All Systems Nose to Tail
How the FAA Ensures Public Safety at Commercial Space Launches
By Jennifer Caron, FAA Safety Briefing Magazine
I almost missed it. My fingers fumbled to click the live stream link to watch the SpaceX Falcon 9 rocket blast into space. I made it just in time as the countdown clock read T-00:01:25 minutes to go.
I anxiously awaited liftoff of the tall, white cylindrical capsule piercing the backdrop of the Florida night sky. As plumes of white clouds blanketed the spacecraft, the launch director called, “Go for Launch.”
It’s now T-minus 30 seconds … 15 seconds … T-minus 5, 4, 3 — the hold-down bolts explode, bright beams of gold illuminate the launch pad, and like a phoenix rising from the ashes, the rocket is unbound and free for liftoff — T-minus 2, 1 — “Engines Full Power! Lift Off!” “Go, Falcon! Go, Dragon!”
What a rush! Every time I watch a launch, I get chills. But consider this — that launch was just another routine FAA-licensed NASA/SpaceX operational success, marking its 27th commercial resupply mission to the International Space Station. Not long ago, who would have believed that commercial space missions would increase in frequency and complexity and become commonplace? Just another day at the commercial space transportation office.
One Giant Leap
For a long time, the commercial space industry was mostly static. What once was an exclusive government-led activity is now open to commercial space operators and private individuals. Now, the industry is very dynamic, and it’s growing and changing day by day. There are new operators in the system, new launch vehicles, and new launch sites and spaceports, with more on the way.
We also see the frequency of launches increasing thanks to innovative commercial technologies. The price of commercial launches is decreasing as companies reuse rockets to save costs and improve accessibility to space. Human space flight is also changing. Although, for now, most of us Earth dwellers still have to “win the lottery” to boldly go and hitch a ride on a space flight.
It’s Not Just NASA
U.S. space transportation has three sectors. The National Aeronautics and Space Administration (NASA) runs the civil sector. The U.S. Space Force, under the Department of the Air Force, oversees the military sector.
The third sector is commercial. The FAA regulates commercial space transportation with jurisdiction over all commercial launches. Yes, the FAA. The FAA has authority over any commercial launch in the U.S. and any conducted by U.S. operators outside of the U.S.
In 1984, Congress passed the Commercial Space Launch Act designating the Department of Transportation as the lead federal agency enabling private-sector launch capability. In 1995, the agency transferred regulatory oversight of commercial space transportation to the FAA. You’ll find the regulations in Title 14, Code of Federal Regulations, parts 400 to 460.
Sharing the Final Frontier
To avoid conflicting requirements and multiple sets of standards between the civil, military, and commercial space launch sectors, the FAA has partnership agreements in place with the following:
🚀 NASA to “achieve safe, reliable, and cost-effective access to space” for passengers, cargo, and payloads for orbital and suborbital missions,
🚀 The Department of the Air Force for licensed launch and reentry activity on Air Force ranges and installations, and
🚀 The National Transportation Safety Board (NTSB) on commercial space mishap investigations.
In addition, NASA and the U.S. Space Force are using commercial operators’ launch services for many of their operations. Both agencies work closely with the FAA to ensure safety without duplication.
These are the Voyages to Exceptional Safety
To enable the world’s safest commercial space transportation system, the FAA plays a vital role in integrating launches and reentries into the National Airspace System (NAS) to balance the needs of all NAS users, including commercial space operators.
The FAA also has safety oversight responsibilities in commercial space to protect the public on the ground, in the air, and on the seas. The agency’s Office of Commercial Space Transportation (AST) works to encourage, facilitate, and promote safe commercial space launches and reentries by the private sector while ensuring the public’s health and safety, the safety of property, as well as the national security and foreign policy interests of the U.S.
Public safety is AST’s top priority. Public safety is at the core of AST’s commercial space responsibilities, from the licensing and permitting process to the safety inspections conducted before, during, and after a launch or reentry, and to the investigation and corrective actions following a mishap event.
License to Launch
You can’t legally drive a car without a driver’s license. It verifies that you have the required training to drive safely. Similarly, you can’t blast into space without a license to launch.
AST licenses and regulates commercial space launch and reentry operations. While public safety is the driving force and ultimate determinant in launch and reentry licensing, AST strives to provide commercial space transportation operators with maximum flexibility to innovate by regulating their operations only to the extent necessary.
The goal of the initial application review is to determine whether or not what the operator is proposing to do is in line with FAA requirements. To help applicants develop a comprehensive, compliant, and complete application for review and approval, AST provides checklists for a launch or reentry license, experimental permit, launch site operator license, or safety approval.
The process begins with conversations about the operator’s concept of operations, focusing on the effects of that operation from a public safety standpoint.
Commercial space covers any type of mission that is suborbital, orbital or beyond when launching on a commercial provider. Key differences determine how a launch is licensed or permitted. For example, some flights are orbital, such as SpaceX flights that orbit the Earth, and others, such as the Stratolaunch, that don’t reach orbit, are designed to return to Earth.
