Lori Garver's FAA Speech On Space Commerce

If they really want to promote the growth of private commercial manned space flight then:

1. Start fully funding the development of a HLV so that we with one single launch we can place large customized space stations into orbits that are advantageous to American companies. The orbit of the ISS puts Americans at a competitive disadvantage in relation to the Russian company Energia.

2. Create a non-taxpayer subsidized manned spaceflight market by creating a space lotto system where hundreds of millions of Americans and billions of people around the world can purchase $1 lotto tickets for a chance to fly to a space station aboard an American private commercial space vehicle.

3. Develop a directly space shuttle expendable SSTO booster (Jupiter without the SRBs but with 6 SSME) to launch at least 20 tonnes into orbit. This would be a vehicle that would be advantageous to NASA, the military, and private industry since it would be the simplest and safest booster ever developed and could probably launched on land and at sea.

With 2 SRBs, this core vehicle would become the classic Jupiter HLV. So by developing just one core vehicle we could develop an HLV for NASA and a sub-HLV (without the SRBs) for commercial spaceflight.

Marcel F. Williams

This is more "talk" that some will use to prove theie theories that we are embarking on bold and game changing adventures.

Unfortunately, its just talk.

"Space tourism is a catalyst that has sparked a whole new industry of passenger-carrying spacecraft" - Whole new industry? I see one passenger-carrying spacecraft out there that has yet to fly and that is from Scaled Composites and it will be suborbital.

"This new direction may have been suggested as the preferred option by the Augustine Commission" - Actually the Augustine Commission report says "Recurring budget ambiguities and reductions and redirections of policy, coupled with the high fixed-cost structure of NASA, have not optimized the return on that investment" as the report calls for program stability. This budget just adds to the ambiguities and redirections.

The report also states that NASA should "in general encourage more engagement by commercial providers, allocating to them tasks and responsibilities that are consistent with their strengths." Not kill existing programs at the expense of this encouragement.

Lori states: "but the decision was made by the President, with the full support of NASA's leadership" It is my understanding that no NASA Center leadership knew what the budget plan was until it was announced to the public.

In another statement: "We had a space transportation system to the ISS being developed (with 10's of Billions more to be invested) that would not have gotten to the ISS before its planned de-orbit." This is such a useless argument. The obvious solution is to extend the station, which they did, then they cancelled the program that would get them there for the sake of commercial incentives that are based on hope.

By the way, has Ms. Garver actually done anything that other than consult with "Senior Executives." I can't even find details of her most recent claim to fame as president of Capital Space, LLC.

Great speech, Ms Garver!

If I was not aware Obama is a democrat with very liberal ideas, I would have thought this proposal came from a republican...

Private industry instead of government bureaucracy? Wow! No wonder Newt Gingrich endorsed it.

I can hear the Constellation folks screaming now:
"...but, but, Ares-1 was designed as the safest vehicle ever built"

The "man rating" argument is so pathetic. I guarantee Atlas, Delta and Falcon can all be man-rated in due time. If that Ares-1 is so great, why don't you join in the competition and get a piece of the pie?

It makes too much sense to me. Go NASA!

Marcel F. Williams all your points are wrong and do not promote the growth of commercial space flight (it is more than just manned or private)

1. Funding the development of an HLV is not commercial

2. More government stations are not needed. The ISS needs to be fully utilized.

3. The ISS orbit does not put the US companies at the disadvantage. They can get to the orbit even easier than the Russians. Where is your proof otherwise?

4, An HLV is not needed for space stations. Bigelow stations can be lifted by EELV's. this is a commercial station which is the point of commercial spaceflight. Not NASA flying more stations.

5. How many times do we have to tell you this. NASA developing a launcher is not commercial. The builder of the launch vehicle is the operation. So explain this, how is one launch vehicle is advantageous to private industry, when there is only one company operating it. Also, the DOD does not need another launch vehicle.

