NASA Releases LEO Commercial Crew Certification Requirements

When NASA is the lead for hardware development, and they need the services of aerospace contractors to help them build, test, and fly the hardware, the contractor is all to happy to charge NASA lots-o-money to meet ALL the NASA requirements.

In this new world of commercially led developed HSF rockets,the contractor: Space X, Orbital, whomever, will now have to spend their own money meeting NASA crew certification requirements, with the idea of realizing a profit at the end of the day.

The extent to which changes to say, Falcon 9 , to meet Crew Certification Requirements, drives the baseline costs of the Falcon 9 up for non NASA customers, ....well,,,,that isn't going to sit pretty with Space X as it will have to raise their prices for the rocket.

Let the games begin!

This is exactly what Wayne Hale warned about. It is business as usual at NASA. Nothing has changed. These requirements are going to ensure commercial human spaceflight will never be permitted to be profitable. Not only is the list of all the NASA requirements documents burdensome, but it still does not get around the fundamental flaw in the NASA model:

1) NASA is both appropriator and spender of the money for such systems, hence they feel correct in being the one who sets the specs. But...
2) NASA is also the arbiter of not only what THEY think the requirement really means (the biggest problem with using vague, aspecific requirements), but they also position themselves as the ultimate certifying agency to determine when/if the requirements have been satisfied.

Until this obvious conflict of interest in the NASA model is corrected, we shall continue to go nowhere in advancing commercial space. The only appropriate solution, as I have long pointed out on this forum, is to adopt the FAA model, where the FAA is NOT the appropriator/spender of the money for the vehicles....but they ARE the independent agency which sets CLEAR requirements that protect public safety, and also determine when those requirements are met.

You cannot have the fox RUNNING the hen house and expect to make a profit on eggs. NASA can do ONE of the two jobs enumerated above, but not both. They need to figure out which one they want to do and drop the other. My vote is they do #1, and that means they will have to SERIOUSLY clean up how they specify requirements. No more willy-nilly words and speculative interpretation when it suits their desire.

Oh yes, and let us also not forget that companies price their development and certification programs based on "shalls". For every "shall" there is a dollar amount associated with designing and verifying that it was met. This is, by far, the largest cost driver on ANY aerospace project.

It would be more consistent with the commercial philosophy if NASA simply levied a monetary penalty for any crew death or equipment loss by a commercial provided. NASA could determine a monetary penalty high enough to elicit the behavior it is trying to dictate through these safety requirements. It would interesting to see if commercial entities like SpaceX would follow the same practices as NASA or would device some other [innovative] way to achieve the level of safety that results in specified risk/return posture.

Ray - you are correct except for the fact that this just deals with CCTS.
This does not affect Virgin Galactic or SpaceX flights for customers other than NASA.

What I see happening is Virgin Galactic flights starting and being a novelty, but creating the impression of commercially available spaceflight to the public.

Then we'll have a Bigelow Hab serviced by Soyuz/Dragon.

NASA will be dragged into the future, albeit kicking and screaming.

Not good news for SpaceX unless they get NASA to continue to subsidize them in a bigger way. With funding being tight in WDC it is likely SpaceX will be limited to cargo flights and maybe as Ray says some support for non NASA customers but there is not a lot of money in that business sector - at least in the near - mid future.

Did you guys read this document? Did you get past the introduction?

"Per this policy, NASA’s approach for commercial crew
transport is to base CCTS certification on NPR 8705.2, Human Rating Requirements for Space Systems.
This certification will apply to NASA missions only (i.e. those carrying NASA or NASA sponsored
crew members)."

If you want to fly on a SpaceX Falcon/Dragon combo not under the auspices of NASA, you will be able to. The FAA may have something to say about it, but ultimately, this is just NASA handcuffing itself.

Honestly I see no problem with this policy as long as NASA pays SpaceX for the ludicrous documentation and testing that has been clearly demonstrated by SpaceX to date.

