When the gates are all down, and the lights are all flashing, and the whistle is screaming in vain,
You can’t blame the wreck on the train, no, you can’t blame the wreck on the train
The 1987 hit written by Terri Sharp and performed by Don McLean is a plea to a friend in a bad relationship who just doesn’t see what is about to happen.
Commercial Human Spaceflight is poised to enter a bad relationship and I wonder why everyone is so blind they cannot see what is about to happen.
And I’m not talking about the Debt Commission or the new Republican House majority, either.
This has to do with NASA and the way the agency works, really works, away from NASA HQ, out in the field centers, with the rank and file engineer.
For almost fifty years, NASA has been contracting with large aerospace firms to build human spacecraft and their launch vehicles. For that entire time, NASA has been firmly in charge and the contractors, with their cost-plus contracts, have found it lucrative to play the game. From time to time there has been an accident, incident, close call, or anomaly. As with all good government bureaucracies, NASA believes that improved processes (read: increased bureaucracy) is the answer to preventing future problems. So NASA writes longer and longer specifications and requirements, and demands more and more documentation and proof. Somewhere along the line, we have crossed over the optimum point to ensure safety and just added cost and delay.
Now we have a move to acquire transportation to low earth orbit from commercial firms. Not only may this initiative save the taxpayers money, but a new industry may be established. The promoters of this idea liken it to the government contracts for air mail service in the 1920’s which mythically enabled a successful and profitable airline industry. We shall see if this is an appropriate analogy or not, but in the meantime, a huge cultural divide is poised to kill the initiative in its infancy. Not intentionally, not with malice, no no, but with the best of intentions.
When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites. NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users. This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.
Now NASA has released a draft (dated Oct. 8, 2010) of its requirements CCT-REQ-1130 ISS Crew Transportation and Services Requirements. I’d like for you to read it but it is behind NASA’s IT firewall and you must have an ID and password to access it. I have read it and I’m disappointed. The document runs a mind-numbing 260 pages of densely spaced requirements. Most disappointing, on pages 7 to 11 is a table of 74 additional requirements documents which must be followed, in whole or in part. Taken all together, there are thousands of requirement statements referenced in this document. And for every one NASA will require a potential commercial space flight provider to document, prove, and verify with massive amounts of paperwork and/or electronic forms. This, folks is the old way of doing business. This is one of the major reasons why spaceflight is as costly as it is.
NASA at its highest leadership level has committed to try to allow commercial space flight providers a great deal of flexibility and cost control. There are ways to do this which will not compromise safety in design or operation. But having NASA civil servants as the arbiters of whether or not thousands of requirements have been satisfied is not the way to accomplish neither safety nor cost efficiency.
So whether Commercial Space Flight gets $6 billion or $3 billion or $50 million, the entire effort is on the way to a train wreck.
NASA must change or this effort will fail. I am reminded that the US Military’s requirements for its first airplane ran 2 and ½ pages; and the requirements for the NASA’s Gemini capsule ran about two dozen pages. Simple, straightforward requirements and the flexibility to use good industry based standards could allow commercial space flight to be as successful as those programs or the NASA Launch Services program. But we are not on that path.
Folks, the gates are down, the lights are flashing, the whistle is blowing – don’t be surprised if the signals are ignored that there will be a wreck.
Wayne Hale's Blog 
The trouble is that we’ve all had experiences in which a contractor refuses to do what appears to be the right thing because there is no official requirement for it. That drives the mindset of assuming that the contract will do everything wrong unless you force them to do the right thing by specifying it in the contract. And so, because spaceflight is very complicated, the requirements set becomes huge.
I don’t know what the fix is but here’s a suggestion: Put together an industry-wide working group and come up with something better. Let NASA act as a reviewer and submitter of non-binding comments. Maybe NASA will buy into the result. This would be vaguely similar in which the way the FAA allows certification of light sport aircraft via adherence to an industry consensus standard (see FAR 21.190).
So, what can be done to fix it? I mean that realistically.
An edict from on high that says “Thou shalt not levy too many requirements” is, itself, another requirement, and hardly a verifiable one.
A cultural change within NASA itself could do it, but there is absolutely no impetus for that change – these civil servants have been doing their jobs for decades and will probably continue for decades more. It’s exceedingly difficult to change a culture with a workforce like that.
The other thing I wonder is, how many of these requirements have to do with ISS specifically (electrical/mechanical connections, docking requirements, etc.) and which have to do with actual spaceflight safety.
It’s worth pointing out that NASA isn’t the only customer of commercial launch services, and the ISS won’t always be the only destination. Private companies like Bigelow Aerospace will need flights for their own purposes and will almost certainly not bear the requirements burden that NASA imposes. Plus, the plethora of commercial suborbital vehicles coming online soon will also have clienteles well beyond NASA. I think the industry will get its legs in time to avoid a train wreck, if it can avoid the mistake of over-regulation while in its infancy.
Suborbital flight is an entirely different subject. As you might note, NASA is not proposing that those providers meet NASA standards. It is in the baliwick of the FAA
I have a some questions:
1) I recall seeing a document (but can’t find ATM) that mentioned vehicles with more than 14 successful flights in a row to be considered human rated. Is there no consideration for demonstrated reliability?
2) The existing EELV fleet launches nuclear payloads from time to time. How do the risks and requirements of “Nuclear rating” compare to “Human rating”?
Perhaps Boeing/SpaceX should focus on commercial crew for Bigelow and allow NASA to find its own way.
(1) I know of no such document. The NLS documents do make a different oversight standard for companies/vehicles with many successful missions on the books vs those who are new, but that is for expendible non-human rated missions.
(2) Not even close. No life support, no crew controls, no reentry vehicle, not even close.
(3)If they had the money they would already have done so. Everybody needs Uncle Sam’s contribution to make their spacecraft fly.
I found that it was in the House authorization bill.
Can you cite the paragraph? I guess you mean the version that got dropped rather than the joint Senate-House version that finally passed.
yes, I believe those statements were in the bill that was dropped.
Regarding the human-rating (#2), I was not referring to spacecraft, but to launch vehicles (EELV). I presumed, according to statements made by various NASA folks that it might be possible for Orion to fly on one if there was no NASA vehicle available.
