Category Archives: Space

Interesting New Legislation

A bill has been introduced into the House to encourage private manned spaceflight, by clarifying the regulatory situation, and making more explicit government support for it. It’s numbered H.R. 3245. The text of the bill can be found here.

What it seems to do is the following:

1) It authorizes funding of about eleven million dollars per year to the Department of Transportation to support its regulatory activities, but more importantly, if I’m reading it correctly, it seems to reestablish the old Office of Commercial Space Transportation, which implies to me that it will be pulled out of the FAA (undoing one of the many dumb things that the Clinton administration did in this area) and having it once again report directly to the SecDOT. FAA-AST will be no more, and it will revert to OCST.

I infer that this is the purpose because they direct the SecDOT to “clearly distinguish the Department’s regulation of air commerce from its regulation of commercial human spaceflight, and focus the Department’s regulation of commercial human spaceflight activities on protecting the safety of the general public, while allowing spaceflight participants who have been trained and meet license-specific standards to assume an informed level of risk.” That implies to me that it will no longer be within the FAA.

This would presumably give the office more horsepower in its turf battles with FAA-AVR. Whether or not Patti Grace Smith will remain in charge of the office remains to be seen. She’s a Clinton administration holdover, and the Bush administration never replaced her, probably because it didn’t pay much attention to the office at the time, having other priorities. With the establishment of OCST, it may be an opportunity to force the issue of whether or not to put in someone actually vetted by this White House.

2) It rewords Section 70101 of Title 49 (Findings and Purposes of the DOT space activities) as follows:

It changes paragraph (3) from

new and innovative equipment and services are being sought, produced, and offered by entrepreneurs in telecommunications, information services, microgravity research, and remote sensing technologies;

to

“new and innovative equipment and services are being sought, produced, and offered by entrepreneurs in telecommunications, information services, microgravity research, human spaceflight, and remote sensing technologies;

and it changes paragraph (4) from

the private sector in the United States has the capability of developing and providing private satellite launching, reentry, and associated services that would complement the launching, reentry, and associated services now available from the United States Government;

to

the private sector in the United States has the capability of developing and providing private satellite space launching, reentry, and associated services that would complement the launching, reentry, and associated services now available from capabilities of the United States Government;

The effects are to make clear that human spaceflight is now to be considered as an area for private development, and that the government shouldn’t necessarily be making available (i.e., competing) its services.

3) They amend the Definitions per the following:

They add one: “crew” means an individual or individuals carried within a launch or reentry vehicle who performs a function necessary for the protection of public safety.

And they modify a few others. The paragraph that currently reads:

”payload” means an object that a person undertakes to place in outer space by means of a launch vehicle or reentry vehicle, including components of the vehicle specifically designed or adapted for that object.

would now read:

”payload” means an individual or an object that a person undertakes to place in or return from outer space by means of a launch vehicle or reentry vehicle, including components of the vehicle specifically designed or adapted for that individual or object.

After the paragraph:

”reentry vehicle” means a vehicle designed to return from Earth orbit or outer space to Earth, or a reusable launch vehicle designed to return from Earth orbit or outer space to Earth, substantially intact.

They would insert a new paragraph:

“spaceflight participant” means an individual who is not crew carried within a launch or reentry vehicle during a launch or reentry.

In other words, a passenger (and, perhaps, a flight attendant, since their function is to provide for the safety (and comfort) of the passengers, not the public).

After the paragraph:

”reentry vehicle” means a vehicle designed to return from Earth orbit or outer space to Earth, or a reusable launch vehicle designed to return from Earth orbit or outer space to Earth, substantially intact.

they would add the following definitions:

“suborbital rocket” means a rocket-propelled vehicle intended for flight on a suborbital trajectory whose thrust is greater than its lift for the majority of the powered portion of its flight.

“suborbital trajectory” means the intentional flight path of a launch vehicle, reentry vehicle, or any portion thereof, whose vacuum instantaneous impact point does not leave the surface of the Earth.

These are the definitions described earlier this year by FAA-AST representatives at the Space Access conference in Scottsdale.

