On Fri, 18 Oct 2002 07:17:25 -0400, "Justin S. McFarland"
<[EMAIL PROTECTED]> wrote:

>Did you get in contact with the AST/FAA yet declaring your intentions?

Michael Wallis and I went to visit AST in Washington in October 1999,
to apprise them of what we're working on.  It hasn't changed since,
though we're well behind our intended schedule as of then.

>They want you do to an impact study proving you're not going to harm anyone

The EC calculation doesn't have to prove you're not going to harm
anyone.  It has to prove you will harm no more than 30 third parties
per million flights.  That's a mighty low figure, but it isn't zero.
And, members of the flight crew (if any) and ground crew - anyone
directly involved with the flight - aren't third parties, and aren't
involved in the EC calculation.

>as well as a few other fun and exciting quirks. They'll step you through
>exactly what they want from you based on your vehicle configuration.

Already done, in the NPRM for RLV launch licensing.  They have a very
nice Safety Systems Engineering Program there, free for the
plagiarizing.

>Essentially they want you to mathematically prove that the probality of
>killing innocents or causing damage to property is very small.

Of course, the easiest and most reliable way to do this is to fly in
an area where are no third parties within the distance the vehicle can
fly.  With POGO at MTA, this will be easy.  With some of later KISS
variants, like Spike, this won't be possible at MTA, because Randsberg
Road is only a few miles away.  It will be easier at Black Rock, but
then we have hazmat regulations to deal with.

Another regulatory aspect I'm not sure I've publicly discussed is when
you need a launch license.  FAA has a standing order to its regional
centers to forward all waiver requests for 25,000 feet or over to
Washington, so AST can look at them.  I recently (finally) found an
online copy of FAA Order 7400.2, which codifies this.  In addition, it
says that any rocket not exempt under FAR 101 will be reviewed by AST
under Part 400 provisions.

So, you don't always need a launch license to fly between 25,000 feet
and 164,000 feet.  You may just get a waiver.  It will depend on where
you're launching, how big the rocket is, etc.  164,000 is the magic
number above which you definitely need a launch license because you
are placing something "otherwise in outer space."  164,000 feet is 50
km, which is the altitude above which you need a license to operate an
amateur radio space station, per FCC rules.

>The process needs to be started now (if it hasn't already) so that when you
>make your run for space, you're not held up by red-tape.

I haven't started work on a launch license application, because we
have begun detailed design on a vehicle which will require one.  We
will need a burn time waiver for POGO, but it will be easy to prove
that it can't hit the road, and there isn't anything else out there.

-R
Randall Clague
Regulatory Affairs
ERPS

--
"...And the last thing I remember is asking,
'What could go wrong?'"
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