1. Presented to: By: Date: Federal Aviation Administration Office of Commercial Space Transportation Orbital Debris 10 June, 2015 Symposium for the Small Payload and Rideshare Association (SPRSA) Steph Earle, FAA AST-100 Steph Earle, PMP Space Traffic Program Lead / Space Transportation Industry Analyst Federal Aviation Administration Office of Commercial Space Transportation

2. Federal Aviation Administration Expanding U.S. Commercial Capabilities Suborbital RLVs, ELVs with vehicle return capability, habitat demonstration Bigelow Aerospace XCOR Aerospace Orbital Sciences Space X Virgin Galactic Armadillo Aerospace and Masten Aerospace Blue Origin We expect reusable LVs will launch small-sats – increased opportunities and revenue 2

3. Federal Aviation Administration Commercial remote sensing satellite Licensed by NOAA NGSO commercial communications satellite Licensed by FCC GEO satellite communications slot Allocated by ITU GEO satellite communications Licensed by FCC Commercial launch event Licensed by FAA Commercial launch event Licensed/Permitted by FAA Commercial Suborbital launch/reentry site Licensed/ by FAA Commercial orbital launch/reentry site Licensed/ by FAA Suborbital Orbital NAS Today’s Space Oversight Regime Commercial reentry event Licensed by FAA 3 DOD provides safety of flight information services Different agencies currently have oversight based upon the general mission of the objects Interagency coordinates on regulations and safety requirements but some differences exist

4. Federal Aviation Administration Commercial Launch Growth These could change significantly with breakthroughs. Estimates derived from AST engagement with operators, including launch manifests; orbital and sub-orbital 4 Commercial Space Industry is Now a Reality; Poised for Strong Continued Growth

5. Federal Aviation Administration Orbital Debris Guidance 2010 National Space Policy calls for “minimizing debris and preserving the space environment” 2013 National Space Transportation Policy Execute exclusive authority, consistent with existing statutes and executive orders, to address orbital debris mitigation practices for U.S.-licensed commercial launches, to include launch vehicle components such as upper stages, through its licensing procedures. 5 Continue to follow the United States Government Orbital Debris Mitigation Standard Practices, consistent with mission requirements and cost effectiveness, in the procurement and operation of spacecraft, launch services, and the conduct of tests and experiments in space. Guidance International forums continue to stress standards to prevent debris creation on orbit Space Policy and Space Transportation Policy Inter-agency Space Debris Coordination Committee (IADC) International Code of Conduct for Outer Space Activities between European Union and the U.S. Rocket Bodies in LEO* ~1800> 1,100,000 KG * Data from 2014

6. Federal Aviation Administration Current FAA Requirement § 417.129 Safety at end of launch. A launch operator must ensure for any proposed launch that for all launch vehicle stages or components that reach Earth orbit— (a) No unplanned physical contact between the vehicle and the payload; (b) Debris generation does not result from the conversion of energy sources into energy that fragments the vehicle or its components; (c) Stored energy is removed by depleting residual fuel and leaving all fuel line valves open, venting any pressurized system, leaving all batteries in a permanent discharge state, and removing any remaining source of stored energy. 6 Policy cannot be directly levied on commercial operators except through rulemaking process.

7. Federal Aviation Administration US Government Standard US Government Orbital Debris Mitigation Standard Practices (USGODMSP) Four objectives 1.Limit debris released during normal operations Anything ≥ 5 mm must reenter within 25 years 2.Minimize debris generated by accidental explosions Design spacecraft to limit risk Safe spacecraft and upper stages at End of Mission (EOM) 3.Select safe flight profile to minimize lifetime collision risk 4.Plan for cost effective EOM disposal procedures for spacecraft and upper stages 7 Current LV Regulations Reusable upper stages and new technologies for de-orbit Current Typical Practices

8. Federal Aviation Administration FAA Orbital Debris Mitigation proposed changes 8 FAA has jurisdiction over rocket bodies (including upper stages) through the end of launch Goal: Updated regulations would better align with the US Government Standard Practices Challenge: Cost vs benefits must be analyzed –Difficult to quantify –Rules that impose a cost to the industry are hard to pass through the review process

9. Federal Aviation Administration Launch Collision Avoidance How does it look for a typical launch window –Considering active satellites and known debris –Objects passing within 200 km of trajectory –Launch window closed when objects and vehicle could collide 9 Close approaches by minimum distance for one hour launch window km Seconds 200 km limit of concern.Orbital Objects Launch Time; sweeps through window. All approaches within 200km identified. Congestion building as we squeeze more objects into the same space!

10. Federal Aviation Administration Debris Mitigation Standard Practices Relative to Commercial Launch Continue to follow the United States Government Orbital Debris Mitigation Standard Practices, consistent with mission requirements and cost effectiveness, in the procurement and operation of spacecraft, launch services, and the conduct of tests and experiments in space. Guidance 10 FAA Rulemaking process is a deliberative process that often takes years. Yet it allows public and industry to participate. Policy cannot be directly levied on commercial operators except through rulemaking process.

11. Federal Aviation Administration Identify Need for Rulemaking Legislation Petition Court Decision New Technology Develop proposed rule Initiate rulemaking Draft Cost/benefit analysis Council review Council approval Coordinate proposed rule DOT Review OMB Review Publish in Federal Register Start of public comment period Public Comment Period Possible Public Meeting Develop final rule End of public comment period Analyze and address comments DOT review OMB review Publish Final Rule in Federal Registry Rulemaking Process 450 Days 90 Days310 Days 1.25 Years 1.5 Years 2 - 3 Years 11 What’s it take to change the rules? Rulemaking Considerations and Realities Additional scrutiny for rulemakings that are determined to be significant: an annual impact on the economy of $100 million or more Legal agreement and concurrence Complete cost-benefit analysis demonstrating that the benefits justify the cost OMB Review Industry reaction and comments Current US Government anti-regulatory environment – minimization of rules and aversion to additional rules

12. Federal Aviation Administration Questions 12