Regulating Explosive Risks
Amidst the well-earned publicity for the latest NASA landing on Mars of Perseverance, a quieter revolution is taking place in space launch capabilities. Launch frequency continues to climb, the cost-per-kg to orbit continues to fall rapidly, and new launch systems are seeing investment at record levels.
SpaceX has been the leader in the field in terms of launch frequency and payload deployment, with its Falcon-9 system posting launch reliability rates of 98%. It recently had a minor bobble as booster stage B-1059 failed to land after its sixth flight. Not long ago, space watchers fretted about the ability of a rocket to be reused at all. Now we fret that they are not being reused enough!
The long-term play for SpaceX, however, is their Starship program, its launch system for both large-payload flights to Low Earth Orbit, and for longer-term missions to the Moon, Mars, and beyond. SpaceX has turned reusability into a major asset. Instead of launching one rocket and expecting it to make it all the way to a distant target, launch one to orbit, refuel, and then have much more capacity to perform tasks in space. Refuel can be accomplished by ferrying fuel up to an orbital tanker facility (maybe as simple as “just another Starship”) and running many flights. On current estimate, if SpaceX can work out the orbital fuel transfer capability, a total of 7 Starship flights can position a fully-fueled Starship in orbit, with massive delta-V capability for work in space.
That model will require one thing: extremely low-cost reusable rockets at a scale similar to the Saturn V that launched the Apollo missions. This sounds challenging when you consider the Boeing/NASA Space Launch System, a vehicle of similar capacity to the Saturn V, has spent $18B over several years, including a billion dollars just for the test stand. But SpaceX has prototype SN10 on the stand at their Boca Chica facility now, with several more in production nearby, funded mostly privately.
Estimates for Starship production costs vary, but $100M is probably the upper bound and the cost may be considerably lower. They plan to build 100 of them so they’ll need to be cheap. And at that cost, they can afford an iterative, test-to-destruction program.
Hence where the risk comes in. When your economic costs are so much lower than competitors, and the entire system is designed around volume production and reuse, the risk of a single flight failure becomes much more manageable. SN8 crashed and exploded on landing. SN9 did the same, for different reasons. SN10 may well do the same. The data gained is worth the production loss. The cumulative risk, however, has caught the attention of US regulators. The US Federal Aviation Administration, which holds responsibility for public safety regarding aircraft, are now investigating — and in some cases, delaying — SpaceX’s aggressive testing program.
This all boiled over a bit with delays imposed on the SN9 test by the FAA, in a rather pointed Twitter discussion by SpaceX CEO Elon Musk. American space fans immediately jumped all over the FAA, accusing it of being behind the times, too slow, and in the way of progress.
It’s not that simple. The FAA has guidelines from Congress for regulation of space programs, and Congress is not the most nimble of bodies at the best of times. The guidelines call for risk thresholds to the public in the 1/1,000,000 range, and for clear processes to be in place to manage to that level of risk. Boca Chica is six miles away from tourist destination South Padre Island. Starship stands over 150 feet tall and is fueled with liquid methane, which makes impressive fireballs on impact. Small wonder the FAA wants to review mishaps.
SpaceX has not been spotless in their record. Local government agencies keep the public away when a launch is scheduled, but the responsibility for ensuring a clear range for launch lies with the launch provider. There have been multiple pre-launch range clearance issues, with one passerby driving right past the SN9 prototype fueling up for a static rocket test. And the FAA SN9 delay, it turns out, was due to SpaceX launching SN8 with an incomplete signoff on their failure blast radius analysis, an important detail to get right when calculating risk to the public from giant exploding rocket ships.
Note, however, in Elon’s tweet that he took pains to criticize the regulations, not the regulator. There’s a couple of reasons for that.
Regulators are there to help manage risk, not to completely eliminate it. The FAA knows this and has been quite responsive for a government agency in working with SpaceX. The language used by the FAA tells you something, though. They refer to the SN8 “mishap” because that’s what the regulations call it, even though all parties knew SN8 was unlikely to pull off a landing on the first try. The regulatory guidelines, however, presume that you really don’t want to crash your expensive rocket. They were written in a time where that was not expected at all. So the risk regime needs an update. And, as it happens, one was ordered by the President in 2018 and will be rolled out in March.
But Musk, I suspect, does not really want the FAA to get lost. The FAA helps SpaceX manage risk as well. Rockets that were approved by regulators tend to be presumed to be operating to a reasonable standard and not one of negligence. So if SpaceX makes a mistake and damages property or people, they have some independent review and “best practice” assertions to fall back on. Likewise, insurers are increasingly playing a role in managing risk for the space industry as it matures. Insurers like predictability, and regulatory review and signoff provides that predictability.
Regulators may be slowing down SpaceX a bit. But they are providing important risk management services to all parties as payment for that delay.