I talked about the same thing during my interview on The Space Show recently(http://www.rv-103.com/?p=1027). SpaceX and other commercial companies have no idea what type of regulations and oversight they will experience as they get into bed with NASA. All these companies can see is the millions of taxpayer dollars for the taking. As a former Space Shuttle worker, I have seen first hand how much time is devoted to paperwork and dealing with the NASA bureaucracy. Elon Musk used to complain about Air Force paperwork required to launch from CCAFS. That’s small potatoes compared to what he will have to endure under NASA’s thumb.
You said it even better than I have
Wayne
As a service to the community, you should post the Gemini SpaceCraft Requirements.
I have them in hard copy but not electronically. If I get a scanner and some time I may do that.
I’d gladly type it up for you if you sent me a hardcopy – photocopy or spare original. I will also gladly promise to send an original back.
I think one problem could be that the draft is meant as a one size fits all. Maybe that’s the only way it could be written. But it’s one thing to ask Boeing, LockMart or Orbital to use best industry practices in an otherwise general requirements document; all are very knowledgable of those practices because of their decades of experience in the space launch business. Others are not.
Perhaps the key is to have a stepped requirements system based on a launch company’s record, as scored by the AirForce and NASA?
What are your thoughts Wayne?
Could work, but that is not the approach that is being taken.
I would have to second Brandon. How does the US change NASA’s culture so that the overall requirements for commercial human spaceflight are not so burdensome? We can see the problem, but can we see the solution?
For example, should human spaceflight requirements be based on the FAA model for regulation? FAA does have regulatory oversight of spaceflight. Since I am not privy to the NASA site, are a lot of the requirements listed in NASA document technical?
The FAA model for regulation would be better than what is being proposed. The FAA is following NASA’s lead in this area and has not proposed their own standards. You could say all the requirements are technical.
Part of NASA has been through this difficult culture change: the NASA Launch Services program. That model could work — if NASA has a leader who is willing to invest the energy and pain that it takes to change the culture. That remains to be seen, but I have yet to see a knight arriving on a white horse from NASA HQ.
Thanks Wayne. This is disappointing, but the first step in seeking changes is to draw attention to the problem. Best wishes, – Edwin
So what happens if these requirements are not met? Does this mean that NASA astronauts will not be allowed to ride on the commercial spacecraft?
What happens if NOBODY decides to follow all of these requirements? Will NASA astronauts then be restricted to only NASA designed /contracted/ built spacecraft?
Not to sound crass, but maybe NASA astronauts will be left out in the cold. If it’s not worth it for commercial companies to support manned NASA spaceflight, maybe they will have to start concentrating on non-NASA spaceflight. Bigelow et al will eventually need these services.
Unfortunately, I’m not well-connected enough to know whether the commercial companies need the NASA teat to close their business cases. If that’s the case, then the train-wreck is inevitable. The companies will go out of business, or forgo manned spaceflight, leaving only the bloated Orion capsules for actual transport.
Not to fear. Human spcaflight will continue. We’ll just have to watch on the sidelines as yet another industry gains a toe-hold in China / Russia / add your favorite non-US country.
Currently the potential space flight providers need NASA money to develop their spacecraft. They either play by NASA’s rules or they get no money. I am not at all sure that human spaceflight will continue. It is not guaranteed as much as I wish it were. No venture capitalist in his right mind would put up enough money for such a high risk and low return on investment. But then what do I know?
Maybe you can further educate us, Wayne. It seems that there are some fairly clear lines of personal accountability here. Someone at HQ wearing the badge of “Deputy Administrator” is visibly and proudly carrying the banner for NASA’s advocacy of commercial spaceflight. And someone at JSC wearing the badge of “Manager – Commercial Crew & Cargo Program” is undoubtedly screening and approving documents such as CCT-REQ-1130 prior to release. To the layman, this would appear to be a problem that can be resolved with a simple phone call. Yet darker forces are clearly at play here. So what keeps HQ from informing C3PO that they’ve got the wrong answer?
There is a huge disconnect between the policy makers and the technical workers. Somebody needs to bridge that gap. It may be that one of the main reasons I left NASA is that I could not persuade NASA leadership that there was a gap to be bridged.
Yes sir, again “nail on the head” here.
It is not in the interests of any for policy and implementation of policy to be anything but at odds. It is a maddening state of affairs, and for anyone who just wants to make things work, ultimately frustrating to understand that isn’t desired here.
If you cross over to the “political dark side”, it doesn’t change – they (all sides) neither want or feel it can work – they don’t want to waste sweat on it either. You just become a consultant to the administration/congressional staffer/K street cog until you burn out. Clearly inside govt or the agency or in commercial doesn’t have the need or desire to have this be different.
My assertion is that we need to have policy form as a group activity in the open, where it can be thrashed by all but be moderated by only the most qualified in a rather brutal way. This gives policy makers the critical information to set the necessary limits on things, keeps HQ/mid level management from overreach, and allows implementation of policy to appropriately “push back” up the hierarchy rational limits on policy choices that aren’t being heard. Not easy to do.
But this has its downsides too.
I have been wondering for some time. What if United Space Alliance were to buy the 3 shuttles. Could they safely continue to fly them for a few more years using civilian crews for considerably less money than NASA uses? I seems to me that the purchase price could include the use of NASA
This is nonsense. United Space Alliance would need about $3 billion to operate the shuttle fleet for 6 flights a year. You do the math. Its not feasible.
Back when North American/Rockwell International still existed as a company and the production lines were still in place, there was more than one effort by some people to buy a space shuttle orbiter and presumably even access to the whole supply chain to make a complete shuttle. They were simply told “No”. It wasn’t a matter of money, but politics and NASA didn’t want these guys butting in.
I don’t know what life would have been like with private commercial shuttles, and in the long run I don’t think it would have worked out very well either, although had there been an additional 2-3 shuttle orbiters with an extra half dozen or more flights per year paid for by private industry, they might have been able to take advantage the standing army and amortized the costs a bit better to justify the costs involved.
The largest problem with the Shuttle program is that it is simply too complex and the design parameters were made as a compromise that simply doesn’t really work out in the end. The complexity is one where some compromises were made early on where money could have been spent earlier in the development cycle as a higher initial cost, but instead were kicked down the road as more expensive recurring costs. This complexity also limits the number of potential flights per year for the Shuttle on an absolute basis, even if the crew at KSC is going flat out trying to launch as many shuttle missions as is possible and the budget sufficient to send as many missions as possible into space.
