Thursday, November 09, 2006

Early morning with the FAA.

This morning at 6:00am I had a conference call with the FAA/AST.
I think it was a good first discussion.

One bit of good news is that they can still issue "burn time waivers"
or officially license waivers. This is a lot less onerous than doing the full
environmental review called for by an experimental permit.

I was hoping to get endorsement for my concept of drawing a bright line between operating and safety systems and qualifying the safety systems and leaving the operating stuff alone.
They did not really say no, but it was clear thats not the way they want to proceed.

In some places I was hoping for a little more direct guidance about whats acceptable.
Some of the conversation went like:

Question to FAA:What would you like to see to prove X?

Answer:Its your job to convince us of X.

The answer is completely correct and almost useless.

Its all part of the process and my current action item is to generate a hazards and hazard mitigation document.

My short version of the document:

Hazard: The Vehicle or parts of the vehicle can leave the defined operating area and hit
something it's not supposed to.

Mitigation: Add redundant safety abort systems that will Kill the vehicle before it does so.

They want a bit more detail, I'll have to work on that. :-)


Anonymous said...

I think in the hazard analysis that AST is looking for failure modes, not just failure effects. It's a little annoying that they treat your vehicle as an unknown quantity so they assume probability of failure 1.0 (Your vehicle could go anywhere so you have to be a kilometer from the crowd) while simultaneously requireing you to give them details on how you mitigate each failure mode to make its probability of failure less than 1.0. But that's the multi-pronged approach that the FAA is used to.

Anonymous said...

well. depends on what you're doing. If you're going for a license waiver, chances are AST is going to hold you more to the license rules than the permit rules. (They have to justify the waiver by essentially addressing all the rules they are waiving. Somehow this is different than justifying the license approval by addressing all the rules you are meeting.)

In any event, a waiver to a license is considered a "major federal action," and is subject to NEPA (the environmental stuff). Anybody who told you otherwise might have been misinterpreting the ease of getting a categorical exclusion with having "no environmental." You will never really have no env... you'll just have LESS env. :)