They amend the definition of third parties:

”third party” means a person except –

(A) the United States Government or the Government’s contractors or subcontractors involved in launch services or reentry services;

(B) a licensee or transferee under this chapter;

(C) a licensee’s or transferee’s contractors, subcontractors, or customers involved in launch services or reentry services; or

(D) the customer’s contractors or subcontractors involved in launch services or reentry services.

to the following:

”third party” means a person except –

(A) the United States Government or the Government’s contractors or subcontractors involved in launch services or reentry services;

(B) a licensee or transferee under this chapter;

(C) a licensee’s or transferee’s contractors, subcontractors, or customers involved in launch services or reentry services; or

(D) the customer’s contractors or subcontractors involved in launch services or reentry services; and

(E) crew or spaceflight participants.

The effect of all of this is to formally recognize passengers in the law, something that was not contemplated under the original Commercial Space Launch Act passed in the mid 80s.

Now comes a more controversial, and potentially problematic change. In Section 70104, which describes licensing requirements, they add the following:

COMPLIANCE WITH SPACEFLIGHT PARTICIPANT REQUIREMENTS- The holder of a license under this chapter may launch or reenter a spaceflight participant only if–

(1) the spaceflight participant has received training and met medical or other standards specified in the license;

(2) the spaceflight participant is informed of the safety record of the launch or reentry vehicle type; and

(3) the launch or reentry vehicle is marked in a manner specified by the Secretary of Transportation which identifies it as a launch or reentry vehicle rather than an aircraft.

I understand the intention of this, and it’s a good one. They’re apparently trying to codify into law Patrick Collins’ and Peter Diamandis’ concept of “accredited space passenger.” This could potentially provide a work around for liability issues, using the analogue of a “qualified investor” by the SEC’s definition, to allow people to fly without placing too large a regulatory burden on fledgling spacelines.

The idea is that certain people could be accredited to accept what would certainly be a higher-risk ride than on an airline, and remove the need for the spacelines to come up with an unrealistically high reliability and certification (which, if it ever comes to pass, would be the equivalent of an IPO, in which anyone can buy stock, rather than just qualified investors).

The problem is that the language isn’t very specific, and seems to leave it up to DoT discretion as to what the training and medical standards will be, which means that what actually comes out of the process could be pretty onerous (particularly when Boeing and Lockmart’s lobbyists get done with it).

I haven’t had time to think about it enough to comment, but over at sci.space.policy, Gary Hudson has already expressed concern with this provision, and David Gump has the following thoughts:

“Regulation expands to fill the space available” is a physical law of government.

Regulators given a task will keep at it, until they hit a limit. If they’re regulating an existing industry, either the corporations or their customers will eventually push back when the regulations reach a tipping point. For our almost nonexistent industry, we have no substantive mass to push back with, so any regulatory train set in motion will likely continue going well beyond what we’d consider to be logical limits. So we have to be *very* careful what paths we start the regulators down.

The only safe task to set before FAA is disclosure (ala food labeling, or campaign contributions) so that anyone buying a flight is fully informed of the risk.

What’s not safe: enforceable medical standards and any “other” standard that might appear to be a good idea to the fine professionals at the FAA, whom I admire.

Why not medical standards: The medical conditions of the 500 or so previous space travelers are secret. NASA is obsessive about protecting all astronauts’ medical privacy. Yet, the only logical course for the FAA is to attempt to gain access to these very sensitive records, and then make its own judgments about what they mean. Rocket companies will *not* get to see them in detail and thus will *not* have any way to influence their interpretation.

So what standards will the FAA adopt? Only conditions that have failed to disqualify astronauts will fail to disqualify private passengers? What about a condition that’s OK for an astronaut who was 30, but the proposed private passenger is 60? Still OK? We all know that many of the private firms’ initial passengers will be older because they’ve accumulated the most money, and their grown children aren’t responsibilities anymore… yet older people take more pills and have more medical conditions. Do you want to be arguing with FAA doctors about the medical status of most of your passengers, based on a medical database you can’t examine yourself… while trying to equate the strains of a Shuttle or Apollo flight with whatever stresses you believe exist for your perhaps quite different vehicle?

Yikes!

So consider the above for the straight-forward issue of Medical Standards. Now consider what can happen if any “other” standard can be thrown into the vetting of passengers.

Full Disclosure for Informed Consent — that’s how it is done when testing risky new drugs, and it’s the only sane way to approach the issue of the government’s role in passenger space flight.

