Certifying Commercial Space Stations

NASA just put out an RFI. This concerns me a little: “NASA is currently developing requirements for commercially owned and operated destinations that would support NASA, international, and private astronauts safely in low-Earth orbit.”

NASA can certify facilities for NASA support (as it did for commercial crew), but it has no business saying what safety requirements should be for use by international or private astronauts. My comment will be that different individuals will have different risk tolerances, and that commercial facilities should be allowed to establish their own requirements for their own customers.

[Afternoon update]

From the document: “NASA intends to be one of many users of the provider’s CLD. NASA will only levy requirements on the CLD service to ensure the safety of the NASA or -NASA sponsored crewmembers. However, for CLD provider services with their other customers, NASA will need to have Insight to the provider’s activities to ensure that these do not create an elevated risk that could impact the NASA or NASA sponsored crewmembers.”

CLD is Commercial LEO Destination. I wonder why they capitalized “insight”? I assume by this that they mean that if NASA is going to be using the facility, NASA would want to know who else is and what they are doing, so they can assess whether that activity is consistent with NASA’s needs for safety assurance for their own employees. That’s not unreasonable (we had to do that sort of thing in payload integration for the Shuttle to ensure that a payload wouldn’t break an Orbiter), but it will be an inhibitor for facilities to welcome NASA aboard. But by my reading, this will only apply to facilities that want NASA as a customer, and those that can find markets without NASA will be able to have their own safety requirements independent of anything NASA wants. Both Phil McAlister and Kathy Lueders have read my book, and are aware of the danger of overspecifying S&MA requirements, but they also have to be cognizant of the politics.

44 thoughts on “Certifying Commercial Space Stations”

  1. On the other hand, the federal government seems to regulate everything these days and giving jurisdiction to NASA might be preferable to the FAA or whoever else wants it.

      1. I expect you addressed this in your book, which I have been putting off reading since you first announced it, but when regulation comes for off-planet activities what agency do you think would be the least of evils?

      2. They would demand a certain amount of ‘muslim out reach’ and the correct pronouns…

        Around page 4225 they would get to the space technical requirements.

    1. It will probably end up in the department of education. Unless you can think of a worse place for it.

        1. I worked for FAA/AST for 10 years. Our paychecks came from the Department of the Interior. No one was ever able to explain why…

          1. My dad was with USGS and BuMines from the time he got out of the Army in the 40s until he retired in the 80s. As near as I can tell, if any part of something involves the interior of the US, it can fall within the purview of DoI.

          2. if any part of something involves the interior of the US, it can fall within the purview of DoI.

            So relative to Space, this reminds me of the old Jose Jimenez Reluctant Astronaut joke (paraphrasing):

            Q: “So tell us Mr. Jimenez, for our viewers and listeners, what exactly has the Space Agency planned for your recovery and landing mechanism?”
            A: “Nevada”

  2. If I am a prospective customer I can certainly give you a list of requirements your product or facility would have to meet before I would consider utilizing it. It sounds like that’s what NASA is doing. They are not a regulatory agency, but they are a potential anchor tenant. Vendors can choose to target other customers with different requirements if they wish. But they would need to meet NASA’s requirements if they want the agency as a customer. I see nothing wrong with that.

    1. I see nothing wrong with it, either. I’m just saying that if I want to build a commercial facility and I don’t care whether or not NASA is a customer, NASA should have nothing to say about my facility design.

      1. I think Musk should make falcon-9 second stage taller, put floors and stuff in it. Launch it, and spin it for experimental, artificial Mars gravity station.
        Then send crew in dragon capsule, to outfit and operate it. And if 10 meter radius is too short, attach the capsule to it with rope, and get taller radius of spin- and see what radius a stick artificial gravity station, needs.
        Most cost is second stage and dragon trips to it.
        Musk’s basic cost is 30 million and 30 million per crew plus adding to 5 times limit one can use a dragon capsule.

        1. F9 stages are around 3m diameter. And the research has been done – even Starship’s 9m diameter is too small for practical spin-gravity.

          1. “….The Gemini 11 spacecraft then undocked with the GATV in order to begin experiments with the rope tether configuration. At a mission elapsed time of 50 hours, 13 minutes the Gemini 11 spacecraft was slowly maneuvered to allow it and the tethered GATV to slowly rotate around one another.

            Although movement of the tethered spacecraft was erratic at first, the motion stabilized about 20 minutes after the rotation maneuver was begun. The rotation rate was then increased, and again the motion stabilized relatively quickly.

            It was a challenge for the astronauts to keep the rope tether tight between the spacecraft. It remained stiff, but moved somewhat like a jump rope as the spacecraft rotated around one another.

