Space Governance and Stakeholders Roles

Space Governance and Stakeholders Roles 5th Manfred Lachs Conference

Montreal 5-6 May 2017

ByTommaso Sgobba and Isabelle Rongier

International Association for the Advancement of Space Safety

International Association for the Advancement of Space Safety 1

The Skills Gap


Licensing of commercial safety-risky activities is traditionally performed by a governmentregulatory body that has the responsibility for:

- levying safety requirements

- performing surveillance activities, and

- certifying compliance

However, considering the ever-widening technical skill gap between high-tech industryand traditional government regulatory organizations, such way of operations is becomingimpractical in many advanced technological fields.

Space has some additional peculiarities: 1) skills gap between countries withlong tradition of government space programs, and countries which arenewcomers in the space arena; 2) skills gap within a country with specializedknowledge residing in a different government organization (e.g. national spaceagency, e.g. NASA vs FAA).


Bridging the skills gap withina country

(Human Spaceflight)

The Case of Commercial Human Spaceflight in US

Current U.S. commercial space legislation limits FAA licensing to the protection of public safety

during launch and re-entry operations.


However, there is one remarkable exception

that applies to operators providing commercial

transportation services to the International

Space Station under the terms of NASA’s

Commercial Crew Program (CCP). They are

required to obtain a NASA safety certificate for

the safety of humans on board, as foreseen by

the original agreements signed by governments

participating to the ISS program (NASA OIG,

2016).

The Case of Commercial Human Spaceflight in US

The safety policy document ESMD-CCTSCR-12.10 “Commercial Crew Transportation System

Certification Requirements for NASA Low Earth Orbit Missions” includes four parts:

a) Certification Process: outlining scope and elements of the certification process: validation of

the technical and performance requirements/standards; verification of compliance with

requirements/standards; consideration of operational experience; and acceptance of residual

technical risk due to hazards, waivers, non-compliances, etc.

b) Documentation: compilation of plans and documents required for submittal at project

milestones to collectively prove that the system meets technical requirements and is safe.

c) Safety Requirements: system capabilities in three primary categories of system safety,

crew/human control of the system, and crew survival/aborts.

d) Standards: in the fields of engineering, safety, and medical/health, subdivided in those that

must either be met as written, or equivalent alternate proposed to NASA Technical Authority

for approval, or representing recommended best practices.


Verifying compliance with performance requirements is not easy task

Because it is simply impossible to formulate prescriptive requirements (i.e. detailed safety

design solutions) for something that never existed before, space agencies use to issue

safety and technical requirements that are goal/performance oriented.

Being performance requirements generic, verification of compliance is a crucial task demanding

highly-skilled interdisciplinary competences.


During safety reviews of a CCP spacecraft, a NASA

multidisciplinary panel of experts will identify issues and make

recommendations, but cannot impose design or operational

solutions. However, NASA Technical Authority can refuse to

accept a risk.

Even if FAA would have the responsibility to regulate

human spaceflight in US, it would not have the skills.

Third party certification: the example of Classification Societies


In the second half of the 18th century, marine insurers based at Lloyd's coffee house in

London, developed a system for the independent inspection of ships presented to them for

insurance coverage. In 1760, a committee was formed for with the express purpose of

classifying the condition of each ship on an annual basis. In 1834, the Lloyd's Register of

British and Foreign Shipping was reconstituted as a self-standing 'classification society'.

Following the example, a number of Classification Societies were established worldwide.

Nowadays, Classification Societies act as a “Recognized

Organizations” carrying out statutory surveys and

certification as delegated by national maritime

administrations (flag administrations).

Building a Commercial Space Safety Institute


No matter how much the cost of spaceflight will be slashed, without advancing the safety of

space vehicles there will be no growth, no expansion and perhaps no future at all for the

commercial human spaceflight industry.

Advancing space safety engineering applications, research, and education should be a primary

strategic business goal of industry as a whole. Industry should build on the experience

accumulated in more than 50 years of government space programs, and cooperate within

industry and with regulatory bodies to advance safety as common strategic goal. For such

purpose, commercial human spaceflight industry should consider establishing a Commercial Space

Safety Institute (CSSI) as a non-for-profit organization funded by industry but independent and

separated from trade organizations.

The CSSI would provide standardization and safety certification services commercial human

spaceflight industry. The SSI should be a “recognized organization” approved by and operating

under oversight of a national regulatory entity. The Commercial Space Safety Institute would also

coordinate, support and promote research in the field of space safety engineering, support

educational programs, and provide professional training opportunities to members.

Building a Commercial Space Safety Institute



Bridging the skills gap between countries(Space Debris Mitigation)

Good intention – inadequate action!


For space debris, we are still in the phase of promoting awareness, collecting statistics,

and issuing guidelines. In 2007, the United Nations General Assembly endorsed the

COPUOS Space Debris Mitigation Guidelines. In 2011, ISO standard 24113 on “Space Debris

Mitigation” was issued which is policy guidelines saying ‘what’ needs to be done and not ‘how’

to do it. While some countries and organizations have already taken the step of

mandating its implementation in their space programs (as the French Space Operation

Act), worldwide implementation is still largely pending.

Good intention – inadequate action!


As a minimum, we can say that the progress made until now does not match the seriousness

of the problem. A growing problem that the arrival of newcomers, launches of CubeSats, and plans

for mega constellation will further exacerbate.

As of January 2017 (Source ESA)

Verifying/enforcing compliance: the IAQG example


The establishment of an international (government) organization to verify/enforce

compliance is not on the table. The alternative is to look for an industry initiative, and the

IAQG is an interesting model.

In 1998 major aerospace primes having recognized that they were often sharing the same supply

chain, decided to set up a non-profit organization, the International Aerospace Quality Group

(IAQG), with the responsibility to adapt the ISO quality standard (ISO 9001) to the need of the

aerospace industry, to develop supporting ‘best-practices’, and to establish a unique system of

compliance verification and enforcement through shared auditing. Nowadays AS/EN 9100, the

IAQG aerospace quality standard, is used worldwide, recognized by major government regulatory

body, and implemented by suppliers and primes as well.

Establishing the Institute for Space Debris Prevention and Control (ISDPC)


The issue of space debris mitigation is not only a matter of political will but also of

access to skilled human resources which are rare outside major space agencies

and industry.

In 2013, the IAASS presented at the 50th COPUOS STSC session the concept of

setting up a non-profit organization (on the model of IAQG), as a collaborative

consortium of industry, open to the participation of experts from government

organizations, for implementing processes for verifying compliance with ISO space

debris standard. The Institute would also make available to all stakeholders in space

activity, whether large or small, expert assessments for safe space operations.

Conclusion


Future space governance should move away from classical model of separation of roles between

government regulatory bodies and industry, and move towards a closer collaboration.

The space industry should develop a notion of space safety and

sustainability as their own collective national and international

responsibility. Under the oversight of relevant regulatory bodies and with

the benefit of international cooperation, “industry should establish

specialized institutes, as industry created, independent, self-

policing entities aimed at developing, adopting, and enforcing

standards of excellence to ensure continuous safe access and

operational integrity of space operations”*.

* Paraphrase of the recommendation of the Presidential Committee that investigated the 2010 Deepwater

Horizon oil rig disaster in the Gulf of Mexico.

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Space Governance and Stakeholders Roles