Off-Nominal - 135 - Stupid Vertical Dogleg Machine

Episode Date: December 15, 2023

Jake and Anthony are joined by Tom Marotta of The Spaceport Company to talk about what they’re working on, spaceport operations, and the FAA licensing process.TopicsOff-Nominal - YouTubeEpisode 135 - Stupid Vertical Dogleg Machine (with Tom Marotta) - YouTubeNASA: Let’s Ketchup on International Space Station Tomato Research - NASAThe Spaceport CompanyT+259: Tom Marotta, The Spaceport Company - Main Engine Cut OffThe Spaceport Company- Full Length Launch ProRes HQ 4 - YouTubeThe Spaceport Company demonstrates offshore launch operations - SpaceNewsOrbital Access Methodologies Part III: Pop-up TSTO | Selenian BoondocksFAA publishes streamlined commercial launch regulations - SpaceNewsSpaceX violated launch license in Starship SN8 launch - SpaceNewsAstra aborts launch attempt - SpaceNewsFollow TomTom Marotta (@thomasmarotta) / XTom Marotta | LinkedInFollow Off-NominalSubscribe to the show! - Off-NominalSupport the show, join the DiscordOff-Nominal (@offnom) / TwitterOff-Nominal (@[e-mail]) - Spacey SpaceFollow JakeWeMartians Podcast - Follow Humanity's Journey to MarsWeMartians Podcast (@We_Martians) | TwitterJake Robins (@JakeOnOrbit) | TwitterJake Robins (@[e-mail]) - Spacey SpaceFollow AnthonyMain Engine Cut OffMain Engine Cut Off (@WeHaveMECO) | TwitterMain Engine Cut Off (@[e-mail]) - Spacey SpaceAnthony Colangelo (@acolangelo) | TwitterAnthony Colangelo (@[e-mail]) - jawns.club 🐘Off-Nominal MerchandiseOff-Nominal Logo TeeWeMartians Shop | MECO Shop

DLS and go for main engine start. Hello, everybody. Welcome to Offenomenal. Jake, how's it going down there? It's going good, man. We're in a bit of a cold snap here. Believe it or not, this is the one week in the year in Yucatan, Mexico, where I have to find a sweater at certain hours of the day.

It's very weird. I don't like it. What a shame. I'm going to survive. I've made the commitment to power through this time of not always hot weather. Conversely, yesterday, I was like, man, it's really cold out today. And then I realized all the cold is still coming. Like, that was not even the beginning of the cold yet and all of it's still coming.

Yeah, I think it gets worse next week for us too. So I think I think everything is just dipping down. Like it does that, I don't know, it's almost like a polar vortex kind of thing or just like that just pushes and everything goes south. So everyone goes like five or 10 degrees colder than they usually are. I'm a polar vortex denialist, but someone who probably isn't is Tom Marada. How's it going, buddy? I'm great. I'm great. It's also, as you can tell, for my sweater, quite chilly here in northern Virginia. But I'm doing well. I'm pushing through. How are you guys?

We're going to survive this together with our... Yeah, we'll be okay. We'll be all right. We will be all right. We will band together and survive this polar vortex. Oh, man. Well, what do we? All right. Yeah, so we're going to talk about some very, very, exciting. This is like our last, like, content content episode of the year. We've got off nominees next week. But, you know, this is like our last episode of the year where we do

something like not frivolous and weird. Are these your content hands? What is this? Yeah, what is crunchy bits? Real stuff we're going to do. And we thought, what more exciting thing to talk about than commercial spaceflight regulatory reform? Yeah, you guys are really straight at the bottom of the barrel here. Yeah, yeah, yeah. So everybody get your code of federal regulations now and turn to page 8 billion. And let's get started. You can follow along on section 2, subsection C.

Listen, last week we did refer to the federal code. And foreshadowing for our first second of the show, we are going to recap some federal government storylines before regulation. That's true, yes. We do have to follow that. We should do drinks first, though. We should do that before we get in. Yeah, Tom, what do you have? So I've got two things to show and tell.

This is what I'm going to be drinking my drink out of. Wow. And this is a 1990s era, Great American Achievement Stein. And this is the fifth in a series made in Brazil with pride, of course. And it's got all sorts of space stuff on it. So, uh, what were the other four achievements?

Do you know? Brewing? I don't know. I have no idea. Discovery of Golden Colorado. I don't know. I don't know the other. I haven't collected the second.

You didn't get those ones. And I'm going to be drinking space wine. From, uh, from, uh, water's and brewery, a local.

Yeah. And it's 8%. So I'm going to be drinking. it very slowly. Is it beer or wine? It's beer, but they call it space wine and has nothing to do with space. It uses galaxy hops,

which apparently are very rare and special. I feel like we drink them a lot on this show. Yeah. Okay, cool. That's what I've got. I don't know how we're going to top that, but maybe you can go, Anthony. Well, I've had this before. This is a great American achievement. The B-25, ghostbomber gin. There's a B-25 right on the front of that. So I'm actively making a gin and tonic because we went a little long in the pre-show. So I just had to gather all my materials and bring it up here. So high stakes, gin and tonic mixing above my track pad and everything else on my desk. But that's what's happening right here.