6 Also, an expendable SSTO with 6 SSMEs would be more expensive than current vehicle.

It's all very interesting, especially the bit about creating a 'portfolio' of several potential providers. However, right now, there is just one destination: the ISS. At most, we are talking about perhaps 2 flights a year at the maximum. Does anyone think that the combined CRS and commercial crew business will be enough to sustain more than two commercial providers?

Seriously, when the time comes to start thinking about BEO again, I will be very surprised if there is not just one commercial crewed spaceflight provider in the US operating a monopoly and almost entirely dependent on Federal cash to survive... Somewhat similar to now, in fact, except that the NASA name won't be anything to do with it.

Thanks Charlie and Lori for doing such a good job. It takes guts to lead change and usher in new paradigms.

Whole new industry? I see one passenger-carrying spacecraft out there that has yet to fly and that is from Scaled Composites and it will be suborbital.

Did I then imagine the flights of Dennis Tito, Richard Garriott, Ms. Ansari, and others? I must have.

Actually the Augustine Commission report says "Recurring budget ambiguities and reductions and redirections of policy, coupled with the high fixed-cost structure of NASA, have not optimized the return on that investment" as the report calls for program stability. This budget just adds to the ambiguities and redirections.

It gets rid of the high fixed costs, and seeks to end the ambiguities by creating a sustainable spaceflight industry. Constellation didn't.

The report also states that NASA should "in general encourage more engagement by commercial providers, allocating to them tasks and responsibilities that are consistent with their strengths." Not kill existing programs at the expense of this encouragement.

Of course, when the existing program is inhibiting the development of the commercial providers, you must consider the idea killing off the program

This is such a useless argument. The obvious solution is to extend the station, which they did, then they cancelled the program that would get them there for the sake of commercial incentives that are based on hope.

"I guarantee Atlas, Delta and Falcon can all be man-rated in due time."

It's that due time that concerns me. Atlas and Delta have some history behind them, Falcon not much.

What concerns me most is the starting over apparently of the spacecraft. Developing this and performing the required qualification tests (unless we are letting these private companies be reckless with human lives) takes time. For a new company, more so.

It's easy to make a claim and those in support of commercial space flight are giving them a free ride and not challenging them to back up these claims.

"1. Funding the development of an HLV is not commercial"

Neither is the ISS. But being able to launch multiple space stations will create a lot more traffic into space than the ISS ever will. In fact, the ISS currently bans tourist.

"2. More government stations are not needed. The ISS needs to be fully utilized."

The ISS is a titanic boondoggle. There's no logical reason for a titanic centralized space station that can accommodate only 6 people. Launching multiple space stations could accommodate dozens of scientist and potentially hundreds of tourist annually.

"3. The ISS orbit does not put the US companies at the disadvantage. They can get to the orbit even easier than the Russians. Where is your proof otherwise?"

http://www.astrosociety.org/education/publications/tnl/34/space2.html

"4, An HLV is not needed for space stations. Bigelow stations can be lifted by EELV's. this is a commercial station which is the point of commercial spaceflight. Not NASA flying more stations."

An Delta 4 heavy can only launch a 25 tonne space station into LEO. A Jupiter HLV could launch a 100 tonne space station into LEO.

"5. How many times do we have to tell you this. NASA developing a launcher is not commercial. The builder of the launch vehicle is the operation. So explain this, how is one launch vehicle is advantageous to private industry, when there is only one company operating it. Also, the DOD does not need another launch vehicle."

Actually, NASA buys its launch vehicles from private industry. And other private companys would do the same. In fact, there was some interest from private companies in purchasing their own space shuttles until it was finally realized that the shuttle was too large to be an efficient people shuttle, too small to be an efficient heavy lift vehicle and flew too infrequently to significantly lower cost.

"6 Also, an expendable SSTO with 6 SSMEs would be more expensive than current vehicle."

There are currently no expendable SSME. That's the core of the problem. There are no mass produced SSME. And space travel will always be expensive as long as the demand for rocket launches remains very low.

If the current shuttles used expendable SSME, that would only require 15 SSME per year. However, if SSME were also used for a Jupiter SSTO vehicle where the demand for space launches could be hundreds per year due to space tourism and private satellite launches then the demand for SSME could go up from 15 SSME per year to over 1000 SSME per year.

