden on "space transport" developers. There are more rules to comply
with in AVR, and the only real benefit here is that those rules are
not murky; they're quite clear. Let's recognize that when the FAA
certificates an aircraft, what it's doing is blessing the
manufacturing process. If manufacture and sale of vehicles is not
contemplated it would be nice to see something worked out where
limited operation of such vehicles, for revenue, could be performed.
Exceptions to the no-revenue provisions for certain types of
experimental aircraft flights exist now, so there is some recognition
that if, for example, you want a gyroplane endorsement on your pilot's
license, the odds are that you will be paying for training in an
experimental aircraft.
Aviation is an amazingly safe way to travel, and a big part of the
reason for it is rigorous and thorough review by the FAA. We owe our
customers the same regard for their safety and I think are obliged to
set the bar for regulation and certification of our vehicle as high as
we can tolerate.
Sincerely,
Mitchell Burnside Clapp
CEO
Pioneer Rocketplane
Rand Simberg
mitc...@rocketplane.com (Mitchell Burnside Clapp) made the phosphor
on my monitor glow in such a way as to indicate that:
Mitchell, you ignorant slut. ;-)
>The debate over AST vs. AVR is fundamentally a cultural one. It's for
>this reason that I'm increasingly convinced as the years go by that
>"aerospace" is an oxymoron.
>
>I am firmly of the opinion that shopping around for the most
>convenient set of rules is a recipe for investment-dampening
>confusion. I also think that there's a lot of good on both sides of
>the argument about who regulates what. But any kid who doesn't like
>the answer he gets from Mom and goes to ask Dad will be in a world of
>pain when the two compare notes.
>
>Ultimately, I think, the problem is a definitional one. "What is a
>space transport?" Anything that flies on a suborbital trajectory falls
>into AST's field and that means that every time I take a jump shot
>shooting hoops at the Y, I'm breaking the law. Heck, I don't think
>there's a black letter law definition of "space."
Well, AST has come up with a definition that doesn't encompass jump
shots or home runs.
>If the jettison of stages is contemplated, then it becomes an AST
>responsibility.
So how do you handle the case (as you've proposed in various
incarnations) where you've got an airplane-like thingy launching
expendable stages? Or are you talking about boost stages for the
vehicle itself? In either case, does that mean that you have to
explicitly get both mom and dad's permission?
>Finally, I understand that advocating this approach does raise the
>burden on "space transport" developers. There are more rules to comply
>with in AVR, and the only real benefit here is that those rules are
>not murky; they're quite clear. Let's recognize that when the FAA
>certificates an aircraft, what it's doing is blessing the
>manufacturing process. If manufacture and sale of vehicles is not
>contemplated it would be nice to see something worked out where
>limited operation of such vehicles, for revenue, could be performed.
>Exceptions to the no-revenue provisions for certain types of
>experimental aircraft flights exist now, so there is some recognition
>that if, for example, you want a gyroplane endorsement on your pilot's
>license, the odds are that you will be paying for training in an
>experimental aircraft.
It would indeed be nice. The problem is that the government hasn't
been reasonable about it, to date (based on my, and Peter's experience
merely in getting already-certificated aircraft capable of taking
passengers for weightless flights).
>Aviation is an amazingly safe way to travel, and a big part of the
>reason for it is rigorous and thorough review by the FAA. We owe our
>customers the same regard for their safety and I think are obliged to
>set the bar for regulation and certification of our vehicle as high as
>we can tolerate.
"...as high as we can tolerate" is what we're arguing about here. We
certainly owe our customers the best regard for safety and risk that
still allows them afford to fly at all, given the current state of the
art. But it's not reasonable to expect spaceflight to be as safe as
aviation at this time (and perhaps never). I continue to believe that
imposing a regulatory regime on the space industry that would have
caused the aviation industry to be stillborn had it had that burden in
its infancy, will result in continuing shackles to the planet.
--
simberg.interglobal.org * 310 372-7963 (CA) 307 739-1296 (Jackson Hole)
interglobal space lines * 307 733-1715 (Fax) http://www.interglobal.org
"Extraordinary launch vehicles require extraordinary markets..."
