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Section 415.37(a), which was originally proposed as section 415.37(c), implements the FAA's current flight readiness guidelines. As noted in the NPRM, the requirements arise out of recommendations from a National Transportation Safety Board (NTSB) investigation of an anomaly that occurred during a commercial launch from a federal launch range. Requirements intended to ensure the readiness of a launch team include designation of an individual responsible for flight readiness, launch readiness reviews, rules and abort procedures and, countdown checklists, dress rehearsals procedures, and procedures for crew rest.
The FAA recognizes that there are many reviews conducted of a launch system from its initial design up to flight. However, in section 415.37(a)(1), the FAA places special emphasis on a flight readiness review, or its equivalent. A review is typically conducted not more than one or two days prior to scheduled flight. In most cases a flight readiness review is standard practice at federal launch ranges, but the FAA considers the review, and the topics required in this section, to be so important that the applicant must, in its application, commit to a meeting and identify the topics to be addressed. This review must ensure that all system and personnel readiness problems are identified and are associated with a plan to resolve them, that all systems needed for flight have been checked out and are ready, and that each participant is cognizant of his or her role on the day of flight. If this review reveals unresolved issues, the licensee will be able to assess its ability to resolve those issues before the intended launch time or to delay the flight, as appropriate.
Section 415.37(a)(2) requires an applicant to possess procedures that ensure mission constraints, rules and abort procedures are contained in a single document approved by licensee flight safety and federal launch range personnel.
Section 415.37(a)(3) requires an applicant to employ procedures that ensure that all launch countdown checklists are current and consistent. Past inconsistencies in critical countdown checklists and procedures have raised serious safety concerns. The FAA recognizes that it may be impractical for all launch participants to have identical checklists due to differences in the roles of launch participants. The applicant should, however, have some process, such as a master countdown manual, to ensure the currency and consistency of all participants' checklists during countdown to flight. This will ensure that confusion and uncertainties on launch day are minimized, that flight safety critical procedures are completed successfully, and that those individuals with launch decision authority know what is going on and are able to make sound decisions.
Section 415.37(a)(4) requires an applicant to have procedures for the conduct of dress rehearsals. As demonstrated in the past, poor performance at a dress rehearsal may indicate a lack of readiness of individuals or systems responsible for safety. An applicant's procedures should include criteria for determining when dress rehearsals are not necessary. A number of launch companies, for example, have been conducting routine launches of the same vehicle for many years. The FAA recognizes that although dress rehearsals may not be necessary in every case, they may be critical to those launch companies that are new to a launch site, to those that have significant changes in personnel, or to those launching a new launch vehicle.
Even those launch operators that routinely conduct launches typically have certain criteria and procedures in place to verify that a launch team is ready for launch, especially if a considerable period of time has elapsed since the last launch took place. In this regard, Space Access recommends that the FAA impose a currency requirement of 45 days. Space Access at 11. The FAA will take the recommendation into account in future rulemakings, but for the time being declines to impose a currency requirement of 45 days. The need for dress rehearsals is driven by issues specific to particular vehicles, including the number of personnel required to launch the vehicle, the complexity of their tasks, and the amount of communication required among team members to launch safely.
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Commercial Space Transportation Licensing Regulations(34)