            This motion between the spacecraft caused artificial gravity to be created in space for the first time, although the gravitational force created was only 1.5 one-thousandths that of Earth.”
            Or as described by wiki:
            The Gemini 11 mission attempted to produce artificial gravity by rotating the capsule around the Agena Target Vehicle to which it was attached by a 36-meter tether. They were able to generate a small amount of artificial gravity, about 0.00015 g, by firing their side thrusters to slowly rotate the combined craft like a slow-motion pair of bolas.[6] The resultant force was too small to be felt by either astronaut, but objects were observed moving towards the “floor” of the capsule.

            The Gemini 8 mission achieved artificial gravity for a few minutes. This, however, was due to an electrical fault causing continuous firing of one thruster. The acceleration forces upon the crew were high (around 4 g), and the mission had to be urgently terminated.”

            I am talking a “stick” artificial gravity station or also called baton.
            I would call it a pipe shape or long cylinder.
            So the second stage is:
            Length 13.8 m
            Diameter 3.7 m

            And add 10 meter length cylinder which also 3.7 or 12 feet in diameter.

            For reference the Agena Target Vehicle:
            5 feet (1.52 m) diameter
            26 feet (7.92 m) long
            Launch mass 18,030–18,100 pounds (8,180–8,210 kg)
            Dry mass 4,012–4,085 pounds (1,820–1,853 kg)
            So dry mass of falcon-9 is 4100 kg and the gross mass is 10 meter section would about 10 tonnes which includes few tons of water.
            The total stick length is +20 meters or radius of spin of about 10 meters.
            And like Gemini 11 mission, you attach rope to it and a dragon capsule which brings crew up to and docks with it. And target artificial gravity is at most Mars gravity so rope would need to strong enough to withstand more than 1/3 the mass of gross weight [earth weight] of dragon capsule. But first you try out the Stick by itself- and it’s not long enough, then have rope connecting Dragon Capsule and redo the Gemini 11 mission [and have longer rope].

          2. gbaike – what’s interesting about this proposal is that you dedicate two dragon capsules to make a gravity lab. This would be a good end-of-life usage of dragons once starship goes on-line with little additional cost. Starship could take over the ferry to ISS missions or even replace ISS altogether. Problem with Dragon however is endurance. You’d need to run the gravity lab for at least a year to see what effects low g might have on the human body. Perhaps even longer.

          3. Let’s see. You take 8 baton stations, cut them in half and mount them on and 16-port hub, then connect the 16 labs with pressurized bridge-tunnels, and… oh, wait.

          4. –gbaike – what’s interesting about this proposal is that you dedicate two dragon capsules to make a gravity lab. This would be a good end-of-life usage of dragons once starship goes on-line with little additional cost.–

            This fairly old idea, but just thought of that aspect- or soon, Musk could have much them, if not already.
            But not using two dragon capsules, though could send a lot dragon capsules to it.
            Or it’s experimental- or it might work.
            The idea station is payload of Falcon -9 and the Falcon-9 stage is part of station, but if works, at some point one refuel the Falcon-9 second stage and put into higher orbit {or Venus or Mars. The part attach rope to dragon and station, would to find out, how two one needs it.
            If 50 meter radius is needed, then one knows that 2 starship, attached end to end, would work. And 50 meter radius doesn’t work, then one have modify, but 2 starship and a rope, needs very strong rope.

          5. “…would to find out, how two one needs it.”
            Using rope is also to test, how tall it needs to be. Or you find out, that 10 meter radius just doesn’t work.
            Or NASA trying to see is very short radius can work- this is the same, only it 10 meters [And NASA doing this much as far as I know- and also not doing it on Earth surface- in 1 gee gravity. Or would say NASA not testing it and should be done in orbit.

          6. –William Barton
            May 11, 2022 at 9:11 AM

            Let’s see. You take 8 baton stations, cut them in half and mount them on and 16-port hub, then connect the 16 labs with pressurized bridge-tunnels, and… oh, wait.–

            You have a wheel.
            Unless you like to ride a bike- I see little advantage to wheel space station.
            You have the docking in the center- but you also do with that a baton station.
            The wheel would always spin.
            It seem with baton, you would at times, stop the spin. You could also go somewhere.
            But main thing is wheel isn’t practical, yet also tend to be thought of as only way to do artificial gravity.
            And we have experiment- if experiment with sticks, we might eventually do wheels.

    2. Giving NASA the authority to levy requirements without any consideration for cost is a formula of disaster. They could and likely would end up driving the costs higher than the station’s orbit. NASA doesn’t get to levy requirements on the airliners their employees ride on or the hotels where they stay on business trips (in terms of building costs or airworthiness requirements). Why should commercial space stations be different? Admittedly, the builders of those stations should take advantage of NASA’s knowledge base when designing and building their stations.