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Henry Spencer
Rand Simberg <simberg.i...@org.trash> wrote:
>>If the jettison of stages is contemplated, then it becomes an AST
>>responsibility.
>
>So how do you handle the case (as you've proposed in various
>incarnations) where you've got an airplane-like thingy launching
>expendable stages?
As he indicated two sentences later, he thinks any system which involves
separating an unpiloted stage at some point puts you in AST territory,
because the onus is then properly on you to establish that said stage's
traditional-rocket-like failure modes will be acceptably safe.
I say "unpiloted stage" because Mitch didn't actually address the
possibility that all the stages might have pilots (in his sense of the
word, implying continuous real authority over the stage's fate). That
design approach is not common nowadays but remains credible.
--
MOST launched 1015 EDT 30 June, separated 1046, | Henry Spencer
first ground-station pass 1651, all nominal! | he...@spsystems.net
Rand Simberg
he...@spsystems.net (Henry Spencer) made the phosphor on my monitor
glow in such a way as to indicate that:
>In article <3f83fd55....@news.west.earthlink.net>,
>Rand Simberg <simberg.i...@org.trash> wrote:
>>>If the jettison of stages is contemplated, then it becomes an AST
>>>responsibility.
>>
>>So how do you handle the case (as you've proposed in various
>>incarnations) where you've got an airplane-like thingy launching
>>expendable stages?
>
>As he indicated two sentences later, he thinks any system which involves
>separating an unpiloted stage at some point puts you in AST territory,
>because the onus is then properly on you to establish that said stage's
>traditional-rocket-like failure modes will be acceptably safe.
>
>I say "unpiloted stage" because Mitch didn't actually address the
>possibility that all the stages might have pilots (in his sense of the
>word, implying continuous real authority over the stage's fate). That
>design approach is not common nowadays but remains credible.
Then it makes me wonder how his criteria would apply to any real-world
system currently being contemplated/funded.
jeff findley
>
> If the jettison of stages is contemplated, then it becomes an AST
> responsibility. Calculating things like expected casualties and so on
> becomes an appropriate thing to do in those circumstances. I think
> this is true for systems like the ones we're working on at Pioneer
> Rocketplane that imagine very high-speed over-water release of upper
> stages. There's no chance such a stage could survive intact to the
> ground, and there's precedent for "no range safety" package for
> Pegasus Stage III, which releases at a similar flight condition to
> what we imaging, but I think we are obliged to prove that to a
> competent regulator, and that's AST.
What about manned designs such as the X-15? What makes the B-52 a
carrier aircraft? Is it the pilot? If so, one could design a
reusable first stage that is a VTVL, rocket powered, piloted vehicle
and still be considered an aircraft. I certainly wouldn't want any
regulations on a manned first stage (with pilot control and abort
modes) to be required to have a range safety (destruct) package.
Jeff
--
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Rand Simberg
he...@spsystems.net (Henry Spencer) made the phosphor on my monitor
glow in such a way as to indicate that:
>In article <3f83fd55....@news.west.earthlink.net>,
>Rand Simberg <simberg.i...@org.trash> wrote:
>>>If the jettison of stages is contemplated, then it becomes an AST
>>>responsibility.
>>
>>So how do you handle the case (as you've proposed in various
>>incarnations) where you've got an airplane-like thingy launching
>>expendable stages?
>
>As he indicated two sentences later, he thinks any system which involves
>separating an unpiloted stage at some point puts you in AST territory,
>because the onus is then properly on you to establish that said stage's
>traditional-rocket-like failure modes will be acceptably safe.
>
>I say "unpiloted stage" because Mitch didn't actually address the
>possibility that all the stages might have pilots (in his sense of the
>word, implying continuous real authority over the stage's fate). That
>design approach is not common nowadays but remains credible.
Then that restricts his proposal for AVR to be the regulator of
orbital systems to either piloted SSTO, or as you say, multi-stage
with all stages piloted.