Although a majority of FAA licensed launches do not involve human space flight activities, there are several considerations to be made with those that do. Take, for example, the differences between Richard Branson’s Virgin Galactic flights and Jeff Bezos’ rocket company, Blue Origin, which is famous for launching Capt. Kirk into space “for real.”
Blue Origin flies without a pilot on board. Their flights are suborbital, software-driven, and they launch from a relatively remote area in West Texas.
In contrast, Virgin Galactic (VG) flights have two pilots. Their suborbital space flight system involves two vehicles, a carrier aircraft, or mothership, and smaller spacecraft attached below. Both vehicles are licensed for the launch of a reusable launch vehicle, where the spacecraft separates from the mothership and air-launches under rocket power. VG flights launch from New Mexico, which brings additional considerations to protect the public and surrounding property.
“It’s different when you’re launching nearly straight up in the middle of Texas in a remote location as you do with Blue Origin, but when you’re climbing out and away from Spaceport America in New Mexico, there are people and property around that have to be protected,” says Ray Jenkins.
Jenkins is an aerospace engineer and licensing evaluation team lead in AST’s Safety Authorization Division. He trained astronauts during NASA’s Space Shuttle program and currently leads the FAA licensing teams for human space flight operators Virgin Galactic, the Boeing CST-100, Space Florida, and reviews safety approvals for commercial ground and flight training from his office at the Cape Canaveral Space Force station near the Kennedy Space Center in Florida. “You have a mothership that’s carrying a rocket with nitrous oxide and other very explosive commodities, and you have to make sure that these are not going to fly over populated areas in the event of an anomaly,” Jenkins explains.
The FAA also requires human space flight commercial operators to provide life support, smoke detection, and fire suppression systems on the launch or reentry vehicle. Operators are also required to take the precautions necessary to account for human factors that can affect a crew’s ability to perform safety-critical roles in such things as the design of the vehicle and mission planning.
“We look at what kind of ground equipment they’ll use, how they’ll pressurize the vehicles before they fly, what kind of fuels they’ll be using, and how the space flight participants will be informed of the risks and trained to fly aboard. We’re looking at it from beginning to end, whether pre-launch or post-landing,” says Jenkins.
SpaceShipTwo, another VG vehicle, is a rocket going up, but a glider coming down. “We need to understand which way the rocket’s pointing, which means when it’s coming down, we need to make sure it’s not going over-populated areas,” Jenkins explains.
For crewed flights, AST also reviews the commercial space operator’s pilot qualifications and training. Jenkins reviews the operator’s pilot operating handbooks in great detail to ensure that these handbooks address all the operations necessary to function safely.
FAA commercial space safety regulations also contain requirements for flight crew qualifications and training so that the vehicle’s operation will not harm the public. This includes training for routine, emergency, and abort situations and demonstrating the ability to withstand the stresses of space flight.
Next, AST conducts deep dives into flight and system safety analysis by performing more specialized studies and reviews. With a risk-based approach, they focus specifically on the effects a commercial space operation could have on public safety. AST uses flight safety and system safety analysis to determine license application compliance and develop a quantitative assessment of public risk.
To calculate risk and determine probability, AST’s technical staff evaluates several critical factors of the proposed operation. For example, they look at what would cause the spacecraft to break up and how it would do so. They evaluate the location of property and persons, performing complex calculations such as the potential trajectory of the debris and whether or not these pieces are explosive or could cause harm.
“Essentially, we apply a risk-based approach to commercial space flight to estimate and calculate the public’s safety and their level of risk during all phases of commercial space operations,” says Katie Cranor. Cranor is AST’s Safety Analysis Division manager, coming to the FAA after 17 years at NASA as deputy chief of safety and mission assurance at NASA Wallops Flight Facility in Virginia. “Our team consists of highly-trained engineering specialists that weigh in on the initial application by analyzing the operator’s flight safety and system safety processes.”
The flight safety analysts on Cranor’s team aim to achieve a probabilistic expectation of the likely outcomes. They review the launch vehicle and the potential hazards, such as what would happen if the guidance system were to fail or the probability that the vehicle would fly off in the wrong direction.
Flight safety analysis and system safety analysis are concurrent processes. System safety is the umbrella that identifies the hazards. System safety analysis evaluates particular hazard control strategies to mitigate the risk to acceptable levels. AST requires commercial operators to follow a system safety process and designate an independent safety official within their organization that is separate from the launch vehicle team. System safety analysts take an overarching approach to evaluate the operator’s system safety processes from the top down. They identify top-level hazards and ensure that the verifications of mitigation measures put in place by the operator are sufficient.
AST’s system safety analysts evaluate every safety-critical system on the vehicle, particularly the systems that implement the operator’s hazard control strategy, design, and all components of the operator’s flight safety system.
Flight safety systems, for example, are specific to the operator’s mission. In VG operations, the flight crew is essentially part of the flight safety system; therefore, they play a critical safety role in the event of an anomaly. They’re on the controls and have direct input into where the vehicle is going.
