Says NPRM Lacks Adequate Clarity, Supporting Guidance Documents

The Commercial Spaceflight Federation has filed comments and recommendations to the FAA’s Notice of Proposed Rulemaking for streamlined launch and re-entry licensing requirements. And while the CSF appreciates the FAA's efforts to modernize its regulations, it sees potential issues with the NPRM as it is currently written.

While we appreciate the significant effort that has gone into producing the initial draft, our comments detail serious concerns with the proposed rule. In order to ensure that new regulations do not inhibit innovation, potentially result in less safe systems, and keep pace with the U.S. commercial space industry’s operations, the FAA has more work to do,” said CSF president Eric Stallmer. “We look forward to working with the FAA to refine and improve the rule.”  

According to the CSF, as currently written, the NPRM lacks adequate clarity, supporting guidance documents, and the cost analysis and justification of the new prescriptive requirements it proposes. Space Policy Directive 2 is clear: FAA should modernize launch and re-entry regulations to replace outdated, prescriptive requirements with performance-based regulations in order to promote economic growth, protect public safety, and encourage American leadership in space commerce. Without significant change, the final rule will fail to meet these objectives.

While CSF appreciates FAA’s effort to move forward expeditiously, getting the substance of the nation’s future regulatory environment is more important than speed. To properly comment on the substance of the regulations, all missing guidance documents, justification, cost analysis and clarity must be available.

“Given well-documented deficiencies in available information related to the proposed rule, CSF strongly recommends that the FAA issue a revised Supplemental NPRM, publish the missing Advisory Circulars, and engage in a productive dialogue with stakeholders,” Stallmer said.  

(Source: CSF news release. Image from file)

FMI: CSF comments
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