I don't see either one occuring in the near term, but of course, the
real issue is suborbital (and specifically, Burt, which is what I
suspect prompted the post). But Mitch, are you also proposing that
AVR should regulate wingless piloted suborbitals (e.g. Michele B, or
Carmack's stuff)? I suppose you could throw them in the "powered
lift" category, but I'm not sure that it was ever intended for
rockets.
Dan DeLong
> The debate over AST vs. AVR is fundamentally a cultural one.
Agree. AST's culture regulates commercial spaceflight. AVR's culture
guarantees similarity between serial numbers of production aircraft.
AVR assumes a non-knowledgeable passenger just wanting to travel to a
destination. New designs within this world are evolutionary, small
changews to proven designs.
> Ultimately, I think, the problem is a definitional one. "What is a
> space transport?" Anything that flies on a suborbital trajectory falls
> into AST's field and that means that every time I take a jump shot
> shooting hoops at the Y, I'm breaking the law. Heck, I don't think
> there's a black letter law definition of "space."
No. AST's definition requires rocket propulsion and thrust greater
than lift; and there is a minumum size exclusion.
> For me, the bright-line test is this: If it is under the sole control
> of a pilot, physically present aboard the vehicle, who is able to take
> corrective action at all phases of flight if something breaks, then it
> is an aircraft, regardless of whether the lift comes from aerodynamic
> forces, propulsive forces, inertial forces, buoyant forces, or
> supernatural forces.
Only aerodynamic forces create lift. AVR deals with this.
I think the same is true of control and it's not
> consequently helpful to draw a distinction between "needs reaction
> control" and "needs aerodynamic control." All such vehicles should be
> certificated by AVR, in a category appropriate to their design.
So far, after 10 years of work, Zero-G has not convinced AVR to
certify a standard airliner to fly weightless parabolas. That's a
certification FAR simpler than a whole new vehicle. I leave it to the
reader to extrapolate that curve.
> think Jeff Greason and I probably disagree on this point, so talking
> about it in here might be helpful.
Jeff is currently on his way to Wash DC for yet another formal meeting
with FAA and Congress on exactly this subject, so you're stuck with
me. :) FAA has regular meetings where you can air your requests. Jeff
Greason has been doing this for the past four years. Before that Mike
Kelly did much of the heavy lifting.
> (Let me stress, by the way, that control is not used here to mean
> "real time control loop closure", or hand-flying. Some designs just
> don't permit that. It does, however, mean that there ought to be
> actions the pilot can take at every instant of the trajectory to
> assure vehicle and public safety. Systems that contain a person with a
> stick that isn't hooked up to anything don't count. Systems that have
> unabortable flight phases where the crew's only recourse is to make
> their peace with their Maker don't count. An occupant is not a pilot).
>
> If the jettison of stages is contemplated, then it becomes an AST
> responsibility.
So just add a RATO. (Not trying to be mean or obtuse, Mitch, just
pointing out that the definition has loopholes.)
Calculating things like expected casualties and so on
> becomes an appropriate thing to do in those circumstances. I think
> this is true for systems like the ones we're working on at Pioneer
> Rocketplane that imagine very high-speed over-water release of upper
> stages. There's no chance such a stage could survive intact to the
> ground, and there's precedent for "no range safety" package for
> Pegasus Stage III, which releases at a similar flight condition to
> what we imaging, but I think we are obliged to prove that to a
> competent regulator, and that's AST.
I Agree
> Finally, I understand that advocating this approach does raise the
> burden on "space transport" developers.
Absolutely, I think that's the understatement of the century. What it
will do is take a $20 million program with technical, management, and
market risk, and turn it into a multi-hundred million dollar program
with added regulatory risk. It's a HUGE burden, Mitch, and one we
can't live with. And all that money adds no value because we (the
industry) need to fly as safely as possible to stay in business, make
the insurance payments, and successfully defend ourselves in court.
There are more rules to comply
> with in AVR, and the only real benefit here is that those rules are
> not murky; they're quite clear.
