General Industry Comments, Concerns

1. Industry Comments to Commercial Space Transportation Reusable Launch Vehicle Operations & Maintenance Guidelines Presented to the COMSTAC RLV Working Group by Chuck Larsen Federal Aviation Administration Associate Administrator for Commercial Space Transportation October 26, 2004

2. General Industry Comments, Concerns • Industry is concerned that these Guidelines will become regulations soon • Industry believes that it is premature for these Guidelines to be developed • AST plans to study Industry’s comments in our RLV O&M Subgroups while we and Industry together gain experience with RLV Operations • AST plans continued consultations with the COMSTAC RLV WG during the development of the Guidelines

3. RLV Operations & Maintenance Preliminary Guidelines RLV Maintenance

4. Maintenance • Preliminary Guidelines • 1. Maintenance Program Plan 2. Maintenance Tracking System 3. Maintenance Requirements Flow Down to Sub-tiers 4. Configuration Management System 5. Inspection Schedule

5. Industry Comments to Maintenance • Change the “shall” and “must” imperatives to “should” • A storage plan for spare parts cannot be developed before some operational experience is gained • Cannot accurately specify PM, staffing levels, skill levels until operational experience is gained • Safety through accountability is a myth • Don’t recommend a tool control/calibration program unless special tools required • Don’t require software ID, tracking and reporting for vehicles that don’t use software • Inappropriate to require maintainability requirements be imposed on each subcontractor until industry matures • CMS should be a recommendation not a requirement • Inspection schedule meet operational needs while ensuring public safety and updated to reflect operational history

6. RLV Operations & Maintenance Preliminary Guidelines RLV Support Personnel

7. RLV Support Personnel Hypothetical proposed tasks/responsibilities used to fulfill the functions of an RLV operations and maintenance program: VMC – Vehicle Mission Coordinator RAMT(s) – RLV/Aerospace Maintenance Technician(s) RAMI(s) - RLV/ Aerospace Maintenance Inspector(s) MSO - Mission Safety Organization Note: One person may perform more than one task/responsibility concurrently

8. RLV Support Personnel • Preliminary Guidelines • Reviewed the RLV Working Group comments to the draft Guidelines and as a result, • Combined the ATC-O and the VOD task/responsibilities into the VMC • Removed the LSO task/responsibilities from the RLV O&M Guidelines • Replaced the RS task/responsibilities with the MSO 2. Developed Training Guidelines 3. Developed Qualification Guidelines

9. Industry Comments to Support Personnel • General • Change the “shall” and “must” imperatives to “should” • Change “required” to “recommended” • Change “subject to” to “available for” • Change “safety inspection” to “study”

10. Industry Comments to Support Personnel • Specific to VMC • VMC as Mission Planner acceptable in principle • FAA does not have established procedures for defining and filing mission profiles • No ATC collaboration is necessary if in DoD restricted airspace • LSO coordination is necessary but not clear it should be VMC responsibility • Knowledge of ATC rules/regulations and of NAS should be a recommendation not a requirement • VMC should not plan a mission the vehicle can’t fly or violates a regulation • Do not need to collaborate with LSO on mission planning • Do not need to coordinate with LSO and ATC to meet mission milestone dates and activities

11. Industry Comments to Support Personnel • Specific to RAMT • It is too early to tell whether the proposed ratings matrix makes sense • If it does, industry will develop the matrix and develop appropriate technician standards • No consultation with XCOR on its experience operating the EZ-Rocket • Specific to RAMI • It is to early to define the positions, skills, responsibilities, qualifications for inspectors

12. Industry Comments to Support Personnel • Specific to MSO • Completely unsatisfactory and absolutely unacceptable • Don’t dilute the authority of the Safety Official with some nebulous MSO • Safety Official does not need or want the support of an MSO • Can be more than one hold decision as every moment of pre-flight is both a potential hold and a potential abort • Only one person is necessary to activate the Flight Safety System • All subject knowledge, task knowledge, and task performance described are of the Safety Official • XCOR’s safety organization is XCOR Aerospace

13. RLV Operations & Maintenance Preliminary Guidelines RLV Operations

14. Operations • Preliminary Guidelines • Draft Guidelines covered flight safety system, communications and thermal protection safety-critical systems. • Additional operations guidelines developed for these and other safety-critical systems, including electrical power and structures, systems engineering and propulsion.

15. Industry Comments to Operations • General - Change the “shall” imperatives to “should” • Specific to SYS-1 • Rephrase to “The RLV operator should consider using functional redundancy for safety-critical systems, and where employed, the RLV operator is encouraged to make available to AST his processes and procedures for switching from primary to secondary systems” • Specific to FSS-1 • Rephrase to “RLV Operator should operate the vehicle such that its risk to public safety is minimized on the ground during any attempted landing, including abort and contingency landings”

16. Industry Comments to Operations • Specific to FSS-2 • Rephrase to “The RLV operator’s ability to control the instantaneous impact point (IIP) should be extremely reliable unless the IIP cannot reach a substantially populated area” • Specific to COMM-1 • Rephrase to “The RLV operator is encouraged to transmit safety-critical data from the RLV to the ground in real-time during launch and reentry, when practical. The RLV operator is encouraged to record and store safety-critical data for post-flight analysis” • Specific to COMM-2 • Rephrase to “The RLV operator should ensure the continuous recording of safety-critical data during licensed operations. The data recording should not depend on the vehicle landing safely to retrieve the data”

17. Industry Comments to Operations • Specific to EPS-2 • Rephrase to “The RLV operator should ensure that stored power reserves are sufficient to support normal vehicle operations during any credible flight scenario, including nominal flight, contingency abort, and emergency abort” • Specific to STR-1 • Rephrase to “With the exception of test flights, the RLV operator should make every effort to ensure that the vehicle is operated within its design parameters, including safety margins. In an emergency, the RLV operator may waive this guideline in the interest of public safety” • Specific to PROP-1 • Rephrase to “The RLV operator should operate the vehicle such that the vehicle’s safety-critical propulsion parameters, if any, are maintained within acceptable limits”

18. Commercial RLV Operations and Maintenance Activities • FAA/AST RLV O&M Sub-groups Drafted Preliminary Guidelines – 10/03 to 5/04 • RLV O&M Team Briefed AST 2 on Draft Preliminary G/L - 06/04 • RLV O&M Team Briefed AST-1 on Draft Preliminary G/L - 07/04 • Transmitted RLV O&M Preliminary G/L to COMSTAC RLV WG Chair - 07/09/04 • Received RTI RLV O&M Guideline Inputs and Technical Evaluation Report (draft): Maintenance – 08/04 • Received COMSTAC RLV WG consensus comments to RLV O&M Preliminary Guidelines 09/23/04 • Received RTI RLV O&M Guideline Inputs and Technical Evaluation Report (draft): Training – 10/04