The cost of the astronauts themselves is so insignificant that the cost is statistical noise. It is the standing army of workers at KSC and elsewhere to keep the system running regardless of how many flights happen which is the problem for the Shuttle.
Besides, the Shuttle program is over, and at this point it would be so expensive to restart that I can’t even imagine the costs involved.
Who owns the launch pads? How about the test stands at Stennis to green run the pumps every time. It is incredibly neive to think that all you have to do is buy some orbiters and go fly them. The “marching army” is there because that is what it takes to fly an orbiter.
Perhaps the origin of this behavior was with George Mueller’s arrival and the notion that the abundance of process was a safeguard, and absence of process was simply disaster waiting to happen. An attempt to “front load” a then “too small” organization so as to catch-up / “get ahead” of itself. Never addressed the case of how to throttle this back when it got onerous.
Couple this with an active fear that attempting to make more of the decision making process “in the open” or “transparent” and you get a pernicious situation, because the longstanding practice is unchallengeable. And this is why it continues – one can’t have one without the other.
Frequently at NASA people are aggravated with said practice. Yet they continually “enable” the practice with the way they selectively interact with it.
When diagnosed this, it isn’t greeted well this co-dependence. But this is also an explanation of why it never changes. It can be changed. But there is a obvious price.
In case anyone really cares to change it.
But this is not always the case, and you cannot handle multiple providers differently.
Unfortunately, this isn’t the 20s or even the 60s. Companies now are not necessarily guided by the right thing to do, they’re governed by one thing only: money. NASA has fifty years of manned spaceflight experience, they have none. NASA tells them that their design is deficient, and they say, “that’s nice, thanks for your opinion, but it meets the requirements so we’re not changing it.” To get them to do the right thing, so their crews and assets are not put into danger, NASA adds more requirements. And so it goes.
These things can’t be handled with a handshake anymore.
There were plenty of scandals in the 1920’s if I read my history properly. Don’t think that things were perfect; certainly few deals were done on a handshake even then.
I think one of Wayne’s points is that while this extensive bureaucracy has worked in the past, we need to make a more sustainable choice now. If I’m SpaceX, any significant launch failure immediately jeopardizes the company, so the money’s on building and operating a safe launch vehicle as cheaply as possible.
NASA (or Bigelow) needs to be clear on all interfacing requirements for missions to ISS or any others where there’s shared responsibility, but any additional requirements should be founded on NASA’s experience–not to force new developments through Apollo-sized holes, but to leverage NASA’s experience.
I think the problem is that NASA doesn’t know what requirements and procedures lead to success, and is instead trying to force large sections of shuttle procedure on new vehicles. The solution must be flexibility in specifications and clear communication between NASA and launch providers; NASA needs to learn what core requirements successful space vehicles have while realizing that those requirements were learned from operating one vehicle. Those developing new vehicles need to understand the purpose of the requirement and determine how that impacts their design decisions.
You nailed it on the head, Wayne. Having worked in both the “mainstream” and “low-cost” industries, it can be extremely difficult to make the two work together. You need people who see both sides of the issue and can try to find an intelligent way forward. In my view this is a cultural and human problem as much as a technical and managerial one.
The only thing one could do, in answer to comments, would be to prepare a set of requirements, trying both to implement a low-cost approach and address the major concerns of the bureaucratic machine (PA, rad levels, software PA, margins) and then get both the “commercial” suppliers and good-will people inside NASA to push for it…
Good luck…
A.
Yes, the success of the COTS procurement was primarily driven by the fact that it was a sideline to the real show that didn’t really matter. The requirements was basically: here’s some milestones, for each one you hit we’ll give you some money, miss them and we’ll talk about dropping you for someone else. In that regard it was a winner but, the minute it became center stage, that is no longer acceptable.
And the COTS providers weren’t carrying people; just underwear and water. So if they fail, it doesn’t kill anybody. Commercial Human Spaceflight, on the other hand, has a more interesting set of potential outcomes.
Well, the COTS contracts did include the COTS-D option.. and if Constellation had continued as the center stage then those options may well have been funded and.. but we’ll never know.
Wayne, I’m sure you remember well that Progress M-34 was only carrying underwear and water too.
guess I am missing the point
Wayne, you’re not the only one.. but my guess is Sean is trying to whimsically suggest that ISS proximity operations are pretty dangerous even if you’re only carrying cargo, so it’s good the COTS contractors have complied with all the published requirements. Perhaps carrying crews could also be accurately and publicly documented in much the same way?
and Sean, there’s no need to shroud your comments in whimsy.
Progress M-34 is the one that hit Mir and depressurised the Spektr module. Cargo ships need some amount of human rating even if they’re not carrying actual people because they interact with human space vehicles.
The problem here, if I’m understanding Wayne correctly, is one of political will and beaurocratic inertia rather than engineering. It may well be that the cargo flight requirements are a good fraction of all that’s really needed to cover flying NASA astronauts to the ISS but if we can’t convince NASA of that, so what?
Progress M-34 that hit the Mir was empty except for trash as I recall. It was an off nominal manual docking exercise where the crewman on the Mir did not have enough information to prevent a collision because TsUP had turned off the critical info to make it harder for him. It was a stupid accident that was unnecessary. Caused by the people who should have been in charge of preventing such accidents.
Are “good industry based standards” available and useful in a new industry? I worry that the potential providers with experience gained under the old model would not want to share their information with new competitors.
It’s true that “real engineering work and hardware production” take money, but do you think that NASA could have been successful with some of the grand goals of VSE operating under the same budget if it could have broken out of the monster requirements documents model?
Absolutely good industry based standards are available. Part of the problem is that there are too many good standards out there and professionals argue about which standard can dance best on the head of a pin. Successful companies pick a good standard. The problem comes when NASA imposes a different standard and you have to scrap all the parts you have made to date because they don’t meet the imposed standard. And you have to document the living daylights out of every step.
Generally, I think the companies that will be competing to provide commercial crew services will be fully motivated to ensure the safety of their vehicles without a thousand pages of requirements documents. They have everything to lose by not building a safe vehicle, and nothing to gain. NASA engineers should take the attitude that their role is knowledge transfer, not oversight. But if you are concerned that these companies might decide to take some shortcuts, how about requiring that a senior company executive be aboard each of the first five flights? 🙂
I have to throw the B. S. flag on this comment.
