Wayne Hale thinks that he posted in haste. But the problem remains:
Now I have re-read it and have some additional thoughts. It is clear that this is a vast scaling down from the requirements that say, Ares-1 and Orion had. And many of the paragraphs say that the specifications and standards can be replaced with alternatives, or with other standards that “meet the intent of” spec such and such. That is good. And to the casual reader that sounds like a big change. Unfortunately, it is not. Having to prove that an alternative standard is just as good as the standard NASA listed is an uphill battle. The adjudicator will be some GS-13 who has lived with one standard his whole career, understands it thoroughly, probably sat on the technical committee that wrote it, and loves it. Proving that his baby is ugly is going to be time consuming, and probably fruitless. I speak from sad experience.
So, what is my recommendation? Simple. Do what the Launch Services Program does: require that providers HAVE standards and follow them – don’t make them pick particular processes or standards, let the flexible, nimble, [your adjective here] commercial firms pick what suits their business best. As long as they have standards and stick to them – that is what we should require.
I would note that this is the FAA’s approach for launch licensing of passenger flights, until the industry matures sufficiently to develop certification standards (a point in time that is many years off).