That would encourage rocket engine manufacturers to move from the inefficient 'craft' production of the engines to highly efficient 'mass' production of the engines. But you don't necessarily have to use SSME for a Jupiter heavy lift or SSTO light lift vehicle. You could also mass produce RS-68 engines for the Jupiter vehicle.

Marcel F. Williams

"At most, we are talking about perhaps 2 flights a year at the maximum."

The Russians fly about a dozen Soyuz & Progress a year, _with_ the Shuttle assisting in station supply.

newpapyrus,

"Start fully funding the development of a HLV so that we with one single launch we can place large customized space stations into orbits that are advantageous to American companies."

SpaceX Griffon, late 2010s.

"Launching multiple space stations could accommodate dozens of scientist and potentially hundreds of tourist annually."

Yes, but the private industry should do this, not the government. The government should not pay one dime to develop the stations. They can incentivize with grants for *research* (such as for exploring inflatable designs and even structures capable of creating 'gravity'), but not full on development.

"Create a non-taxpayer subsidized manned spaceflight market by creating a space lotto system"

It will be done. Education is largely funded by our lotto system. A SpaceX flight for 10 million or less (per seat) could result in a very popular lottery program. It's to early to outline such a thing, however, at the moment, and people would ridicule them if they said that's what they wanted to do. Especially since currently space tourists have no place to go to.

"Develop a directly space shuttle expendable SSTO booster (Jupiter without the SRBs but with 6 SSME) to launch at least 20 tonnes into orbit."

NASA is getting out of the rocket business, for the better.

"An Delta 4 heavy can only launch a 25 tonne space station into LEO. A Jupiter HLV could launch a 100 tonne space station into LEO."

Griffon based SpaceX will launch 75 tonnes or more. Late 2010s. Only a small amount of increased COTS funding should bring it to the mid 2010s.

good points there jc about Garver, a whole lotta talkin going on and she seems pretty smug about the whole thing - wonder what it is exactly that commercial industry has done so well that makes her so sure she's right?

the whole point of government, rather than commercial, running the hsf space program was that the non-profit status of the government better ensures quality and safety

sort of like customer gouging Banks vs. Credit Unions, ummm, privatizing Social Security, profiteering private insurance vs. medicare, etc. etc.

well, between Disney World and the Cruise Lines at Port Canaveral - there's always KSC's "Shuttle Launch Experience" ride at the visitor center for the public to remember NASA at it's best.......

http://www.kennedyspacecenter.com/shuttle-launch-experience.aspx

This is a very curious speech. It seems the president has spent some time considering the future of space and consulted with a number of experts to arrive at an enlightened position. By actually reducing the 2011 NASA budget we'll get to explore more quickly and using better technology. Before the uproar of "the budget is actually increased!" begins, remember that $1.6B is earmarked to destroy all evidence of progress on the constellation program which shouldn't really count as forward progress. Other funds are designated to "disposition" Space Shuttle.

If Mr. Obama has really come to this conclusion with the full support of NASA leadership, then it is curious that the NASA center directors weren't consulted. It's also curious that Mr. Obama hasn't said a word in public on this issue he's spent so much time considering.

I don't buy it. This new plan has been done with nothing more than a rubber stamp by the president and was likely formed by others. It's really hard to pinpoint who could have created this plan. It would likely be someone who has spent the last several years studying, listening to, consulting for, and lobbying with the nascent new start commercial providers. Hmmmm, who could this be? Hard to tell, but I'm sure the intrepid press corps will, at some point, reveal this information. Maybe congress may ask some questions leading to an answer.

At any rate, cutting the 2011 effective NASA budget, destroying progress made over the last 4 years, and setting aside money to special interests doesn't sound like we're getting closer to real exploration outside LEO. Without goals, NASA has shown time and time again they turn into a technology sandbox with random output. They're not unlike any other group of engineers and scientists. Gadgets are neat, functioning systems take a lot of work.