Remember, it's NASA's dime, you and I are just giving NASA the dime ;)

VR
RE327

This document is for SpaceX. So until we hear what SpaceX thinks.... Not sure how laypersons can have an opinion.

I'm glad to see that some of us got the main point — this spec applies to commercial companies doing NASA contracts only, and has no bearing on the commercial industry as a whole. Why is it that every time another spec makes the news we have to go through correcting this same misassumption?

You also have to consider that NASA isn't free to create whatever specs they like. They have regulatory agencies and insurance companies and congress and everybody else breathing down their neck, each one insisting including on its own two cents.

With respect to overblown specs (like this and like the bolt-pick-and-torque in a recent thread), it is by no means unique to NASA. How many of you have worked for a contractor on a military contract? I've worked on military programs for the US, Canada and Australia, and I found that they were all to some degree "over-speced" just like the comments we're seeing about NASA. (USAF was the worst in my experience.) The same holds true for issues like requirements creep and cost-plus. And it's not just mission critical systems programs that are so spec constrained; even "small" programs like training systems go through this.

So, just maybe, the problems are not so much NASA-unique as simply part of the game. I think there's plenty of blame to go around.

Just my thoughts.

Steve

I think people are being a little quick to pile on.

It's not the same document Wayne Hale had problems with.

Overall, I think it's about right. NASA doesn't need to reproduce what it does for NASA and force it on commercial providers. NASA needs to clearly state what it's requirements are and have the commercials write how they will do it. I think this what NASA is doing.

Some of if was a bit ambiguous, but overall, it's good.

So since this only applies to NASA flights only. Any bets on what year spacex will fly their first commercial dragon lab joy riders to make history again :)

Spacex history making tour
Hurry Hurry dragon lab tour rides. No escape system yet, bring 6 of your friends for best price. We offer fly by tour of the international space station. We fly close enough for them to see you give them finger through our window ports. We can't land there because they are doing very important science studying weightlessness and space station operations. In a few years our tour will include stops at one bigelows 10 stations now being built under contract for other countries. One will be outfitted for roomy deep space flights to mars for the first human mars landing.
Bring your money sign the lean release. we don't expect NASA to fund cots d before 2016 that stuff take time you know. Enjoy your ride :)

If SpaceX has to perform design changes that increase the weight of the Dragon by half a ton to comply with the NASA specification then other users of the Dragon will find themselves with a heavy spacecraft. Make sure that the rules are sensible.

The CST-100 and DreamChaser will also have to comply with this rule book.

Bigelow needs to read the specification carefully, two thirds may apply to them - even if that was not the intention.

SpaceX, meet SpaceHab.

Spacex history making tour
Hurry Hurry dragon lab tour rides. No escape system yet, bring 6 of your friends for best price. We offer fly by tour of the international space station. We fly close enough for them to see you give them finger through our window ports. We can't land there because they are doing very important science studying weightlessness and space station operations. In a few years our tour will include stops at one bigelows 10 stations now being built under contract for other countries. One will be outfitted for roomy deep space flights to mars for the first human mars landing.
Bring your money sign the lean release. we don't expect NASA to fund cots d before 2016 that stuff take time you know. Enjoy your ride :)

After reading the requirements I was pleasantly surprised. They don't micromanage the vendor (such as requiring certain metals or particular management practices). They offer plenty of sound advice which has been learned by space agencies the hard way (such as having a beacon on board so if you land somewhere unexpected the rescuers can find you).

[It was also interesting to note that the Space Shuttle violates about half this document.]

I can't find anything to fault here. If there is a specific problem, I'd love to hear it.

A funnier question is how much does Orion violate? ;)

What part of buying a COMMERCIAL SERVICE does NASA not get ? NASAs role here should be to verify those companies are adhering to industry best practices & assessing risk to NASA payloads (humans or non-human) and determining if that risk is acceptable for a particular launch vehicle.... NOT thinking their smarter than those companies about vehicles they played ZERO role in developing by levying vehicle system requirements. NASA is going to make this venture much more costly than it should be.