Yes. This will probably be the main area of contention of this legislation in the space community. I’m not sure how it will play out, but other than that, I’m fairly happy with the legislation as proposed. If nothing else, it will help to ease some of the regulatory uncertainty that has been holding back investment.

[Update on Sunday night]

As a result of talking to several people at this weekend’s Space Frontier Society conference, including Jim Muncy (former staffer for Congressman Rohrabacher, who was the principal sponsor of the bill, and who played a key role in drafting the legislation) most of my initial analysis has been borne out.

However, I was mistaken on one front. It was not the intent of the legislation to create “accredited passengers,” as I wrote above. Also, it’s clear to me now that the intent is not to privide the Department of Transportation with discretion to set or control the standards for either medical condition or training of passengers or crew–that is to be left up to the individual licensee. In support of this, it’s important to emphasize the wording of the change to the definition of “third parties” as described above.

The explicit exclusion of “spaceflight participants and crew” to the definition of third parties is much more significant than I had previously implied.

Under the original Commercial Space Launch Act (as perceived to be required by the 1967 Outer Space Treaty and 1972 Liability Convention) the Department of Transportation has no responsibility to ensure safety of payloads, or authority to deny a license on the basis that the launch may endanger them. It only has responsibility to protect uninvolved third parties on the ground.

By explicitly excluding passengers and crew from the category of third parties, the department is explicitly detached from responsibility for their safety. In so doing, it removes the danger that the clause about setting medical and training standards can be morphed into one establishing uniform standards in these areas, obviating previous concerns expressed above. The standards will be set by the individual licensee, and the only requirement for a license will be that those standards are adhered to by that licensee.

This interpretation was verified by Jay Garvin in Friday afternoon’s regulatory panel, in which he reiterated that FAA-AST has responsibility for only third-party safety, and does not have statutory authority to regulate the safety of passengers.

This language will thus provide flexibility to have different training and medical standards for different types of space transports. For example, a company that has a system with a 9-G entry will obviously have different medical standards than one with only a 3-G entry. Similarly, a company with a vertical takeoff/landing vehicle will have different crew training standards (e.g., helicopter experience) than one that employs horizontal takeoff/landing.

Some may be concerned by the fact that the government is not going to regulate the safety of passengers in this new industry, but it must be understood that if they were to attempt to provide the level of safety through regulation that the airline industry currently provides, the industry will be stillborn.

People die climbing Everest, people die rock climbing, people die sky diving, and people die scuba diving. This industry is simply too immature to impose unreasonable safety requirements on it–the providers don’t yet know exactly how to do it, and the regulators don’t either, and attempting to do so would raise costs so high that it won’t be possible for anyone, even those willing to take the risk, to afford it. This is truly the best solution at this time.

In addition, there’s a benefit to the providers, in that they will be able to turn away potentially risky passengers, on the grounds that they don’t meet their licensed standards as required by the DoT. This will minimize the danger of some potential lawsuits (e.g., oversize people who demand single-seat pricing on airlines, even though they may take up two seats).

To summarize, the bill does the following:

  • It establishes and defines the categories of suborbital vehicles and suborbital flight.
  • It establishes the category of “spaceflight participant” (read “passenger”) as a legitimate and legal payload of private space transports, and encourages the notion that they can be such cargo.
  • It categorizes them as non-third parties (they’re actually second parties), rendering them beyond the statutory reach of the DoT for now, for the purposes of ensuring safety (and thus keeping the department’s hands off of vehicle regulation for this purpose).
  • It requires the Department of Transportation to clearly separate the regulation of space transports from air transports, which can reasonably be interpreted as releasing the FAA from any responsibility for doing so and moving it to a different office or agency within the department.
  • It requires licensees to stipulate medical and training standards for passengers and crew, allowing them to statutorily enforce such standards, while not laying down generic federal requirements.

Overall, while the language could perhaps be tweaked to make things a little more explicit, I think that this proposed legislation is a major step forward in clarifying the regulatory situation, and I would encourage all who want to further enable our nation’s and species’ future in space to lobby their congressional representatives to sponsor and support it.

From The Horse’s Mouth

Jeff Foust reports on Burt Rutan’s presentation at the annual symposium of the Society of Experimental Test Pilots last week in LA. Worth a read if you want to get the latest scoop on SpaceShipOne. He saves the most intriguing bit for last:

The final slide of the presentation, put on the screen during a brief question-and-answer session, showed what appeared to be a scaled-up version of the SS1 (see photo). A cutaway showed the cabin, with one pilot and ten passengers (arranged in three rows of three people with the tenth person floating above them.) The illustration was simply captioned ?A Future Space Tourism Ride??