Did BP have everything to lose and nothing to gain by doing a poor cement job at Macondo? Did the mortgage industry know that it was bad practice to give home loans to people who clearly did not have the resources to afford to pay them back?
There will be schedule pressure and financial pressure. You have to build a corporate culture that stresses safety, but doesn’t go overboard.
Senior executive ride onboard? Now there is a good idea!
In rebuttal, I’d point out that BP was considered one of the worst in the oil industry for safety record, and deliberately isolated themselves from liability through a number of processes that included multiple layers of contractors to isolate themselves from the issues involved. It was a disaster waiting to happen almost by design. Ditto for the mortgage lending industry where the rules were set up for political reasons because people getting homes == votes for office.
The advantage of private industry existing is that when a company ignores the safety of its employees and the general public in the vicinity of where they working, they get weeded out of the market place and those companies are forced into bankruptcy. The problem with government doing the job is that it is a bit harder to switch to another government if the one you are working with isn’t working out so well.
So the question is do you want to work with companies who are concerned about the bottom line as their primary focus, or do you want to work with government bureaucrats whose only focus is to earn votes for the politicians who put them there. Both have problems and neither really provides a satisfying solution all of the time either. The difference with commercial approaches to spaceflight, however, it that it hasn’t really be tried too much so anybody involved is by definition doing something new.
Airlines have been safely transporting passengers on incredibly complex machines by the thousands, and many of them do have outstanding safety records. There are also a few airlines which cut so many corners that the passengers, staff, and the general public suffer too.
Maybe we should ask why are so many requirements created in the first place. Having worked in the Shuttle world, I believe the answer is fear or failure – plain old risk-aversion. A previous post noted that requriements are created as an attempt to protect the mission against both misunderstandings and short-cuts on the part of contractor. Of course there will be misunderstandings if every last detail is not specified, but a good system design with margins, a good test program and some spine for taking risk will deal with this. And of course the contractors will try to save money in some places. Most contracting engineers and managers want the mission to succeed and won’t shave off too much. For the few that will go too far, again, a robust design and test program can buy down almost all of the risk.
The real problem is that NASA, particularly in the human spaceflight arena, is loathe to take any identifiable risk, however small. Each employee who is sitting on console, testing a circuit, or operating the forklift, thinks “please God, don’t let me screw up”. That paranoia is good to have. But it has been too much woven into the cloth of NASA after all these years. Every time something does go wrong, the response of NASA management is not only to understand the failure, but to document it, and, always, turn it into a procedure or new requirement. The culture says that we are not done until there is a paper trail showing the problem wont recur. Perhaps, that sounds responsible, but over time, the weight of the new procedures and requirements builds. More people are needed to manage the paper work. More are needed to verify the work. More review boards are created, who rarely consider cost and almost always levy even more requirements. Eventually this vine of good intentions grows enough that it begins to strangle the tree – the project grows slower than it should and there are schedule slips, cost overruns occur, and, too often, out-right cancellation is the result.
Is there a way out? I only see three options:
1) Let leaner foreign agencies take up the work while NASA continues to wallow.
2) Eliminate NASA outright, start fresh and start small. Only rehire the technical staff with needed skills. Do not bring back the managers or their tools to avoid re-instating the same culture of risk-aversion.
3) The Presisdent needs to stand up with a clear goal (Mars, Moon, or wherever), and tell the American people that astronauts will very probably die. We will go fast, we will do it cheaply, we will take risk. Not every pioneer will return. The American public loves a spectacle. It wants heros again, and will support NASA, even when it does fail spectacularly. The public will also be with there when it succeeds spectacularly.
I really think NASA and their incredibly talented workforce can provide proper oversight to this new activity IF THE LEADERSHIP WILL LEAD THEM.
This is not a failure of the hardworking engineers and safety personnel at NASA, this is a failure of the NASA leadership to Lead, plain and simple.
Yes. What it is, is no clear path of succession of NASA’s prior internal management “CONOPs” to one that applies the accumulated expertise/talent pool to the next stage of challenges. They see nothing but the past so constantly attempt to recreate the past top down … and it doesn’t come off. NASA management doesn’t even see that there is anything else (but the past) there.
What you want to do is to bifurcate (or more) into separate program groups around multiple HSF programs (possibly commercial and govt) and pit them against each other with transparent management common to all of them. Then the experience guides the new HSF programs w/o hobbling them.
There’s a million reasons why this won’t/can’t happen – but it should.
I cringe when I see arguments that keep saying we need to toss the standards and simply accept more risk.
It’s interesting that when talking with existing commercial companies (experienced companies like Loral that do cable TV satellites, not the new starts like SpaceX) I’ve found that they work very hard to “root out risk and drive it out” wherever possible. When mission success (read “profit” here) is the prime criteria, there is no argument about implementing standards. Even SpaceX tests according to MIL-STDs without any arguments.
There seems to be a perception that we can save a lot of money by just throwing these requirements and processes out, but simply deleting them can result in complete failures. Back in the 80s, the Air Force tried the approach of killing government standards and allowing companies to use their best judgment and commercial standards where they thought they should. It was called Acquisition Reform and the intent was save money using a new management paradigm. The effort was an unmitigated disaster. After watching several multi-billion spacecraft end up in useless orbits (or in the ocean), they finally jumped back in and started re-imposing those cumbersome standards in order to start seeing some successes. Many of the cancelled government standards were still used by private companies simply because they were the best standards around.
The Petrobras P36 Oil Rig is another example. Prior to 2001, they proudly announced a new way of doing business for their new oil rig:
“Petrobras has established new global benchmarks for the generation of exceptional shareholder wealth through an aggressive and innovative programme of cost cutting on its P36 production facility. Conventional constraints have been successfully challenged and replaced with new paradigms appropriate to the globalised corporate market place. Through an integrated network of facilitated workshops, the project has successfully rejected the established constricting and negative influences of prescriptive engineering, onerous quality requirements, and outdated concepts of inspection and client control. Elimination of these unnecessary straitjackets has empowered the project’s suppliers and contractors to propose highly economical solutions, with the win-win bonus of enhanced profitability margins for themselves. The P36 platform shows the shape of things to come in the unregulated Global market economy of the 21st Century.””
Sounds great, right?