Steve,

I'm glad to see that some of us got the main point — this spec applies to commercial companies doing NASA contracts only, and has no bearing on the commercial industry as a whole. Why is it that every time another spec makes the news we have to go through correcting this same misassumption?

Perhaps it is because you are the one doing the assuming? Please show me how you know that this document will not be imposed for non-NASA flights? I do not think that decision has been made, so how you can assume that it ONLY applies to NASA is a bit tenuous, to say the least.

In fact, reading the new post on the Commercial Human Spaceflight Forum that Keith posted this morning, it sounds like this could well be adopted as the industry norm:

"Attendees will gain insight to techniques that will be required to successfully achieve the NASA human rating certification and FAA commercial spaceflight licensing."

No caveat there at all. If one reads conservatively (plans for the worst) then one would assume that any time you want to fly humans you will both have to achieve NASA human rating certification and FAA spaceflight licensing.

Note: NASA does not currently human-rate aircraft. Why should they be allowed to be the one who does it for spacecraft?

Neil,

After reading the requirements I was pleasantly surprised. They don't micromanage the vendor

Right, but only because they cannot cover all aspects in this document. Rather, they leave the micro-managing for the "Program Manager" who will unilaterally determine the specifics of what a requirement really means to any applicant.

I can't find anything to fault here. If there is a specific problem, I'd love to hear it

I believe I highlighted the specific problem in my first post. It is a conflict of interest in managing both the system development and in making determinations of compliance for certification. NASA seems to love Independent Verification & Validation (IV&V). Wonder why they do not love independent certification?

Let me make it even more clear what the problems are with these requirements: They are subjective (esp. NPR 8705), and an applicant will not know EXACTLY what must be met until they are fully pregnant (i.e. already committed to the NASA ill-defined process). That amounts to serious risk being taken by the applicant.

Let me also highlight the problem by showing you how the FARs deal with safety in an unambiguous manner (unlike the NPR and this new document which leaves details to the PM). Here is a quote from FAR 25.1309:

(b) The airplane systems and associated components, considered separately and in relation to other systems, must be designed so that

(1) The occurrence of any failure condition which would prevent the continued safe flight and landing of the airplane is extremely improbable, and

(2) The occurrence of any other failure conditions which would reduce the capability of the airplane or the ability of the crew to cope with adverse operating conditions is improbable.

Now, to a neophyte, it may seem that "extremely improbable" and "improbable" are subjective requirements. But to an informed engineer, we know that those words have well-defined numerical failure rates associated with them. There is no need for a "Program Manager" to tell a potential applicant what these requirements mean. Moreover, there is ample additional information (not regulatory, but guidance) in the form of the Advisory Circular and Technical Standard Order systems. These systems basically are the FAA telling the applicant "if you do it this way, the chances of you getting your certification are very high."

Seeing that so many other countries directly adopt the FARs for their own airworthiness certifications for aircraft, I see no reason why this same approach should NOT be applied to human spaceflight certifications. There is no need for NASA to maintain a stranglehold on the industry by wielding nebulous (risky) requirements that can only be clarified by their guy (Program Manager conflict of interest).

@spaceman85:
Perhaps it's you that doesn't get it. You just assigned NASA a responsibility that actually already belongs to the FAA.

Being lazy, I took the following from wikipedia, but the same info exists in the official FAA documents:

"The Federal Aviation Administration's major roles include:
• Regulating U.S. commercial space transportation"
(It was the first item on the list).

"In 1995, the agency [FAA] assumed responsibility for safety oversight of commercial space transportation."

I would say that "LEO Commercial Crew Certification Requirements" clearly comes under the "safety oversight" responsibility.

=============================================

@Ray:
"This document defines the requirements, standards and certification package contents that will be used to certify a CCTS for LEO Missions".

I think that statement pretty clearly supports my statement, no assumptions involved. Unless, of course, someone other than NASA starts a program that can use commercial LEO services and also calls theirs "CCTS," then the situation becomes needlessly ambiguous.