      1. If NASA thought that some hotels and airliners were unsafe, I’m sure they would impose requirements. But hotels and airliners have to meet regulatory requirements of other agencies and the pressures of competition, so they are generally safe. Businesses certainly do consider the safety of their employees when considering when and how to send them to dangerous places.

        I think the relevant factor here is that NASA’s primary purpose in choosing to patronize private space stations is to catalyze the development of a commercial human spaceflight economy, which means they are going to need to balance safety and cost in setting their requirements. We’ll just have to see how well they do that.

        1. When Boeing or Airbus is designing a new airliner, NASA doesn’t get to come in and levy additional requirements on the planes before letting their employees ride on them. The planes have to meet the certification requirements of the FAA and other national aviation agencies. The ability of an outside party to come in and levy requirements without any responsibility to compensate for the higher costs does nothing but drive up costs. This isn’t a theoretical point. You can easily find examples in everything the government regulates.

          1. The problem here is that there is no certification authority for commercial space facilities. That would require legislation.
            The problem here is that such legislation would more likely than not put NASA in charge. The issue with that is that NASA doesn’t have a good track record when it comes to cost consciousness of major space programs. It’s unclear to me that NASA has the requisite skill set to deliver what it’d be tasked with. Or worse, like Shuttle, only partially deliver, while crippling the rest.

          2. I don’t agree that that would be the most likely outcome.
            Well I hope you are right. But can you point to a counter-example case in point? This would be novel for NASA. Let’s hope they don’t approach it programmatically like they did Apollo. But that is, after all, their institutional knowledge.
            I’d like to understand why you think this way. Personal knowledge from the players themselves? Feel free to bump it on the OP if you like.

          3. NASA has never been a regulatory agency. If there is legislation proposed to regulate space facilities, there will be a turf war between Commerce and Transportation, but NASA won’t be a player.

          4. there will be a turf war between Commerce and Transportation, but NASA won’t be a player.
            I disagree. Often politicians, like flowing water, pick the path of least resistance. Putting NASA in charge avoids the turf war. All they have to do is just reference that magic word: “Space”. It’s not in the name of either Commerce or Transportation, or even Interior.

          5. That’s not how it happened in 1984. It’s not how it will happen this time. DOT currently regulates space transportation, and Commerce regulates space imaging, and has an Office of Space Commerce (that Rich DalBello just became head of). It would go to one of them. An independent agency with no history of having regulatory authority is not going to be given it now.

          6. Commerce or Transportation. Hmm. But we are talking about codes for space structures. Why not NIST for building standards? Or maybe if Transportation wins the war use them for consultancy on regulations? But again why not NASA instead of NIST? So ring around the rosy guess who’s back?

        2. I guess there is CCDev. Parts of NASA did a great job there, others not so much, MSFC I’m looking at you. Also including Congress, esp. the Senate.

    1. In the realm of NASA RFPs contracting for commercial services, “insight” is a defined term of art. Commercial providers don’t want NASA picking over their proprietary secret sauce, but NASA equally doesn’t want to buy from providers whose answer to safety-critical questions is “trust us”. So the RFPs specify what kind of technical information contractors shall provide, and further identify certain items for which NASA requires “insight” (implementation awareness, but contractor retains design authority) or sometimes the more intrusive “oversight” (details and NASA sign-off).

  3. I am happy to be exposed to people with pedantic knowledge of how the federal government operates and it always strikes me that our government is too big, too complicated, too unaccountable, and too meddlesome. Who is it that has to deal with any of this and thinks we need more?

    “My comment will be that different individuals will have different risk tolerances, and that commercial facilities should be allowed to establish their own requirements for their own customers.”

    This is rational but no one will be allowed to set all of their own requirements, at least not for long. Here is the place where libertarianism conflicts with conservatism and the belief that some regulation is necessary. Later we will be in the place where conservatism conflicts with tyranny and the belief that while some regulation is certainly necessary, if we look close, we will find that every decision must be influenced by government, especially the mundane.

  4. The Commercial LEO station developers are in a tough spot, though: They not only need NASA as an achor tenant at this point, they also need NASA’s imprimatur to open up venture capital and customer wallets: people *will* feel more willing to invest in, and make use of, a piece of hardware that has the NASA Safe Housekeeping Seal of Approval. Rightly or not.

    The day is coming when a station is built that doesn’t pursue NASA as a client. (I hope I live to see it.) But I don’t think any of the current four efforts is willing to try that glove on for size just yet.

  5. Things will inevitably fall off of stations, even if it’s only tiny screws or other small parts by accident. If the station is rotating to generate artificial gravity then they will go wandering off into other orbits and eventually, possibly, hit something. The probability is very small but not zero. So it will happen Other organizations have an interest in minimizing the chance of this kind of catastrophe and even potential tenants like NASA have an interest in it to minimize risk of being sued. But nobody’s really very interested in trying to figure out what can mitigate or minimize this.

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