Except that soon after it was placed on station, there were a couple of explosions that killed 11 people. The rig developed a list and sank 5 days later.
So maybe not so great.
I think there are smarter ways of implementing standards, but simply throwing them out isn’t one of them. Remember that many of those nit-picky requirements were added after something blew up or someone was killed.
Thank-you for your polite response, but I disagree completely.
First, I did not nor would ever say to “throw out all standards”. Everybody would build to a different plan, generally to suit their own interests, and would collide and nothing would be accomplished. SpaceX tests to a MIL standard in many cases, well of course. Are “nip-picky requirements added after something blows up”? Sure, that can and does occur.
My point is that the standards, the requirements,the documents and the reviews in the HSF world have built to an overwhelming weight, although perhaps those of you embedded in the HSF world cannot see this.The weight is carried by thousands of personnel, so the load is shared, but the cost of all those people put otherwise possible missions out of financial reach. There is a balance between the chaos of too few requirements and standard, and the heat-death of too many,
Imagine if the Lewis and Clark expedition had been under the control of NASA. Each boat would have to have been through dozens of reviews. Have the settlers been through their required 40 hours of camp-fire training? Do they have the specified 52.4 lbs per person of medicine aboard, sealed in approved, protective containers, labeled in waterproof black ink? Does the boat cover have sufficient strength to withstand arrows, months of sunlight, rain? Is the stitching count tight enough? Was an acceptable thread used, which is found on the approved list, or do you have a triply-signed waiver? Was the person who did the stitching qualified to do that work? Can you prove with documentation that the stitcher’s trainer had the required 40 hours of Boat Cover Stitch certification training? Was the stitching inspected under UV light and checked for fraying along its entire length, and with an inspector foreman present? Was a similar patch of stitching tested in the Long Term Western Plains Environment facility? Do you have Daguerreotypes of the stitching before, during and after the test in case it fails and we need to go back and reconstruct what failed? Who is the assigned Boat Cover System Engineer? Did the Boat Cover Stitch Test Review Board assign any actions, and were those closed?
I could go on for hundreds of pages, and NASA would. Instead of buying a cover for your boat, slapping it on and going, you would prefer to pay for tens of employees among the reviews, training, management and so on.
If you were employed in this 1800’s NASA world, perhaps each one of the above requirements would seem necessary. After all, if the stitching fails, the cover will fail, and perhaps expose the flour and food to the rain, and thus cost the mission. Remember, there was that case of the P36 oil platform cover that failed due to the stitching, and people died. We HAVE to get the stitching right. We HAVE to document it. We have to HAVE the right thread, and training and inspection.
No.
Lewis and Clarke would never have left the Mid-West. Did some other follow-on expedition have issues because their boat cover was bad? Sure, that might have happened. But in the big picture, these explorers took risks, which sometimes they lost but they succeeded often enough for us to remember, generations later, that they did something bold to push forward.
We are their heirs. We can take chances – yes, take chances with astronauts lives and yes, take chances with taxpayer money. Its better that than trying vainly to shove through a mountain of bureaucracy, and thus wasting grounding astronauts and burning money.
In a few generations,who is going to remember NASA’s trip to Mars, if it doesn’t happen because we were afraid to take on more risk?
Take heart. Remember that NASA wants this effort to succeed as much as (or even more than) you do. If there’s not enough money to go around, then why not shake hands and team up (41 separate companies expressed interest in the CCDev 2 synopsis)? Then send your most influential people to the NASA Docking System (NDS) Technical Information Meeting (TIM) on November 17, 2010 at NASA-JSC; express your concerns as an Industry Working bloc there. America is counting on you!
Docking TIM? Nice plug for your meeting. What has that got to do with the price of tea in China . . . or with the root problems facing human space flight. Build a cheap, durable, can’t-fail mechanism and the world will beat a path to your door.
I may be misinformed, but I am under the impression that the Space Shuttle does not meet NASA’s own human rating requirements and flies with waivers allowing it to do so.
Could a similar process apply here? A company seeks and is granted waivers from certain requirements for its system?
The Space Shuttle was built and certified before NASA had human rating standards. In fact the Space Shuttle requirements document (NSTS-07700) is a really detailed set of requirements that the program has to meet. That set of requirements, by the way, fills about 34 2-inch thick binders. I know, I had to abide by every statement in it or ask the permission of the administrator and the Pope to fly with a waiver.
While I understand the notion, is comparing Commercial crew and NASA Launch Services a bit of an apples to oranges scenario? After all, the latter only uses mature/demonstrated LV, while Commercial Crew will use new spacecraft (even Dragon would be substantially reworked)
Makes one wonder whether the technical community is really just fighting to make the spacecraft themselves (Orion), not because of a self-serving motivation but with the genuine belief that such a route is the safest and only way to build a manned spacecraft.
Since the mid 1990’s, the military has undergone a huge transformation of structural culture to integrate the services which has reaped enormous benefit, does NASA need to do the same?
It is exactly my contention that NASA needs a “huge transformation of structural culture”.
I see the comments about how NASA might follow the FAA model of not setting standards and let the industry set standards.
As NASA continues to be a jobs program they will continue to fund people to create and review forms. At least in the launch area it will remain business as usual for a while. This is a given, the creativity it takes to fill in or create forms, regulations, have meetings is minimal, just what low trust organizations perpetuate. Wayne, you probably have been sick of this for years, as many of your colleagues still at NASA are.
Confronting the reality, we, the Commercial Space industry will have to create sustainable business models, products and services predicated on the notion NASA will not be an early adopter. We can do this. What role if any would you recommend the FAA AST office play because they have in their mission to Ecnourage, Facilitate and Promote Commercial Space. and what role might the newly announced Center of Excellence for Commerial Space Transportation play? QOU
Pat
I respect you too much to let the first paragraph stand. NASA is full of people who are doing their job expertly and with dedication. I see nobody that takes comfort in having unnecessary forms regulations or meetings. However, the culture of the organization does lead to these things even with the best of intentions.
Sick of this for years? I’m sick of being stuck in low earth orbit with a whole universe to be explored.
I think the FAA is conflicted because they are supposed to both promote and regulate commercial space. To date, there has been much more promotion than regulation but I am sure that is about to change.
As an outside observer of the space industry, I am not nearly as informed about the inner workings and bureaucracy as most of you. However, as a “space fan” who enjoys seeing what we have accomplished and hopes for continued progress, I find the discussion interesting and informative.