Those rules may be quite clear for existing airplanes, but they don't
exist for space transport. A few of the many examples are: AVR has no
rules for reentry TPS designs or margins. AVR has no rules for the
materials of construction we are likely to evolve. AVR has no rules
for how to do supersonic flight, other than they prohibit it. If AVR
can hold up certification of the Beech Starship because the stall
warning indicator was not appropriate for a canard configured
airplane, just imagine what they would do for a hypersonic, low Q yaw
damper.
Let's recognize that when the FAA
> certificates an aircraft, what it's doing is blessing the
> manufacturing process. If manufacture and sale of vehicles is not
> contemplated it would be nice to see something worked out where
> limited operation of such vehicles, for revenue, could be performed.
Within AST, that's handled by testing and demonstration. Nothing to
work out.
> Exceptions to the no-revenue provisions for certain types of
> experimental aircraft flights exist now,
Mostly, these are violations of the rules, not exceptions.
so there is some recognition
> that if, for example, you want a gyroplane endorsement on your pilot's
> license, the odds are that you will be paying for training in an
> experimental aircraft.
When you do this, you are breaking the rules. Not always, but often.
Some operators have exceptions, given on a case-by-case basis. You're
not likely to get an investor's due diligence blessing based on
"They're breaking the rules, so we will too", or maybe get them
changed.
> Aviation is an amazingly safe way to travel, and a big part of the
> reason for it is rigorous and thorough review by the FAA.
FAA doesn't know how to do a "thorough and rigouous review" of a
launch vehicle any more than NASA does. And NASA's annual budget is
three orders of magnitude higher than any entrepeneurial company is
going to raise. Maybe space flight will become safe too, after several
generations of build and test. Maybe by then, FAA will know how to do
a thorough and rigorous review. In the meantime, AST has a good
formula for letting the nascent industry develop.
We owe our
> customers the same regard for their safety
It's not going to happen, Mitch. Nobody is that smart. If your intent
is to initially get into the "common carrier" business selling
point-to-point rides to a destination, you have to provide that level
of safety. I repeat, that's going to be several vehicle generations in
the future. Maybe. And maybe not. It may turn out that high energy,
high altitude, highly variable Q and IAS flight really is more
dangerous. In which case, by your statement, we should not fly at all.
In the meantime, we can fly "Adventure Travelers" who go through a
rigorous "space camp" getting trained on ejection seat procedures,
pressure suit procedures, etc. When your customer gets out of this, he
will understand the risk is more comparable to skydiving or mountain
climbing.
and I think are obliged to
> set the bar for regulation and certification of our vehicle as high as
> we can tolerate.
>
> Sincerely,
>
> Mitchell Burnside Clapp
> CEO
> Pioneer Rocketplane
Sincerely,
Dan DeLong
Chief Engineer and VP, XCOR Aerospace.
Mitchell Burnside Clapp
> news:<7a393d23.03091...@posting.google.com> ...
>
> > The debate over AST vs. AVR is fundamentally a cultural one.
>
> Agree. AST's culture regulates commercial spaceflight. AVR's culture
> guarantees similarity between serial numbers of production aircraft.
> AVR assumes a non-knowledgeable passenger just wanting to travel to a
> destination.
True enough. I think, though, that you've created a false dichotomy here. AVR
does other things besides simply the things you describe. In particular, and
it's relevant to the conversation, they deal with experimental aircraft.
> > Ultimately, I think, the problem is a definitional one. "What is a
> > space transport?" Anything that flies on a suborbital trajectory falls
> > into AST's field and that means that every time I take a jump shot
> > shooting hoops at the Y, I'm breaking the law. Heck, I don't think
> > there's a black letter law definition of "space."
>
> No. AST's definition requires rocket propulsion and thrust greater
> than lift; and there is a minumum size exclusion.
That reasonably accurately describes AST's definition, I agree, but my point is
more "How should things be?" rather than "How are things now?" The argument I'm
trying to lay out in my initial post can be rephrased thus:
"We have two regulatory groups, who regulate two different types of vehicles.
Aircraft are regulated by AVR and launch vehicles are regulated by AST.