Let's keep the debate of Constellation vs. new starts going and just ignore we're not going forward. I guess we'll have to find a billionaire who wants to become a millionaire to fund our human exploration outside LEO. Bill Gates? Warren Buffet? Oh well....

Exploration Believer, the billion plus for "closing down" Cx is just NASA fulfilling their contract. As of now Cx contractors are still going forward, as if nothing is happening. If the new budget is approved, they'll still get paid for basically doing nothing (as it doesn't cost that much money to fire people).

Exploration Believer, you are right on with your statements. However, you said "setting aside money to special interests doesn't sound like we're getting closer to real exploration outside LEO." I will take that even further and say that we are not getting closer to within LEO either.

Your statements about the budget actually thinning due to the $1.68B is also correct. Effectively this budget takes away dollars to just get to LEO.

If this plan works at all, which it won't, NASA needs to be preparing about 500 RFPs for technology development and, at least 2 RFPs for commercial crew to be released right now. However, I don't see that happening.

While I am a firm supporter of Constellation, I do know that the NASA ability to execute anything in the proposal stage with any haste is pretty slim. And that won't turn around just because someone who knows nothing about the process makes a speach and uses the word "commercial."

Everone needs to remember that this argument is not just about launch vehicles, it is also about spacecraft that carry humans to LEO before you can get to beyond.

And before anyone says Orion was over schedule and makes up something like Orion wouldn't be ready until 2037 and will cost $100 billion (numbers seem to expand exponentially on this site). Remember that the design that made it to PDR with hardware being built will support LEO, Lunar, and other beyond LEO missions. Other commercial companies don't have anything close and that is a fact.

Well, I see a lot of talking at each other and very little listening. The facts are this:
- it will likely take 18 months for NASA to wind down all the contracts associated with Constellation; during this time, NASA will be taking budget hits, but after that all monies that were dedicated to Constellation will be free for other purposes.
- The Orion capsule would have been ready by 2017, perhaps sooner. However, it is incredibly overbuilt for any purpose it could be put to for the first fifteen years of its life. Bigelow and Boeing are basing their crew capsule on the Orion design; it will be lighter, cheaper, seat seven and be ready before Orion would have been. When a version will be required for hyperbolic (lunar) reentry, they can build that as well.
- Constellation biggest problem has always been their launch vehicles. I know the Constellation crowd disagrees. Well, we're going to have independent confirmation of their attractiveness. Right now, the designs of Ares I and Shuttle derived launch vehicles are being offered to private industry. If someone picks them up, then we'll know they had some value. However, as things stand at the moment, no one, not even ATK, wants Ares I. There is some interest in the Shuttle derived architecture to build a Direct style launcher upon, but the infamous base heating problem is causing quite a concern. NASA is working with the interested companies to see if something can be worked out.
- Everyone always points to SpaceX and say "these guys just aren't ready." Well, one of the other LEO solutions is the Boeing/Bigelow entry of a simplified Orion on top of an Atlas V. The Atlas V has a perfect launch record; coupled with a lighter Orion it offers a LEO solution that is superior to the Orion/Ares I of Constellation. If everyone else fails, we will have Boeing to fall back upon, and their solution will be cheaper than the $1B estimated cost of Orion/Ares I.

Launch to LEO is a commodity market -- a commodity market that because of NASA's involvement, export regulations, etc was one that American technology could not compete. That is all changing; Elon Musk has gone on the record that once they get the kinks out that their target price is $500/kg to LEO. This isn't just talk; I know people on the Board of Directors and they feel that's what they have to aim for in order to compete. Shuttle price is $10K/kg; cheapest available overseas is $4K/kg. Just think for a moment what an order of reduction in magnitude of launch prices could bring: cheaper payloads, as you don't have to shave every gram any more; larger crews in orbit; different payloads become economically feasible, etc.