As a pilot and safety person, I am fairly familiar with the FAA and their history. When I read that the FAA is “supposed to both promote and regulate commercial space” I was shocked. I do not know when this mandate was established, but I am surprised it has not yet been modified–from what I understand, history seems to be repeating itself…
In 1935, Senator Bronson Cutting was killed in a TWA DC-2 crash. Congress chose to react and in 1938 the Civil Aeronautics Act was created, with a “dual mandate” in its charter. The 1940 amendment to the to Act established that the Civil Aeronautics Board was to regulate and promote aviation. After the 1956 mid-air collision of United and TWA airliners over the Grand Canyon, Congress again reacted to pass the Federal Aviation act of 1958. The dual mandate was kept, but more focus was put on regulating safety.
After two high-profile DC-10 accidents in the early 1970s, a call for the elimination of the dual mandate came during a Congressional investigation to explore the relationship between the FAA and industry. The end-result of that investigation was to remove the relationship of the NTSB from the Department of Transportation, and instead report directly to the Senate.
Not until after the ValuJet crash in 1996 was the “promotion of aviation” mandate re-chartered so that safety was the highest priority for the FAA–almost 60 years after it was originally established. Even still, the Alaska Air crash in 2000, and more recent maintenance lapses have shown a culture of relationships not conducive to safety between the FAA and industry.
I hope I have not gotten too wordy with the history. I am not rooting for one side over another. As an idealist, I would love to see all sides succeed for the best future for man-kind, but as a realist, I have my doubts. I understand that culture is one of (if not) the most difficult changes to implement, but perhaps history can help us avoid costly missteps in the future.
So the man who sat at the table, gavel in hand, most able to fight the good fight against requirements creep, and too much bureaucracy sat silence, unable to muster the courage to fight now wants me to believe this new way of thinking? A man now on the payroll of commercial development of space?
Teddy Roosevelt said it best when he talked of the man in the ring, when Mr. Hale was in the ring he quickly sidestepped the very issue he now complains about.
Really Wayne, I now understand your great grandmother’s quote even better. “The cowards never started, and the weak ones died along the way.” What would your great grandmother think of the man who never started, but now wants to complain?
You must have missed all those PRCBs and daily boards where we addressed waivers and excess requirements and laboriously whittled them down. Saying no to unnecessary requirements was one of the things that I thought I did fairly well. But I guess others should judge that.
It is absolutely true that in my post-retirement life I am consulting with several of the firms which are trying to build commercial human spacecraft. If that makes my judgment tainted, then I guess I am guilty. I did have the thought that I was helping a new industry start, but again, others should be the judge of that.
I appreciate the fact that you have read my other writings and can quote my dear departed grandmother so well. I have also said several times I don’t know if I could have been a pioneer; the folks that founded this country were really tough. My point was not to complain so much as to try to initiate positive change. We’ll see if that result comes about.
Thanks for joining the dialog; it is helpful to me when folks point out my shortcomings.
Mr Hale:
Speaking for myself, I appreciate hearing observations from someone who has been on the inside and understands what NASA is all about, rather than the usual cluster of armchair experts who often have never even grappled with a differential equation, let alone real spacecraft hardware.
Thanks for resuming your blog!!!
Wow!
Amazing discussion!
So the requirements should be simplified and stated in broader terms that encourage the contractor to innovate a better way to full fill them, ie; fly safely?
diminishing returns. I have had a chance to watch the bureaucratic demands of the Feds on industry develop in situation, first hand, during the Oil Spill. I wish I had gathered data from the start to compare the escalation of paperwork with the productivity of the contractors. I am not sure which is more interesting to follow… the piles of additional paperwork, or the justification of said paper by those who nobly invent it.
KISS, right?
Tim
Wayne, I suspect that one way to resolve this upcoming train wreck is to set up these regs to be a shopping list of requirements, from which the terms for each contract may be developed. Thus the specs would be tailored appropriately.
Of course, that’s easy to say since a lot of these things get cast in concrete. Better that the NASA and the FAA get together and negotiate who does what to who and when.
ReusableForever, Negotiating the requirements with each contractor does sound somewhat promising. That could be similar to how Rage Safety requirements are “tailored” to each program. At any rate it is one way forward.
Oops. I meant Range Safety.
Wayne,
Are the requirements in CCT-REQ-1130 more or less strict than what NASA was working to when developing the Ares-I? If they are similar to the Ares-I requirements and everyone agrees they are overkill, then why not have NASA build launch vehicles to the same “relaxed” requirements that the commercial companies would build to.
Mr. Hale, great conversation and insight from your point of view. I started in the Shuttle program with Rockwell in 1979 as temporary tile tech.. Having grown with the entire organization, the transformations and learning processess that came with a brand new vehicle was eye opening. I for one witnesses and experienced the ever increasing requirements imposed many of which we all agreed with, equally there are many that seemed to be redundant and hugh waste of time..
I can appreciate your position while in NASA and the constant battles you had to endure dealing with senior NASA executives, a culture that promotes lethargy and slow deliberate discussion on every detail..
I for one know the only way for you to help change this culture is to be Outside of NASA as you are doing now, I do not believe you to be cowardly, I think you, like all of us close to this program know you had no chance while you worked for the very people that promotes the problem, even today!.
NASA, like many governement agencies, has seemingly run with an open taxpayer check book with the promise of more funding in the next FY.. in one hand doing so in the name of safety and in the other a way to employ more people. When money drys up or budgets need reductions it’s the contractor employees that have always born the brunt of these cuts and layoffs as the national media labels all of us as “NASA” workers when the facts are not one ” governement” employee lost anything!
It might seem shallow of me to mention this, but I firmly believe that one of the fundamental building blocks of the NASA culture you speak out against here it that no NASA employees have any fear of loosing their jobs.. if they were forced to work under the same rules of we do, they would be much more careful in creating or adding expense to the program without sound and “resonable” requirements.. There would need to be accountablility, managers and directors would need to question these costs, and report these reasons and justify them as well.. or be fired…
People don’t need to work in fear, just good common sense and spend money wisely.
Now that I have moved into the airline industry I see many similarities between NASA and the FAA requirements, however the the airlines and FAA work more together to make sure these changes make the proper corrections, keep people safe and costs to a minimum..