From The Horse’s Mouth

Jeff Foust reports on Burt Rutan’s presentation at the annual symposium of the Society of Experimental Test Pilots last week in LA. Worth a read if you want to get the latest scoop on SpaceShipOne. He saves the most intriguing bit for last:

The final slide of the presentation, put on the screen during a brief question-and-answer session, showed what appeared to be a scaled-up version of the SS1 (see photo). A cutaway showed the cabin, with one pilot and ten passengers (arranged in three rows of three people with the tenth person floating above them.) The illustration was simply captioned ?A Future Space Tourism Ride??

From The Horse’s Mouth

Jeff Foust reports on Burt Rutan’s presentation at the annual symposium of the Society of Experimental Test Pilots last week in LA. Worth a read if you want to get the latest scoop on SpaceShipOne. He saves the most intriguing bit for last:

The final slide of the presentation, put on the screen during a brief question-and-answer session, showed what appeared to be a scaled-up version of the SS1 (see photo). A cutaway showed the cabin, with one pilot and ten passengers (arranged in three rows of three people with the tenth person floating above them.) The illustration was simply captioned ?A Future Space Tourism Ride??

Living Down To Expectations

When we last left Rocketman, he was accusing Gregg Maryniak of comparing launch vehicles to submersibles, an accusation that, knowing Gregg, I found quite unlikely.

He has since had an email discussion with Gregg, and clarified the issue. I found this little bit of Gregg’s response interesting, because it wasn’t something to which I’d previously (or at least recently) given much explicit thought.

Bottom line is that space stuff costs perhaps 500 times as much to develop historically as (very challenging) undersea stuff. Why? It may be largely because of the expectation that it should (based on the history of governments racing each other without regard to normal engineering cost contraints.) When I speak to big audiences of traditional government space program engineers and program managers I usually pray that one of them will ask me: “You mean to say that mere expectations can be cost drivers–ridiculous”…to which I say, I have two words for them….”stock market.”

Is Gregg right? Is space hardware and operations expensive because we expect it to be?

There’s actually quite a bit of evidence that it is.

Most space contracts, particularly government contracts are cost plus fixed fee. This means that the contractors are reimbursed for the actual costs of executing the contract, as reported by them, plus some amount for profit (typically a few percent of the contract value). This is because high-technology research and development is recognized to be high risk–that the schedule might slip, or the costs be greater than originally estimated, and few if any private companies
are willing to absorb those costs, and NASA knows that none would bid on any other basis.

The problem with this, of course, is that it skews incentives in a way that are bad for the taxpayer (though not necessarily for the true constituencies of the space program–the contractors themselves, and the congresspeople in whose districts the contractors employ people). Perversely, the more they spend, the more they earn. There are occasionally attempts to mitigate this by putting in bonuses for hitting cost targets, and penalties for missing schedules or overrunning the budget, but they’re largely ineffective, at least judging by the space station program.

But there’s a more pernicious result of this, that’s less often considered. In order for NASA to project the cost of the contract, they have to have a way of estimating the costs, even if it’s something that may have never been done before. The way they (and the contractors) typically do this is called parametric cost analysis. They have cost models that are built up by examining many past programs, and incorporating the cost and schedule data from those programs. The models might use factors such as complexity (which is hard to measure), weight, technology level, and so on. The hope is that a good cost estimator can come up with a valid estimate for the program cost and schedule, based on similar efforts that have been performed in the past.

One problem with this is that it’s more art than science, and heavily dependent on the assumptions that the modeler uses. Another problem, of course, is that reinforces notions of how expensive things will be, because by definition, it’s based on how expensive things were in the past. It doesn’t provide any way to model true innovation. In addition, because almost all of the experience comes from government programs, the data base for private space activities is very sparse, so they don’t have any way of modeling that with any degree of credibility. And it turns even government programs, given the right team and incentives, can beat the estimates. As an example, consider the DC-X program:

Prior to letting the DC-X contract our program office conducted a cost estimating study. We used three models, one developed internally, one used by the US Air Force and one from NASA. The results were that our cost estimate based on the rapid program assumptions I described earlier and projected a cost between $60 and $70 million, the Air Force model using standard aerospace procurement practices produced an estimate of $365 million, the NASA model based on highly technology development based shuttle program experience projected the program would cost over $600 million. The actual DC-X program cost through the first test series came in around $65 million.

