JF Mezei wrote on Mon, 30 Apr 2018
16:03:30 -0400:

On 2018-04-30 10:44, Fred J. McCall wrote:

Why would they develop such things before they had to?


Wouldn't such rules be needed PRIOR to SpaceX and Boeing bidding on
comemrcial manned taxi services ? How can you bid on a service before
you know what rules will be imposed on you?


They're not bidding 'commercial' services.


Until such time as one of them is being used for commercial operations
the question is irrelevant.

With Dragon2 flying this year "Until such a time ..." is NOW.


Except Dragon V2 is flying under NASA rules and not flying 'commercial
services'. You're very confused about this. The word 'Commercial' in
the contract doesn't mean what you apparently think it means.

purely commercial operation, I suspect FAA is going to have to develop
something, since NASA has neither the authority to 'approve' manned
spacecraft for purely commercial

You're correct. As far as Virgin Galactic joy rides, NASA has no say.

But it becomes a grey area when it comes to ISS taxi and resupply
missions since NASA is the customer, and as a customer, can impose
whatever rules it wants above and beyond what FAA already has.


No gray area at all.


The question becomes whether the FAA *must* develop rules for commercial
manned flights in oder for SpaceX to be able to launch Dragon2 which
*also* must conform to NASA specs.


Nope.


And in a void, FAA is more likely to just adopt NASA's "man rated" rules
rather than develop its own.


Nope.


And again, it all depends on whether NASA is buying airplane tickets to
the iSS from SpaceX Airlines, or whether NASA is chartering the plane
(Falcon9 + Dragon) and will fly it as a government mission. If the
pilots are NASA employees, it would point to it being a government
flight, at which point FAA may not kick in.


Yep.


If SpaceX has a vehicle with 7 seats, and uses 1 seat for its own pilot
to drive 6 passengers to ISS, then it is a clear case of a commercial
flight operated by SpaceX and no different from NASA buying
Orlando-Houston tickets for its employees on Delta Airlines.


Nope.


How the contract is structured matters in this case. And I don't know
how it is structured.


Well, you know, before you go darting off on tangents it would be
userful if you knew what was going on.


I suspect it will look a lot like aircraft certification, given that
FAA tends to be pretty conservative about such things. If they take a
long time to figure it out, FAA could be a significant barrier to
commercial business (see the case of certification of the Raytheon
Starship business aircraft, for example).

Aircraft certification evolved over decades or trial and error. (The
A320 example I provided being just one of them, but that trial and error
goes back to square windows on the comet becoming a "no no" for
pressurized aircraft after it was found to cause structural failures at
the corner.


Please show where square windows are a 'no no' for aircraft
certification.


You can't expect FAA to develop comprehensive commecial spaceflight
rules overnight. NASA is the one with the experience in the matter
having suffered failures in its history. (early rockets, Apollo 1,
Apollo 13, Challenger, Columbia).


NASA has no experience in developing commercial spaceflight rules.
NASA has some minor experience (which seems to be applicable only when
they want it to) in developing EXPERIMENTAL VEHICLE rules.


So if FAA is tasked to implement commercial manned spaceflight
regulations, it is more likely to take the NASA rules and hopefully
remove onerous ones after stakeholders such as SpaceX have shown they
are not required.


No, it isn't.


Considering BFS is being designed right now, shouldn't SpaceX get some
sort of clarity of what rules will be applied to its ship?


Not an issue until they start selling tickets.


it is an issue for engineers designing the rocket RIGHT NOW. They need
to know what rules they must obey.


Nope. You really don't know **** about aircraft certification,
either, do you?


How many 'lifeboats' does the typical airliner carry?

One at each door. And lifejackets under each seat. And while succesful
ditching in water are rare, the requirement is there. (the lifeboats
also happen to be the slides to allow emergency evacualtion of aircraft
standing on its landing gear).


No. There are no 'life boats' on commercial aircraft. If things go
to **** in flight, you ride it down and pray a lot.


You need to think about it from a political level. If BFR/BFS launches
with 100 passengers and they all die when it can be shown they could
have survived, fingers will be pointed at the FAA's failure to create
proper regulations for manned spaceflight.


And if unicorns start ****ting magic pixie dust fingers will be
pointed...


And there will be tough questions for the FAA in term of risks. If a
window breaks while in orbit, the pilot just can't drop down to 10,000
feet in a couple of minutes so people don't die. Do you mandate everyone
wear a space suit to survive such an event? section off the habitable
space so only a portion of passengers die in such an event? or just
mandate the windows be extra strong? Or just accept the risk?


Suppose everyone farts at the same time and the vehicle explodes...


Note that I THINK a similar debate was had for the Concorde due to how
high it flew.


You think wrong.

Just a bit more on this idea. NASA doesn't have its rules apply to
Russian spacecraft which are not only docking to NASA property (sort
of), but are carrying NASA astronauts.

Fair point. But then again, the NASA employees are passengers and a
russian is in charge of driving the Soyuz and it is controlled by
Russian ground personnel. And NASA did try to impoose as much as it
could in terms of safety rules, with the Russians succesfully pushing
back. Same for ISS in early days when americans relied on Russia for
life and transport and found Russia to be playing very loose which was
incompatible with NASA "everything must be scripted and tested 200
times" approach. But NASA had no choice but to grin and bear it because
they had no choice but to ride with the russians and live in russian
segment.

Bill Shepherd wore a roll of duct tape with him at all times to fix
things in Zarya/Zvezda.


Cite?


The difference with Dragon/Starliner is that NASA has time and isn't
desperate for a ride and can impose regulations if it wants it. The fact
that NASA got SpaceX to drop land landings for Dragon is one such
examnple of the power NASA exerts.


How is that relevant to anything?



As for things like Range Safety, commercial aircraft are required
during operation to obey all sorts of rules. None of those rules are
part of type certification.

If you look at ETOPS, FAA regulation cover not only the aircraft type
certification, but also airline maintenance rules, as well as in flight
rules (ETOPS flights routes, as well as rules that apply in case of
engine failure).


Once again, it becomes obvious that you don't know jack **** about
aircraft certification, either.


--
"Ignorance is preferable to error, and he is less remote from the
truth who believes nothing than he who believes what is wrong."
-- Thomas Jefferson