In the end, I don’t believe for a minute that these COTS folks would be here at all if it were not for the NASA money to “play” with.. Just as in national defence, I firmly believe that NASA should be the main player in manned space, it just needed to be smarter about it’s relationship with the likes of Rockwell/ Lockheed/ Boeing. Had it seen this 20 years ago, we might well have already been back on the moon or Mars..
Its not too late.. As I dont think COTS will be around very long as these requirements and associated expenses start eating into profits.. then where will the USA be? Dependant on someone else to do what we can do now…
Well I’m depressed.
Will this overwhelm COTS then? It seemed a given that it would be the model. For these remarks, it seems that eve the FAA’s AST is already broke so it can’t be the standard.
Space X has often stated the Falcon 9 and the Dragon were following manned ratings from day 1. The Dragon and any cargo carrier must follow those rules (at least some of them) since people go in and out of them once at the ISS (sharps, atmo, ect.).
The numbers keep going up what Space X needs for a Launch Abort System but they imply that is all that stops them for flying people in the Dragon. And why an LAS when STS doesn’t have it?
And then, of course, this only pertains to LEO, there really are no plans for past LEO except a HLV.
Dang it man.
Charley, COTS is dead as far as crew goes yes. NASA confirmed this with recent press conferences for the new program, CCDev. Apparently SpaceX’s first leader advantage must be sacrificed to allow for a level playing field with the likes of Boeing and Lockheed Martin.
And let’s face, COTS can not afford these programs on there own.. no board of directors is going to risk the entire worth of their company on such a high rish and low return venture…
Space is a national endevour where the reward comes in many other way aside from $$$
Thanks for the heads up. Hadn’t paid attention so missed that.
Let’s not forget that the FAA model is far from perfect. In their mandate to both promote and regulate air travel they often end up conflicted between the differing requirements of each. Mix in the NTSB and it can get downright ugly (and unproductive) at times. However, even that flawed model is better than NASA issued requirements that are so top heavy nothing but a government funded vehicle has a chance of meeting them.
Speaking of requirements, NASA has certified the Soyuz to meet the requirements for flying it’s astronauts. Would the Soyuz meet the newly required standards?
The other elephant in the room of Commercial Crew is responsibility and liability. When there is a major catastrophe involving a Commercial Crew vehicle, who will get blamed? Who will have legal liability to the families? If the answer is still NASA, and NASA will again get shut down for ~3 years to do investigations and mitigations, then of course NASA is going to impose all these requirements. If they don’t, they will get blamed by the next commission for ignoring/forgetting the findings of the previous investigating bodies. On the other side, I really don’t see any insurance company or legal department allowing these private companies to take full responsibility and liability for such things.
well you brought up the bad word… liability. with lives on the line this issue is the elephant in the room.
Recently I got to testify before the Senate Subcommittee on Science, Space & Transportation – one of their toughest questions was about indemnification – that is the practice of the government standing in for the liability that might be incurred due to a space launch accident. So liability, the legalities, and the government’s role is front and center in the debate over commercial space flight. Nothing new here.
NASA should be taken out of the loop for LEO. Let the FAA oversee it and let commercial risk their own money and own crews until they can demonstrate a statistically measurable safety of flight (say 10 manned LEO missions?). You can have all the paperwork you like but until they fly and can show some reliability then the safety requirements are just words on paper, a guide only.
I wonder what the safety requirements are for Soyuz? How many pages is that? I bet it nothing like 260 pages yet NASA fly’s astronauts on it.
NASA needs to concentrate on developing exploration architecture to get us beyond LEO ASAP rather than get bogged down with something it already has or shortly will loose control of (access to LEO).
I don’t like to see a requirements list that long either. But it has become something of a necessity just because of the way these things work – or really how infrequently – and especially in the case of expendables. Commercial aircraft have the “luxury” of many months of flight testing to work out problems and to build up confidence prior to revenue service; that comes with a lot of paperwork, too, but always accompanied by hard data from those tests.
We, in the launch business, orbital or sub-orbital, don’t have that “luxury” and never have. VirginGalactic will approach this as they are advertising that they will be flying frequently next year prior to revenue flights – a distinct advantage to reusable systems. Therefore we have always had to rely on analysis, analysis, analysis. One version is FMEA: Failure Modes and Effects Analyses. I haven’t seen the subject lists but I suspect that this analysis approach is well entrenched in those 260 pages. So, we the launch industry, are between a rock and a hard spot: how else do we satisfy a potential customer that we are safe with only a relatively limited number of flights?
I knew Constellation was in trouble when I started working the Constellation Program
Environmental Qualification And Acceptance Testing Requirements (CEQATR) document. In a telecon I heard comments that technology had improved since Apollo and that Shuttle tested too lightly due to reflight requirements. Both were wrong as test technology has improved but not the factor of safety standard and Shuttle tested everything for five to ten times flight duration. They tried to “improve” the old standards. And that’s how billions get spent on documents without real hardware being produced.
When I heard about a new NASA requirements document for commercial flight, I figured NASA would spend a lot of time regurgitating and “improving” launch vehicle requirements, and that the new launch supply contractors would trash-can it as soon as they could.
I wondered at the time why the old Gemini requirements wouldn’t work better. Gemini was an upgrade to a DoD missile with a great capsule and turned out extremely reliable.
But such a thing would be just too simple to satisfy the ten to twelve NASA document review boards. Better to create a huge document that looks impressive and nobody has to fully understand.
Just want to let you know that it’s great to have you blogging in your retirement.
One of the things I noticed in the threads is it seems NASA needs to do what the Air Force did back in the early 90’s. Back then, the Chief of Staff ordered all Regulations, T.O.’s and documents to be cleaned up. It was known as the cut-in-half days. Every thing was looked at real close, and if it really didn’t need to be in their, it was cut out.
For us ops guys, this was hard, because we felt every thing in our books we’re written in blood. Turns out, word came down, if we didn’t, someone else would. We did it, and the world didn’t end, and planes didn’t fall out of the sky.
Then they changed the uniforms, but that’s a different story.
I’m not sure that NASA could do any thing like what the Air Force did, because,
1) The Air Force is ran from the top down, don’t like it, there’s the door.
2) Civil servants are the slowest to change. This happened in the Air Force when CS’s left instead of adopting the new standards.
3) Who is really “in-charge” at NASA.