In other words, they beat the conventional Air Force costing model by a factor of more than five, and its NASA equivalent by almost an order of magnitude, or factor of ten.

Sadly, here’s the process (slightly oversimplified). NASA comes up with a program idea. They come up with a cost estimate for it. They request a budget. If Congress authorizes it, they put out a procurement for that budget target. The contractors write their proposals, and then come up with their own cost estimates that magically, and almost invariably turn out to be close to what NASA has money for. And thus the expensive game is perpetuated.

But as one more example of how such estimates and quotes can be voodoo, let me relate a story (possibly apocryphal, but it’s certainly believable to anyone with experience in the business) that was told to me by a program manager from the seventies. In the process of submitting a proposal, a small, almost insignificant typo found its way into the final version as delivered to the customer. It was a decimal point, misplaced one place to the right, resulting in a bid for that part of the program ten times too high, relative to the contractor’s internal estimate.

The contractor was downselected for a Best And Final Offer, which is an opportunity to negotiate a little bit. The contractor fully expected to be raked over the coals for their outrageously high bid (I think that it was something like ten million dollars, when it should have been one), and they weren’t disappointed. The NASA contracting officer excoriated them, calling them crooks and cheats, and other names not mentionable in a family web site, and finally finished up his lecture with the words, “…and we’re not going to give you a dime over nine million!”

And of course, the outraged response from the contractors’ representatives (as they sighed with relief) was, “But we can’t do it for that!”

Farewell To A Space Probe

Galileo (the spacecraft, not the scientist) is going to plunge into Jupiter’s atmosphere tomorrow, ending its many-year exploration of that planet and its many moons. NASA is deliberately dropping it into the Jovian atmosphere in order to prevent it from accidentally hitting one of the moons, such as Europa, which may harbor life, and thereby contaminate that body with earth life that may have somehow survived the many years in deep space and Jupiter’s intense radiation fields.

This weblog has a warm feeling for the spacecraft, which had a very hard life. The picture of the earth and moon in the banner was taken by it on one of its gravity-sling encounters, in which it stole a little momentum from the earth-moon system to augment its trip to the gas giant. In its honor, I’m displaying it in this post in more detail.

I don’t like to anthropomorphize spacecraft, but it was a doughty explorer, and despite the rocky start to the mission, delivered a wealth of new information about our system’s largest planet and its satellites. May it rest in peace.

[Thanks to my web designer Bill Simon for the heads up]

Cheap Satellites Follow Up

Rocketman has a post on the X-Prize and related subjects that’s worth reading, but there are a couple problems with it.

This is the most egregious:

The difference in energy required for a vehicle to reach the 100 mile altitude necessary to achieve orbit is ~25 times greater than the energy necessary to reach an altitude of 50 miles (I leave it as an exercise for the readers to figure out the difference in energy necessary between 62.5 and 100 miles).

This makes no sense at all. The difference in altitude between 50 and a hundred miles is, well, fifty miles. It’s merely doubled, so it makes no sense that it would be twenty five times the energy.

The problem of course, is that there are two components to energy–the specific potential energy as represented by the altitude (approximated as gravity times the altitude), and the kinetic energy, corresponding to the velocity (half the velocity squared). By ignoring the latter, this statement comes out completely garbled (and the exercise left for the readers is utterly meaningless, and would be frustrating to any who attempted it). Energy is a combination of both altitude and velocity, and the big problem in getting into orbit isn’t the former, but the latter.

Orbit is harder because it has go faster, not because it has to go higher. X-Prize is probably achievable at Mach three or four (say, a couple thousand miles an hour), and getting to a hundred miles wouldn’t require much more energy. Orbit requires seventeen thousand miles an hour–that’s the real killer.

He makes another point that’s more arguable (as opposed to physical nonsense), and I’ll argue it, as I did in last night’s post and today’s Fox column.