With NASA competing with private industry with its own launchers, $500/kg is impossible. With NASA's help, the commercial guys can do it. It won't be orderly, but rather will entail all the messiness and chaos that comes with competition. We will see winners and losers, but even the losers benefit us all: if you need an example, take a look at Iridium. The government, military and private individuals have the benefit of a six billion dollar communications infrastructure that was purchased for twenty five million dollars.

You just don't get deals like that out of a government program. The next decade is going to be lots of fun, and will be to the benefit of us all. You'll see.

"Yes, but the private industry should do this, not the government. The government should not pay one dime to develop the stations. They can incentivize with grants for *research* (such as for exploring inflatable designs and even structures capable of creating 'gravity'), but not full on development."

Why should NASA wait for private industry to do anything. Private companies have no loyalty to the American people. Their loyalty is to the almighty dollar.

"Develop a directly space shuttle expendable SSTO booster (Jupiter without the SRBs but with 6 SSME) to launch at least 20 tonnes into orbit."

NASA is getting out of the rocket business, for the better.

"An Delta 4 heavy can only launch a 25 tonne space station into LEO. A Jupiter HLV could launch a 100 tonne space station into LEO."

Griffon based SpaceX will launch 75 tonnes or more. Late 2010s. Only a small amount of increased COTS funding should bring it to the mid 2010s."

I don't understand. If these companies hate government so much how come they're always begging for tax payer dollars?

The total net worth of people on this planet with a net worth that's more than $1 million (not including their first home) is over 37 trillion dollars. Yet these guys want to grab pieces of NASA's tiny $10 billion a year manned space budget.

If these private companies know so much, why don't they spend some-- real money-- actually putting people into space instead of whining all the time about how much better they are than NASA and trying to tear the people's space program down.

This constant anti-government extremism is getting beyond silly! What do we want to do next, turn over all of our military operations to Blackwater?

Marcel F. Williams

Does anyone think that the combined CRS and commercial crew business will be enough to sustain more than two commercial providers?

Perhaps. CRS by itself will probably not be enough. This can be solved in the same way as DoD solved its problem of getting assured access to space, with a manned variant of the EELV Launch Capability (ELC) contract, though not necessarily restricted to EELVs and also including crew vehicles. This contract takes care of fixed costs, and these are charged to commercial launches, which aligns interests nicely. You could compete two contracts for that. There could even be synergy with DoD's ELC.

Incidentally this would also support Bigelow, who could thus provide more demand for launch services, both manned and unmanned.

There's obviously a misunderstanding of the current constellation contracts. The $1.6B does not just let the contracts run to conclusion. That's wrong, a myth, misinformation, a smoke screen. The plan for the $1.6B is to pay for the liability for terminating for convenience, something the government has the right to do. ALL larger Constellation contracts run beyond 2011. The money in the plan goes to reimbursing expenditures for sole-purpose facilities, gathering all work in process across the huge supplier base, then determining how to dispose of all the hardware and data generated to date. That's a lot of work that costs a lot of money.

As for laying people off, that costs money too. Severance payments, benefit liability, and other expenses make it cheaper to keep employees sitting around on an overhead charge for many months rather than lay-off and recall employees. Seriously, the nearly $2B is not spent on working forward progress. Heck, with the brilliant rollout of this new "plan" the ongoing work already authorized this year has probably been significantly slowed down by worried workers.

The fact remains, next year's proposed NASA budget as proposed reduces NASA's actual funding towards moving humans beyond LEO.

> These people seem to be determined to turn NASA into the next General Motors.

haha that is so converse of sense that I don't think anything you've ever said or will say can be trusted

Exploration Believer, humans beyond LEO was not happening until the mid 2020s, the budget changes nothing in that regard. For all you know, the 2018 budget starts paying for HLLV, since by then all of the science stuff will be winding down. That sounds about right. SpaceX Griffon should be well into the design stages by then.

The budget doesn't change any timelines whatsoever. Unless you believe in a magical budget that doesn't exist and is politically infeasible.

Good speech. Obviously carefully crafted to highlight the previous political nods to commercial space and use a lot of business, jobs & markets language.