You say: "Please show me how you know that this document will not be imposed for non-NASA flights?" Imposed by whom? NASA is not in a position to impose this spec on other buyers of commercial LEO services. As I explained to spaceman85, only the FAA has that jurisdiction.

As a general statement, saying that I "don't know" what might happen in the future has absolutely no bearing on what has already happened. You could (falsely) argue any position that way.

Just my perspective.

Steve

Steve,

Although the FAA AST has the authority to regulate commercial flights the final word will be with the firms that will insure the flights of the new space vehicles and they will likely require their clients to follow the standards that are most likely to minimize their liability. In this context it will be very hard for them to ignore the NASA requirements.

So even if firms are not NASA contractors they will probably need to follow the NASA standards or pay a hefty price for their insurance premiums if insurance is even available to them. This is really the big downside to commercial crew and the new space policy.

You say: "Please show me how you know that this document will not be imposed for non-NASA flights?" Imposed by whom? NASA is not in a position to impose this spec on other buyers of commercial LEO services. As I explained to spaceman85, only the FAA has that jurisdiction.

Do not be naive. This document will form the basis of any non-NASA requirement. The normal way international standards are written is to take a national standard, replace the front sheet and reformat the rest in the organisation's style.

Consequently it is very important to get the initial document right.

In the many standards documents listed,the companies must be able to find an answer to any questions they might have.They say nothing about a reentry escape system.They go straight to safe haven.NASA says they will not do anything that is not practicable,maybe it is impossible.I have not found anything saying a crew or personal escape pod is impossible.But maybe it is.The head of the House science committee said he would ask about no reentry escape system on another day.

@Thomas Matula:
I agree that the insurance companies will certainly have an effect on things to come. I have made this point myself in the past. However, I was addressing the wrong assumption that a number of posters had made by pointing out that currently the FAA has this legal jurisdiction, not NASA. I made a straight-forward statement about what is, not about what might happen in the future.

@A_M_Swallow:
You tell me: "Do not be naive" — sorry, apparently you have a crystal ball or something that lets you see into the future. As I said above, I was addressing the wrong assumption that a number of posters had made by pointing out that currently the FAA has this legal jurisdiction, not NASA. So, in response, I'll tell you: Do not be so arrogant. I was talking about now, but you insult me by presuming to know the future. At least take the time to read properly (and perhaps even think) before launching your sneering attacks.

Happy New Year.

Steve

Interesting comments...

Sadly, I don't see any acknowledgment of the business case for LEO Crew Transportation. You know...real world considerations about whether there's a viable market from which a company can expect to make a profit.

We can all dream of the day when there's a robust market, but it's simply not there now.

The reality is that NASA is THE ONLY customer that a credible company will base it's business decisions upon.

As such, NO credible company will invest in the market without NASA as the anchor tenant.

NASA Commercial Crew launch is the enabler for a robust LEO market. NASA is in a position to facilitate this market via their requirements and acquisition approach.

NASA can be an enabler, or an impediment.

They say nothing about a reentry escape system.They go straight to safe haven.NASA says they will not do anything that is not practicable,maybe it is impossible.I have not found anything saying a crew or personal escape pod is impossible.But maybe it is.

A winged and/or lifting body spacecraft could be fitted with a crew escape capsule, which would probably be similar to the four person escape capsule installed on three B1-A bomber aircraft. This would allow ejection at a maximum airspeed something less than Mach 2.0.

I suppose a ballistic re-entry vehicle such as a Dragon or Olds Orion could be fitted with an escape capsule/escape pod, but ejecting the pod out the side instead of the dorsal surface of the vehicle -- Well, the aerodynmamics of side ejection into the boundary layer is probably a more difficult feat.

No matter if the spacecraft is a capsule or a horizontal lander, it is not practicable, maybe it is impossible, to eject at a high Mach number. ... too hot and too much dynamic pressure. The escape pod with have to have a thermal protection system almost as robust as that of the main vehicle.

I always wear my parachute when I fly delta. Just don't trust the ones they provide.