Proposed space transport vehicles might have aircraft-like and
launch-vehicle-like features. Though aircraft designs vary widely, they all
have occupants who control them at all flight phases and intact takeoff and
landing. Though rocket designs vary widely, they all drop pieces off or are
controlled remotely. Space transports that have solely aircraft-like features
should be considered aircraft. There may be ways to manage the process of
flying passengers for hire in such vehicles that are not prohibitively
burdensome."
> > For me, the bright-line test is this: If it is under the sole control
> > of a pilot, physically present aboard the vehicle, who is able to
> take
> > corrective action at all phases of flight if something breaks, then
> it
> > is an aircraft, regardless of whether the lift comes from aerodynamic
> > forces, propulsive forces, inertial forces, buoyant forces, or
> > supernatural forces.
>
> Only aerodynamic forces create lift. AVR deals with this.
This is an error. Buoyant forces create lift. So do thrust forces. AVR deals
with them as well. I would say, if my reasoning were to prevail, that the
Armadillo and TGV vehicles would be "powered lift" class machines.
> > I think the same is true of control and it's not
> > consequently helpful to draw a distinction between "needs reaction
> > control" and "needs aerodynamic control." All such vehicles should be
> > certificated by AVR, in a category appropriate to their design.
>
> So far, after 10 years of work, Zero-G has not convinced AVR to
> certify a standard airliner to fly weightless parabolas. That's a
> certification FAR simpler than a whole new vehicle.
That's true but it doesn't really address the point above. I don't see a
connection between my paragraph and yours. What am I missing?
> > think Jeff Greason and I probably disagree on this point, so talking
> > about it in here might be helpful.
>
> Jeff is currently on his way to Wash DC for yet another formal meeting
> with FAA and Congress on exactly this subject, so you're stuck with
> me. :) FAA has regular meetings where you can air your requests. Jeff
> Greason has been doing this for the past four years. Before that Mike
> Kelly did much of the heavy lifting.
I'm familiar with the history of efforts to affect the FAA's approach, and
who's done what. Pioneer had someone at the same meeting at Congress too. We
generally keep quiet on such things because of a feeling that virtually any
movement in rulemaking will be favorable, that the status quo is tolerable, and
that the situation is not urgent.
> > If the jettison of stages is contemplated, then it becomes an AST
> > responsibility.
>
> So just add a RATO. (Not trying to be mean or obtuse, Mitch, just
> pointing out that the definition has loopholes.)
Fair point here. How do RATO jettison operations work nowadays? I confess with
some chagrin that I've never seen it done. If it were my airplane I'd just hold
on to the spent motors and take them off later.
In fact, though, there's an implicit worry that your comment brings up, which
is that someone might be able to fly people in an uncertificated airplane under
AST guidance by tacking a qualifying space-transport-like feature on to it, and
then not using that feature. I don't stay up late worrying about it, but it
might provide an unfortunate loophole for someone wishing to avoid aircraft
certification for his or her aircraft.
>
> > I understand that advocating this approach does raise the
> > burden on "space transport" developers.
>
> Absolutely, I think that's the understatement of the century. What it
> will do is take a $20 million program with technical, management, and
> market risk, and turn it into a multi-hundred million dollar program
> with added regulatory risk. It's a HUGE burden, Mitch, and one we
> can't live with. And all that money adds no value because we (the
> industry) need to fly as safely as possible to stay in business, make
> the insurance payments, and successfully defend ourselves in court.
I wasn't really advocating seeking a full-up certification in part 121 for each
space transport. I was thinking along the lines of a case by case grant of
exemption from the experimental rules for demonstration of capability purposes.
A burden, to be sure, but hardly a prohibitive one. I checked my logbook and
have about ten hours in an aircraft that flies under just such paperwork. It
didn't take nine figure sums to get.
> > There are more rules to comply
> > with in AVR, and the only real benefit here is that those rules are
> > not murky; they're quite clear.
