NASA Aerospace Safety Advisory Panel's annual report + some commentary

January 10 2013 06:51:20 AM | by Clark Lindsey, Managing Editor

NASA's Aerospace Safety Advisory Panel has released its 2012 Annual Report (pdf). Much of it deals with the Commercial Crew Program and the issue of certification of the commercial launch systems.

From the cover letter:

In carrying out our responsibilities, the ASAP hears both sides of the story. The NASA program team highlights inability to execute the program of record and grapples with the necessity to modify acquisition strategy to adjust for the funding shortfalls. The Congress notes the lack of credible cost estimate, the absence of an integrated schedule, and “program instability.” In the Panel’s opinion, a consensus between the Congress and NASA will be required to resolve this conundrum.
In FY13, we predict this planning-funding disconnect will again drive a change to acquisition strategy, schedule, and/or safety risk. The ASAP is concerned that some will champion an approach that is a current option contained in the Commercial Crew Integrated Capability (CCiCap) agreement. There is risk this optional, orbital flight-test demonstration with a non-NASA crew could yield two standards of safety—one reflecting NASA requirements, and one with a higher risk set of commercial requirements. It also raises questions of who acts as certification authority and what differentiates public from private accountability. Separating the level of safety demanded in the system from the unique and hard-earned knowledge that NASA possesses introduces new risks and unique challenges to the normal precepts of public safety and mission responsibility. We are concerned that NASA’s CCiCap 2014 “Option” prematurely signals tacit acceptance of this commercial requirements approach absent serious consideration by all the stakeholders on whether this higher level of risk is in fact in concert with national objectives.

As always with the ASAP, there are odd disconnects from the real world of rockets and spaceflight. For example, NASA astronauts fly regularly on the Russian Soyuz despite the fact that the Soyuz system was never certified in any way by the agency and its level of safety was separated by several thousand miles from the "unique and hard-earned knowledge that NASA possesses".

It's also arguable as to whether NASA as an institution possesses such knowledge or whether it is held by the agency's employees, many of whom resign or retire each year, including the few remaining ones who worked on development of a launch vehicle that made it to space. There is no explanation made by ASAP as to why companies that are successfully designing, building and flying rockets and spacecraft do not possess equally unique and hard-earned knowledge.

By the time a crew sits atop a Falcon 9 booster, SpaceX will have flown F9 rockets perhaps two dozen times. Atlas V rockets will have flown several dozen times before they carry Boeing and SNC crew vehicles.

On the other hand, ASAP was willing to accept astronauts riding on an Ares I after just one test flight based on nothing but the fact that all the standard human rating procedures were to be followed (though probably with more than a few waivers as with the Shuttle). ASAP probably will give a similar pass to NASA's plan to fly crews on the SLS/Orion after just one test flight. Flight testing is an integral part of aircraft certification yet ASAP treats certification of launch systems as though it is independent of flight and depends solely on the number of reviews and studies and the height of the stack of paperwork.

ASAP expresses concern about the initial testing of the vehicles with the CCP firms' own crews. Under the current commercial space transportation regulatory regime, a company can build a rocket system and fly people to orbit under a FAA license. The company need never have any interaction with NASA whatsoever. Whether that necessarily means it is a less safe transport than one "certified" by NASA is a matter of debate but it is nevertheless quite legal. Simply because a company in CCP accepts NASA funding and technical input and oversight does not mean it gives up the right to fly its own crews. The commercial crews, which no doubt will include former NASA astronauts, are allowed to accept the risks. (The issue of "public safety" enters with the FAA license requirement that there be extremely low risk to third parties during launch and return.)

The issue for ASAP should be whether those test flights will provide the data needed to tell whether the systems are sufficiently safe for NASA crews. (ASAP might also try to define exactly what level of safety they consider sufficient.) However, as noted above, flight data seems not to weigh heavily with the panel.

If ASAP has ts way, a possible scenario would see CCP firm(s) enter the certification phase and spend years there struggling to be approved to fly NASA crews. And in the meantime, the firms will be flying crews and passengers routinely to orbit to a Bigelow station and for other LEO activities. The absurdity of such a scenario would be a logical consequence of the convoluted and contradictory views on astronaut safety held by ASAP as well as by NASA, Congress and the public.

Update: Rand Simberg, who is working on a book on the space safety issue, finds some positive aspects to the report:

Comments (9)

Rand Simberg
10th January 2013 1:05pm
Charles Lurio
It sounds to me like the ASAP wants the default approach to be the NASA-traditional, government rules approach for everybody. - No flights to those Bigelow stations, because they won't be up there, because all will have to follow NASA rules, private or public, for human transport to orbit. Yes, Clark, I hear what I've been concerned about for years once again - that NASA the all-knowing will become the "certifier" of all craft for all orbital uses, to heck with the FAA. Suborbital was never Read More
10th January 2013 10:57am
yg1968
ASAP also advocates that the phase 2 certification contracts be cost plus. They think cost plus is safer... Commercial crew detractors are no longer opponents, they now say that they have "concerns" and the best way to fix these concerns is by ensuring that commercial crew is not commercial (i.e. it needs more oversight from NASA).
10th January 2013 9:30am
Rick Boozer
Well said Clark. But there is another aspect of this matter that occurs to me and it's kind of scary. Do you think that ASAP is fanagling to try to get Congress to come up with a law giving ASAP control of safety standards for BOTH NASA and private commercial flights?
10th January 2013 4:54am
Bennett In Vermont
I echo Rick's concern, and his praise of your analysis.
10th January 2013 6:41am
Clark S. Lindsey
ASAP itself is just an advisory group so they don't control safety standards. Not sure if NASA is even required to respond to ASAP recommendations specifically in an official manner. However, I do hear an implicit suggestion in the report that there should not be separate NASA and FAA rules on commercial spaceflight. It would be a mess if "certification" by NASA was required of any commercial orbital system even if they are not flying NASA personnel. If there is an early accident, I could see Read More
10th January 2013 8:32am
DougSpace
Clark, Is there a way by which a company could keep out of court by getting sufficient consent from its astronauts re: the risk they are taking and perhaps by choosing its astronauts carefully?
10th January 2013 11:00am
Clark S. Lindsey
Informed consent is currently the primary requirement for "spaceflight participants" on commercial space transports. When they sign the consent forms, they are accepting that they are not mere passengers but are engaging in a risky activity just like parachuting or hang-gliding. With the crazy civil liability system in the US, however, consent forms can often be surmounted by clever lawyers. That's why it has been important to get spaceport states to pass additional liability limitation Read More
10th January 2013 11:41am
Tom Billings
Given the current legal climate, it is almost certain that an accident will result in legal fees for both vehicle and operating companies. A more useful question would be how much signed agreements can mitigate these costs. Unfortunately, until we actually run such cases through the courts, that is likely to be a subjective judgement.
10th January 2013 12:07pm

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