Good speech with good background defining the basis of this proposed approach. I very much hope this works as it will be very painful to turn this ship to its new course.
Fortunately for me I am a civil servant who has some level of security, so I can focus on trying to make the new plan work rather than worry about paying my mortgage and feeding my family. But it will be very difficult on my contractor friends and colleagues. And while I understand there are those outside our community who may look at us as a white collar welfare program, it is my experience that those with that attitude inside our world are actually the exception. I got into this field to push human exploration of space, not be a jobs program, and think this new approach may indeed be what we need at this point, but it will be very difficult to watch dedicated people have their lives upended.
I cannot argue that other industries have also suffered in these difficult economic times and that represents real pain to other dedicated workforces. But that doesn't make this pain any less for us. I will do my best to make it worthwhile. And sincerely hope it will be.

I was only talking about crew rotation.

Assuming that the commercial crew vehicle can remain on station for the entire expedition duration (a commercial Orion or Dragon rather than Boeing-Bigelow or DreamChaser) then you would only need a couple of flights, replacing two Soyuz each due to higher crew capacity (six or seven rather than three), to make station crew rotation equally a US/Russian responsibility. There is the possibility of further launches to carry out mid-expedition rotation of half the crew too but I have a feeling that would be considered an unnecessary extra cost.

In terms of cargo, sufficient cargo launches would be needed to replace three or four MPLMs a year. At least some of that will come from ATV and HTV. IIRC, between them, OSC and SpaceX have eighteen launches contracted for the period 2013-2016. That would average out at about four or five flights per year spread between two providers. So, you have two commercial crew flights and, generously, six commercial cargo flights originating from US providers a year. That totals out about eight commercial launches per year, assuming no mid-expedition crew rotations or space tourist flights. You might be able to squeeze two Federally-subsidised providers out of that.

With ULA, Arianespace and ILS already having pretty much cornered the comsat market, there is very little room for extra companies at current market levels. Overall, I'll stick with only one 'newspace' provider making it to the end of the ISS. If SpaceX's test program goes well, then I'd say they have a good chance of being the one as their product has several advantages including multi-role and orbital loiter.

I am now going to throw down the gauntlet to all who think this "commercialization of space" gibberish is appropriate and will lead to something workable.

1) Please show me the NASA equivalent to FAR 25, which specifies the regulations for design of transport aircraft such that I, the commercial endeavor, can know exactly what I need to meet to achieve certification. NASA has no such regulations, and nor do they operate in any manner like the FAA to provide the same quality of regulations like this.

2) Please show me the NASA equivalent to the FAA Advisory Circulars (AC) which "provide guidance and acceptable means of compliance, but not the only means, for complying with federal regulations" such that I can design a system that I know will be certifiable without being subject to the whims of government bureaucrats who love to change the rules in-process, and thus lead to my company's financial ruin for inability to certify a product. NASA has no such AC system. Not having it presents a MASSIVE amount of risk to any potential offeror.

3) Please show me the NASA equivalent to the FAA Designated Engineering Represensative (DER) and Designated Airworthiness Representative (DAR), which will allow me to develop and bring my system to market in a timely and cost-effective manner without having to work to the government's schedules for airworthiness approval of detailed design and analysis data. NASA has no such system, and its current bureaucratic structure (which tries to be a monolithic design agency and not a certifying agency) would never permit such a "trusted citizen designee" approach. Moreover, NASA is light years away from even thinking about how to implement such a designee system.

I could issue more challenges just like the above, but you get the gist that I am pointing to how the FAA regulates the commercial aviation sector. The FAA's success, in terms of per departure fatality statistics, cannot be ignored and is one of the few examples of "government regulations done right." But to think you can just provide some seed money and turn the whole of human spaceflight over to the private sector without the foundational infrastructure that has taken decades to build with the FAA is totally naive. I know the NASA fanboys and fangirls will try to argue with me, but until you have years of experience with the FAA certification system, you have no position to argue, simply because you think the NASA way is the best way, and it is far from that.