>
> Those rules may be quite clear for existing airplanes, but they don't
> exist for space transport. A few of the many examples are: AVR has no
> rules for reentry TPS designs or margins. AVR has no rules for the
> materials of construction we are likely to evolve. AVR has no rules
> for how to do supersonic flight, other than they prohibit it.
These are fair points. But the same is true for AST and the industry as a
whole. If you're doing new things, you need new standards. I'm just trying to
address where those standards should be applied and in what existing regulatory
context.
> > Let's recognize that when the FAA
> > certificates an aircraft, what it's doing is blessing the
> > manufacturing process. If manufacture and sale of vehicles is not
> > contemplated it would be nice to see something worked out where
> > limited operation of such vehicles, for revenue, could be performed.
>
> Within AST, that's handled by testing and demonstration. Nothing to
> work out.
Well, except for launch licenses, spaceport certifications, environmental
impact statements, calculation of the expected casualty criterion, and so
forth. This is the downside to AST. Arguably, the per-flight hassle of each
event is not worth
> > Exceptions to the no-revenue provisions for certain types of
> > experimental aircraft flights exist now,
>
> Mostly, these are violations of the rules, not exceptions.
The phrase is "Grant of Exemption." They are awarded on a case by case basis,
sparingly, but there is precedent.
> if, for example, you want a gyroplane endorsement on your
> pilot's
> > license, the odds are that you will be paying for training in an
> > experimental aircraft.
>
> When you do this, you are breaking the rules.
Not if you're flying with an ethical and competent instructor. And the time
wouldn't be loggable for the gyroplane category endorsement to your rotorcraft
class rating anyway. I wouldn't fly with someone who didn't have official
blessing to instruct me in his aircraft.
> > Aviation is an amazingly safe way to travel, and a big part of the
> > reason for it is rigorous and thorough review by the FAA.
>
> FAA doesn't know how to do a "thorough and rigouous review" of a
> launch vehicle any more than NASA does. And NASA's annual budget is
> three orders of magnitude higher than any entrepeneurial company is
> going to raise. Maybe space flight will become safe too, after several
> generations of build and test. Maybe by then, FAA will know how to do
> a thorough and rigorous review. In the meantime, AST has a good
> formula for letting the nascent industry develop.
I'm coming around to the point of view that the difference between AST-based
approaches and AVR-based approaches is the difference between "easier now, hard
later" at the other way around. Implicitly, what I think I'm advocating is an
approach that offers more promise of being workable in the long term.
> > We owe our
> > customers the same regard for their safety
>
> It's not going to happen, Mitch. Nobody is that smart. If your intent
> is to initially get into the "common carrier" business selling
> point-to-point rides to a destination, you have to provide that level
> of safety. I repeat, that's going to be several vehicle generations in
> the future. Maybe. And maybe not. It may turn out that high energy,
> high altitude, highly variable Q and IAS flight really is more
> dangerous. In which case, by your statement, we should not fly at all.
By no means, Dan! I want to fly precisely as much as you do. And I'm in total
agreement that to do common carrier flight like any other airline is a ways
off, certainly. I hope I clarified what I'm adocating: limited use hire of AVR
experimental category "space transports" for such vehicles with appropriate
designs.
> In the meantime, we can fly "Adventure Travelers" who go through a
> rigorous "space camp" getting trained on ejection seat procedures,
> pressure suit procedures, etc. When your customer gets out of this, he
> will understand the risk is more comparable to skydiving or mountain
> climbing.
Well, while "space camp" might be entertaining, I would be very hesitant to
sign up for a regulatory approach that would require it for a person whose
flight is going to be spent sitting down, looking out the window, and not
barfing. I'm all for "space camps" as an enhancement to the customer
experience, but I would regard an effort to put them on the regulatory critical
path as unwise and shortsighted.
That doesn't mean I won't want Pioneer's customers to read the waiver of
liability out loud to a rolling video camera, though.
The irony for me is that XCOR is the poster child for the approach I"m
advocating. The EZ-rocket flies as an aircraft, doesn't it? No legal barrier
prevents you from taking off and flying directly into space as far as I know,
just performance barriers.