That said, I’m getting to old to worry about it to much any more. Just hope the new kids on the block can make something happen. For my kids sake.
It looks like Musket is referring to the Air Force acquisiton reform effort of the 90s. I don’t know about planes, but the Air Force blew up a few launch vehicles and delivered several expensive satellites to useless orbits, or worse yet, the bottom of the ocean, largely as a result of cutting corners on testing. MIL-STD-1540 had been whittled down from a specific set of test requirements to a vague set of guidelines that left it up to the contractor to decide which tests were needed. After the failures started occuring, the document was again revised to add the specific requirements back.
Programs almost always tend to cut back on testing, particularly when delivery milestones are approaching. The risk posture often changes drastically when the program is over budget and behind schedule, and without firm test requirements or independent oversight, wishful thinking about hardware performance can easily overcome common sense.
Ed, MIL-STD-1540 was just a small slice of the pie when it came to changing not only the acquisition processes, but also massive changes to the operations side of the Air Force. I was involved in as a Flight Engineer in the Strategic Airlift side of operations. With the reforms came changes in planning, scheduling, acquisition, and actually preforming missions. As time went on, it was found that some of the requirement cuts went to far and some of the old requirements we’re added back in, but only when failures could be identified, or processes showed that improvements could be made to the new standards.
The biggest costs to the Air Force for the Atlas and Delta’s is not the cost of production of these LV’s, but the cost of meeting the requirements set down by the Air Force to meet the requirements set by it’s customers (NRO, DIA, ect).
With the Air Force looking at block purchases of ULA LV’s, we may see the cost of these LV’s come down some and improvements to the LV’s themselves happen with each block purchase.
Requirement creep is a real problem with any organization, and must be carefully watched for. Hopefully NASA OIG can help reduce or reverse some of this problem within NASA and it’s HSF requirements.
Many years ago when I first pitched the idea of the EASE experiment (which eventually flew on STS 61-B in 1985), Gen. Jim Abrahamson (who at the time was the AA for Office of Space Flight) approved the idea enthusiastically, and said “I want to use this experiment to show that the shuttle can be an extension of the academic laboratory, and that we can eliminate a lot of the unnecessary paperwork for flight qualification.” Over the next three years, I came to realize that there is a big difference between the guy in charge and the guy in control. The guy in charge can say “We don’t need all this paperwork”, but the guy in control is a minor grunt in an office far removed from the sunlight who has to sign off on some obscure qualification item. He’s use to seeing a 500-page report before he signs off, and he’s not going to get any benefit on his performance assessment for signing off without it if the mission is successful, but his ass is grass if he signs off without it and the mission fails. Therefore, it doesn’t matter what the AA says, he’s going to see everything he always sees before he signs off. Multiply by a hundred or so and that’s what shuttle certification is like. (I’m told ISS certification is an order of magnitude worse.)
Very astute comment, Wayne, and I hope they will eventually let this standard get through the firewall so us mere mortals can see what they’re asking for these days…
Can’t the “great minds” in Washington compromise on the Commercial Transportation Program? Let NASA build, test and validate the crew module, while the commercial companies build the rocket it flies on. Many of NASA’s plethora of requirements are there to help ensure the (NASA’s) crews’ safety.
If NASA owns the crew vehicle, and the commercial companies build the rocket, then NASA can keep all of their own requirements for human spaceflight ratings and only require the commercial vehicle to interface with and launch the crew vehicle safely.
Or is this too simple a solution?
Yes, “donsginny” and others of similar thinking. It is too simple a solution to try to separate the crewed spacecraft from the launch vehicle. The complete system that must be human-rated (certified) includes all the pieces involved – from crewed spacecraft “payload” to ground processing systems and mission control systems. They all provide support for the human-rating requirements, even if their own specs are completely separate from those of the other elements in the system. The launch vehicle must support meeting all of the human-rating requirements pertinent to it via its own capabilities (meaning by its requirements). Declaring a human-rating requirement “not applicable” to the launch vehicle demands proof that it is not relevant. That is one of the challenges in attempting to convert the EELVs for crew launches. Their requirements never included support for the human-rating requirements associated with crew. In addition, the philosophy of human-rating as NASA has defined it involves a crew safety mindset throughout development. I feel safe in declaring that didn’t happen.
It sound like NASA is more like in the way of commercial spaceflight because of the overburden requirement. What can NASA regulate? When NASA was started, it was for research and development for space exploration.
Concerning the length of the requirements for each vehicle: while some may complain that the complexity of the devices is the cause, it seems to me that the reason for the increase in the number of pages is a growing fear that Something May Go Wrong tied to a fear that the contractors can’t be trusted to do the job the right way.
It’s not about the ISS, Wayne. It never was. They can place all the requirements they want for flight to ISS, but once those capsules are flying they will be certified to launch at price points that non-space agencies, research organizations, coorporations,…heck maybe even some Universities themselves, can afford seats on…and those entities will get together and agree on their own requirements. The whole world is holding its collective breath, sitting on springs, waiting to jump into space…to have space habitats in orbit without the ISS and fly to them without NASA. The clasp on the trigger that sends it all flying is those first Commercial Crew flights.
Extra paperwork to fly to the ISS? That’s just another reason not to fly to the ISS. Congress thinks that Commercial Crew is only important while the ISS is in orbit, but it and NASA will be obsolete, so far as LEO flight is concerned, long before the current scheduled deorbit date of ISS.
Both to pass go and collect the money to develop their vehicles they must get the NASA seal of approval and fly first to the ISS. Hopefully this will start a new industry which flies for other folks to other destinations, but NASA us the jey
I’m not sure what you tried to say here, Wayne, but you are correct. They have to hit their milestones and those milestones probably have all those pages built into them. I would think that both Boeing and SpaceX have access to those details as part of their contracts. They (especially a long-term provider like Boeing) might actually have folks with access to that very file that you read.
Maybe NASA want’s these commercial space companies to experience 10-15 years of launching unmanned rockets before even attempting launching a crew.
Recently I read someone’s post and they insisted that SpaceX would be launching humans around 2017. I wish that were true but I can’t imagine it happening by the end of this decade.
That is the official schedule – both Boeing and SpaceX to fly their human carrying capsules to the ISS in 2017
Spot on
“When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites. NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users. This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.”
When the FAA followed that approach it led directly to the MAX disaster.