Operators such as SpaceX use an autonomous flight safety system (AFSS). Suppose the vehicle starts violating a flight rule. In that case, the flight computer will take action to control the flight of the vehicle. Some AFSSs set off linear-shaped, on-board ordnance designed to blow open fuel tanks to disperse the engine’s propellant and break up the vehicle.
Other operators use a thrust termination system that cuts all power to the pumps feeding the engine.
“Our analysts assess the flight safety system’s ability to end the flight of the rocket in a controlled manner if it were to go off course,” Cranor explains.
Working closely with the commercial operator’s independent safety official, AST also develops mitigation measures that serve as flight commit (go/no-go) criteria on the day of the launch to protect flight and launch personnel and the public in the surrounding area.
To conclude their evaluation, AST identifies inspection items, terms and conditions, and any procedures the operator performs before launch.
Once AST has issued the license, the inspection team takes over. They perform safety inspections with a risk-based approach. They ensure the operator complies with the applicable federal regulations, verify the representations they made in their application, and provide oversight on the operator’s launch operations.
“To do our jobs, we rely heavily on the products produced by our teams in the Safety Authorization and Safety Analysis divisions,” says Jesse Hanson, AST’s Safety Assurance Division Central Branch Manager and mishap program lead in Houston, Texas. “Safety assurance is the pointy end of the process; our safety inspectors are out there with the operators on a day-to-day basis verifying compliance as operations occur.”
Inspection teams perform preflight, launch, and post-flight activities, attending onsite flight safety system testing to verify performance as expected during the launch. Inspectors are onsite with the commercial operator at flight readiness reviews confirming that ground and flight safety systems, safety equipment, and launch operator personnel in safety-critical roles are prepared for the mission. They’re also at emergency response rehearsals to ensure the operator is ready to respond should a mishap occur.
Safety Assurance confirms that the operators have established hazard areas and processes and procedures to ensure that the public remains outside of those areas. That includes NOTAMs and NOTMARs (Notice to Mariners) to protect the site and ensure the public is advised about where there will be a hazard, particularly around the launch area or where an expended rocket stage will impact.
“My safety inspectors at Cape Canaveral and the Kennedy Space Center work closely with NASA and the Space Force to ensure compliance for commercial launches from federal ranges,” says Safety Assurance’s East Branch Manager Erin Moll. She heads up the Cape Canaveral Space Force Station field office in Florida. “We coordinate with the ranges to ensure that our public safety criteria, our regulations, and the standards and requirements of the Air Force are being met.”
Houston, We Have a Problem
Each mission is unique and presents new and different challenges. Therefore, the FAA requires all licensed commercial space transportation operators to have an FAA-approved mishap plan containing processes, procedures, and checklists for reporting, responding to, and investigating mishaps.
The FAA identifies nine events that constitute a mishap, such as malfunction of a safety-critical system or high risk of causing a severe or fatal injury to any space flight participant, crew, astronaut, or member of the public.
“For a standard launch, we’ll have one safety inspector on console, supported by a duty officer, and a mishap response coordinator,” explains Hanson. “In the event of a mishap, the safety inspector, duty officer, and I ensure that we’re making all the required notifications, coordinating with stakeholders, and tracking the operator’s implementation of their emergency response plan.”
A recent example occurred in 2021 when Firefly’s Alpha rocket veered off course just minutes after launch, triggering the Space Force launch team to initiate the flight safety system’s destruct command to break up the vehicle.
After a mishap, the FAA requires the operator to investigate the root cause and identify and adopt preventative measures to avoid a recurrence. The AST safety inspector is on console and verifies if the operator implements their procedures under the representations made in their application or emergency response plan. This includes steps to minimize and contain the mishap, secure data and physical evidence, and provide the FAA with the proper notifications.
Based on the nature and severity of the mishap, AST may authorize the operator to investigate per their mishap plan under FAA oversight, or the FAA or NTSB may lead the investigation. Based on the commonality of launch vehicles and systems, NASA and Space Force personnel may observe commercial space mishap investigations.
This past year, the FAA and the NTSB signed a new memorandum of agreement on commercial space mishap investigations. The agreement identifies the NTSB as the lead agency to investigate commercial space launch or reentry mishaps that result in “a fatality or serious injury to any person, regardless of whether the person was on board the commercial space launch or reentry vehicle, or damage to property from debris that could reasonably be expected to cause death or serious injury, and the property is not associated with commercial space launch or reentry activities or the launch site.” The FAA will lead investigations for all other commercial space mishaps.
To foster collaboration and share best practices and lessons learned in mishap investigations, representatives from the FAA, NASA, NTSB, and Department of Air Force meet regularly in the mishap Quad-Agency Working Group.
To Infinity and Beyond
With a milestone of over 530 licensed launches and counting, the FAA enjoys an exceptional safety record while balancing the extraordinary growth and demands in the commercial space transportation industry. The FAA continues to ensure the safe integration of commercial space ventures into the world’s busiest airspace as we expand our horizons to the Moon, Mars, and beyond.
Jennifer Caron is FAA Safety Briefing’s copy editor and quality assurance lead. She is a certified technical writer-editor in the FAA’s Flight Standards Service.