A ballistic capsule fitted with a LAS literally is an escape capsule, at least in theory. That is one of the reasons why it seems safer than an aerodynamic crew vehicle. The latter, after all, needs to be accelerated above its stall speed with margin enough to glide down to its landing site.

FWIW, I increasingly like a DC/X-style powered descent reusable crew vehicle. You can fit a ballistic capule to the top as an emergency escape vehicle too.

@Steve Whitfield

I do not need a crystal ball to predict the Standard Operational Procedure, just know some engineering history.

The world's first standard was devised by Joseph Whitworth in 1841. The process and associated government regulation has been repeated hundreds of times since then.

A ballistic capsule fitted with a LAS literally is an escape capsule, at least in theory. That is one of the reasons why it seems safer than an aerodynamic crew vehicle.

Tell me, which space capsules have reserve parachutes, in case the main chute doesn't open properly?

Uh, none?

The latter, after all, needs to be accelerated above its stall speed with margin enough to glide down to its landing site.

Not if the winged or lifting body spacecraft has an escape pod or ejection seats designed to climb to minimum necessary altitude and function after separating from the air vehicle at zero altitude.

Ejection seats and ejection/escape capsules on military aircraft have been rated for zero altitude operation for a long time.

The latter, after all, needs to be accelerated above its stall speed with margin enough to glide down to its landing site.

Furthermore, you seem to be assuming that a winged or lifting body spacecraft would not have an emergency rocket to propel the spacecraft away from its malfunctioning launch missile during ascent.

But a gliding re-entry vehicle vehicle could certainly have an emergency/escape rocket. It would probably be a pusher instead of a tractor configuration. Heck, I think the Dragon space capsule is going to have a pusher escape rocket.

One advantage of a pusher emergency/escape rocket is that it can be ignited and used as part of a normal launch after second stage separation if the escape rocket is not needed for an emergency launch abort.

"Furthermore, you seem to be assuming that a winged or lifting body spacecraft would not have an emergency rocket to propel the spacecraft away from its malfunctioning launch missile during ascent."

Actually, I wasn't. Accelerated by LV or by LAS motor (dedicated or dual-use), it has to be above stall speed with margin either way. Sorry if my first post wasn't clear on that subject.

This, of course, means that an aerodynamic return vehicle would almost certainly have a minimum energy requirement for a pad abort that was necessarily higher than that of a ballistic capsule.

Folks:

After a quick read I agree with some of you that it is a pretty lenient document for NASA. I also agree that neither the Shuttle nor the Soyuz meet the minimum standards they set forth. As it stands, except for thr Russians heritage experience, the Falcon/Dragon may already provide safer operations than the Soyuz. State of the art electronics, new materials and processing techniques, controlled re-entry, ground or water landings improve over all safety. Even though every Soyuz launched is fresh off the factory floor they are still based on a forty year old design carefully matured over time. Any new entry into the space biz will have the advantage of fifty years of technological development blended with the latest developments. No competition really.

Somehow I don't think that Spacex is going to be interested in building one rocket/capsule for NASA and another for everybody else. What would Spacex's commercial customers think of something like that? Like, "We're getting a cheaper ride for cheaper?" You know what I mean. Nobody likes a double standard.

This already looks like one.

tinker

The sooner commercial providers can move launch resources to a non-US equatorial island and still get good telemetry they will.

Once Bigelow gets other launch destinations in orbit commercial launch providers can and will skip NASA's death-grip entirely.

Another industry the US could have here on American soil that is being pushed out...

Commercial companies like Space X are their own worse enemies because they are obsessed with trying to integrate themselves with government as the essential provider of services for NASA and the US military instead of focusing on the private commercial benefits of manned space travel– which should be far more lucrative in the long run!

The fastest and cheapest way to achieve their goals is to stop trying to provide services for NASA and the military and start providing services for private customers. Polls indicate that 40% of Americans would love to travel into space and there are about 100,000 people on this planet who could afford a $20 million ticket to a private space station.

Marcel F. Williams