Let me close with just one example of how hard it is to get solid regulations and design guidance in-place: The FAA still has no formal FAR regulations for designing unmanned aircraft that can operate in the national airspace alongside manned aircraft. All such flights (i.e. Global Hawk, Predator) are via special permit and procedure. The industry has been attempting to help the FAA craft such regulations, and the AC design and certification guidance for same, since 2000 (with NASA's help via the canceled ACCESS5 program). Getting these types of regulations and guidance for certification and operations in place is EXTREMELY simple compared to what is required for commercialization of manned spaceflight. And yet, we are still not "there" yet. Manufacturers still do not know how to go about making an unmanned aircraft "certifiable" to co-exist in national airspace with manned aircraft. We have ideas of what it will take, but we cannot make the behemoth of government move any faster than it does.

So what makes anyone believe commercialization of human spaceflight is going to magically happen before 2020 with a couple billion of government seed money? It is not the money that matters, it is the REGULATORY ENVIRONMENT that will either make or break a commercial venture's ability to bring a viable product to market. I would love for the commercialization rhetoric being slung by Garver and Bolden to work, because I am all about the market. But they are going about it completely the wrong way, with no plan, and are not even TALKING about the regulatory infrastructure. Ask any of the FAA greybeards and they will tell you what a disaster this is in the making.

It is certainly the case that, if the Administration is serious about commercialisation of space, it must create a clear and responsive standards and certification framework. Otherwise, the plan will founder on the rock of NASA's institutional hatred of commercial endeavours.

You ask for the NASA regulations that will govern several aspects of commercial space flight. I don't think NASA really has any dogs in that race. The Office of Commercial Space Transportation is a division of the FAA. They are the ones who will deal with commercial space flight, not NASA.

Ben:

It is certainly the case that, if the Administration is serious about commercialisation of space, it must create a clear and responsive standards and certification framework.

You used the "S-word" (standards). Right on, buddy. The importance of standards cannot be overstated, especially because of the following words bandied about by Ms. Garver:

Instead of a highly-risky approach, in which we fund only one system, we are going to fund many systems to create redundancy. No single commercial system will represent the critical path.

Without high-quality standards (and the certification guidance to support them), asking commercial space to develop several different systems is actually MORE risky than a monolithic design bureau developing just one. One thing about commercial endeavors you can count on being true: They don't like sharing their trade secrets and proprietary designs with their competitors...so they won't, and they will lawyer-up to make sure no one forces them to do so.

Greetings RNP:

You ask for the NASA regulations that will govern several aspects of commercial space flight. I don't think NASA really has any dogs in that race. The Office of Commercial Space Transportation is a division of the FAA. They are the ones who will deal with commercial space flight, not NASA.

I can certainly accept that as a valid response. But then there are fallouts associated with that response. Some of these fallouts might be good, but some are clearly not good:

1) Have you looked at the current regulations for Title 14 of the CFR, Chapter III? There are zero regulations that govern vehicle design and certification standards a la FAR 25. That is clearly not good.

2) As a result of there being no design regulations (nor interpretive guidance a la Advisory Circulars) in place, then this compounds the problem of NASA not having a real plan for commercial space, since even they do not know how the FAA will certificate vehicles (assuming, as you put it, that NASA is not the certifying agency). This means that the "seed money" being spent by NASA on the handful of "promising" NewSpace firms is not being smartly spent at all. Lots of risk there, right? VERY not good.

3) Now the one bright spot I can see, if your take on this issue is accepted, would be the NASA Human Rating Requirements (NPR 8705.2B) are not applicable and they can thus be flushed away into obscurity. I say this is a good thing because anyone who is familiar with these requirements know that they are highly subjective and do not lay out any criteria by which their subjectivity can be objectively assessed. So it is best to just get rid of them, and allow the FAA to develop the same kinds of regulations and design guidance from which the highly safe transport aircraft we know and fly today were developed.

"One thing about commercial endeavors you can count on being true: They don't like sharing their trade secrets and proprietary designs with their competitors"

And don't expect any design or testing videos to be published. Those that complain about NASA being slow to release test results can expect worse from companies.