The statement that the “‘harsh environment’ of space was less harsh than that imposed by the ocean on the submersible” is just silly. Deep Rover operates in the ocean at a maximum depth of 1000 meters (3280 ft). At that depth, you are surrounded by water that is at ~40 degrees F and ~120 PSI. In space you are in a vacuum and your vehicle is exposed to direct solar energy that heats up one side of the vehicle and the vacuum of space that cools off the other.

The temperature extremes that exist in space create some difficult engineering problems because of the differences in thermal contraction and expansion that occurs between dissimilar materials. I have had to deal with these problems in my designs, and it is not trivial to engineer effective solutions.

Unlike vehicles that operate in salt water, the choice of materials that can be used in space is extremely limited. Most common materials get brittle at cold temperatures, and they also outgas in a vacuum, which changes their material properties. Some materials have problems with salt water, but there are many common materials that can be used under the conditions Deep Rover operates at.

But the biggest difference between a submersible and a spacecraft is that submersibles do not have to fly. You can afford to have relatively large factors of safety and, if necessary, redundant components in a submersible because weight is not a big issue. Also, spacecraft are subjected to tremendous dynamic and acoustic vibrations during launch, vibrations submersible never see. Designing and testing components to handle the vibrations of launch is again not a trivial problem (I speak from experience on this as well).

No matter what Maryniak would like to believe, space is an extremely harsh environment to design for. It also is not cheap to test components to determine how they will handle that environment. You cannot just sail out to deep water and drop your vehicle in the ocean to test it like you can with a submersible. Environmental chambers with liquid nitrogen ?cold walls,? large halogen lamps and huge vacuum pumps are needed to conduct these tests. And even the largest of these chambers is incapable of testing a complete launch vehicle, so components have to be tested individually.

They’re both harsh environments–but they’re different kinds of harsh. The marine environment is extremely corrosive, and it’s much more difficult, from a structural standpoint, to deal with many atmospheres of positive pressure (the deep sea) than a single atmosphere of negative pressure (the vacuum of space). Yes, space has radiation and temperature extremes that the ocean doesn’t, but both environments are harsh. For example, the choice of materials that can operate in salt water are limited as well.

Many of the implications of expensive launch are subtle, but they validate Gregg’s (and my) point.

Every objection that he has would be obviated by cheap launch, a point with which even he agrees at the end. If launch were cheap, you could afford heavier satellites, because the additional mass wouldn’t be so expensive. If launch were cheap, you could afford more redundancy. Cheap launch systems will have relatively smooth rides (because they’ll have to in order to be reliable and affordably reusable) so the launch environment won’t be an issue. Cheap launch implies affordable test facilities on orbit, so the components can be tested more easily.

So I’m not sure what his point is in arguing with Gregg on this issue.

Non Sequitur

Gregg Easterbrook gives a little history of the Biosphere venture, and how Columbia University has finally ended its affiliation with it. But in the process, he makes a glib comment about the affordability of a Mars mission:

It seems certain that as the space shuttle debate continues, some prominent person will advocate the bold new adventure of a trip to Mars. When someone advocates that, this blog will demolish the idea in detail. Here’s a quick preview. Last week the Wall Street Journal ran a letter to the editor blithely asserting that colonization of Mars could be accomplished “easily and cheaply.” The Russian rocket manufacturer Energia recently estimated that the hardware for a stripped-down manned mission to Mars would weigh a minimum of 600 tons in low-earth orbit. At current space shuttle prices, it costs $15 billion to place 600 tons in low-earth orbit. That’s just the initial launch cost for a stripped-down high-risk flight with a couple of people–spaceship and supplies are extra.

Sorry, Gregg, this does not compute. Why would you take the word of Energia for the mass of a Mars mission, and then make the insane assumption that it would be delivered with a Shuttle (probably the most expensive launch system on the planet, and one to soon go out of business, one way or another)?

If you’re going to go with Russian quotes, use Russian launch prices. Of course, any rational person, contemplating fifteen billion dollars in launch costs, might consider spending that money instead on reducing launch costs…

Dang

Don’t you just hate it when your multi-million-dollar satellite falls over and breaks?

Way to go, Lockmart…

Keith Cowing over at NASA Watch provides the following reader comment:

“It turns out that the POES group at GSFC had a training session for an ISO 9000 audit in July, 2003. Here’s the link to the briefing slides.

The accident appears to be LockMart’s fault, but once again we see the benefits of an ISO 9000 program…”