Joint Letter Sent To Newly-Minted FAA Administrator Stephen Dickson

A group of aviation stakeholders has sent a letter to newly-confirmed FAA Administrator Stephen Dickson concerning the FAA's NPRM covering commercial space licensing.

The group, which includes ALPA, AOPA, A4A, ACI, AAAE, CAA, NATCA and RAA says  there are several areas that they collectively want to bring to Dickson's attention.

"We strongly urge the FAA to develop a performance-based final rule that incorporates airspace efficiency into the licensing process and considers the effects on all NAS users. The FAA estimates that commercial space operations may nearly double by 2023; therefore, it is crucial that the FAA preserve the aviation industry’s $1.6 trillion annual U.S. economic activity, which accounts for 5.1% of the U.S. GDP. Although the document has not yet been finalized, the FAA should consider incorporating the upcoming recommendations of the Airspace Access Priorities Aviation Rulemaking Committee into this licensing overhaul," the letter states.

"The FAA should ensure that the safety requirements for commercial space certification and operations, particularly those addressing the risks to other aviation users, are commensurate with the expectations of the flying public. Ensuring safety is vital for a growing commercial space industry and is the path for true integration into the NAS. The commercial space industry should leverage the experiences from the aviation industry to attain record levels of safety through collaboration and information sharing. Programs modeled after the Aviation Safety Information Analysis and Sharing Program (ASIAS) are the means for advancing commercial space safety.

"There are several associated initiatives that do not need to wait for the completion of the rulemaking process. This includes the formalization of time-based launch procedures under development by the Joint Space Operations Group (JSpOG) located at the Air Traffic Control System Command Center. We also encourage the FAA to move forward with programs to ensure safe commercial space integration including: improvement of existing procedures; the development of new procedures to improve launch planning; the creation of ATC surveillance and tracking capabilities to include automated depictions of hazard areas and launch vehicles; improved and uniform hazard mitigation policies; and two-way communications. These tools will help the FAA achieve the sought-after integration of commercial space.

"Likewise, it is important for the commercial space industry to become a participant in the Collaborative DecisionMaking Process as a step toward normalizing these operations. We also believe that the implementation of Space-based ADS-B provides enhanced surveillance capabilities that will augment the FAA’s ability to more efficiently manage traffic in addressing increasing commercial space activity."

The associations said each would be submitting comments to the NPRM individually along with expressing their concerns in the letter.

(Images from file)

FMI: Letter text