I just filled a little spacewise. It's okay. We're going off to a great start here. All right, well, I have the great Mexican achievement of putting tequila into a can of pop. So this is what we're doing today. It's something weird. I don't know. El Himador. New mix.

New mix. I think it's like grapefruit and orange and lime or something with tequila. I don't know. I saw it at the store and I was like, this is weird enough for the show. That sounds delicious. Cheers, everybody. I'm going to do a little pour or two. Yeah, my tonic nearly exploded right there.

It was like right to the rim on that one. I got halfway up my stairs and I was like, maybe I shouldn't have put the tonic in my pockets. So I walked very slowly up the rest of my stairs. There's a color. I don't know. Great. Wow.

And you got to get a great Mexican achievements, Stein. Yeah, Stein. Yeah. Made in Brazil. All right, Tom, before we get to the regulation side of things, last week in the pre-show, which you can listen to in Discord for all the people that are in Discord, offnom.com slash Discord. I filed a FOIA request live in the pre-show, and I did not even use the media exemption because I thought it was not worthy, but I would be willing to pay $250 for it.

So I submitted the FOIA request. Wow. I didn't know you had to pay for them. Only if you're not, only if there's like a whole, there's, again, we cracked open the Federal Register and we were looking at the guidelines, and we determined that it was not worthy enough to meet the criteria for worthy things that would be given out free. So I just told them I'd pay $250 maximum for it. But at 2.15 p.m. today, NASA posted some content, okay?

There was a tomato lost on the ISS. So we thought there was a tomato lost. on the ISS. They post this, and guess what? There are two tomatoes that were lost on the ISS, and they've now posted the photos of these tomatoes that were found after, I don't even know if they said when they were found, like what day they were found. But it was like eight months between when these tomatoes were lost. So I just want to alert everyone that our head canon is that we submitted the FOIA request, and they started looking for it, and they posted the pictures in response to our FOIA request.

So you guys found the tomato on the space station. I think you can draw the connection. That's what it concludes to, yeah. I think we can put up the picture of George Bush and the mission accomplished flag. Yeah, we did it. We did it. Two tomatoes.

There was two. They said it was one. It sounds like you guys need to start issuing more FOIA requests. We get the job done, you know? We are movers and shakers. Yeah, you guys are the power behind the throne. Sounds like. All right.

So, number one, you're here because you're a very fun hang and somebody we've been like, we should get Tom on this show for so long. You were on Managing Cutoff a few months ago, two, three months ago, I think it was. So maybe we can do a little previously on Tom and you can give everyone the rundown on the spaceport company and also your time at the FAA because both things are highly relevant. Yeah. Yeah. I'll keep the condensed version because we want to dig into the CFR here shortly and regulations.

But yeah, Tom Marotta. I'm a Virgo. I like long walks on the beach. And Tommy DeVito. Tommy DeVito. Yeah, let's see. Pretty unusual career, trained as a city planner, worked in commercial real estate. I was a diplomat for six years, served overseas in Europe and Africa and in Iraq.

And that was great. And then I transitioned my federal career over to the FAA. And for five years, I worked at the FAA Office of Commercial Space Transportation and was one of many people who helped write regulations. I created the launch forecast methodology. So if you go on the FAA space website, they have a forecast of how many launches they expect to see. And I led the team that helped create that methodology.

And did a lot of other things, worked on their good. government relations group called ComStack, the Commercial Space Transportation Advisory Committee. Okay. And after that, I went and worked for Astra for about nine months. It was a real quick, exciting tour of duty with Astra, let's call it. That's a great description of Astra, yeah. Very well-placed pause as well, yes. It was a great, it's a great, it's a great, it was a very interesting place to work. And part of my job there, my primary job was, was regulatory stuff, as you can imagine. But the other part of my job was helping the spaceport team go find launch sites. And the way this would work is they would say, hey, we found this site. What do you think of it from a regulatory

perspective? And I'd be like, no, not going to work. We'd be so good at this job, Jake. This is like, we'd be so good at this. I found this nice piece of land in Newark, New Jersey. Is it a good spot to launch a rocket? It's great. Yeah. Yeah. That a piece of earth is already totally ruined from my perspective. down near south of it. So between the FAA and my type of Astra, you know, when I left Astra, I was like, what am I going to do? My wife's like, what are you going to do?

You're not going to sit around. And our dynamic, my wife and I is like, I often have ideas like, hey, I should, you know, go do this crazy idea. And she's like, no, go get a real job. And so after Astra, I was like, hey, I want to build a spaceport. And she's like, hmm, you know. commercial real estate, city planner, former diplomat, regulator, you know, did the job sort of at Astra. Like, yes, you should go do that. And more importantly, I spoke to some mentors and spoke to

some colleagues and was able to raise some money. And so started the spaceport company in February of 2022. Initially scoured the globe for land. Like we thought we were going to do it the normal way, build spaceports on land. And that's still an option. We're not, the offshore spaceport company, we're the spaceport company, right? So if we could find an appropriate piece of land for a land-based spaceport, we would. But the idea we always wanted to solve is to create a model of a spaceport that can be repeated around the world, right? We don't want to just build a one-off spaceport. That's how things used to be done. We have 20,000 airports in the United States alone, but we only have four places sending satellites to orbit

regularly. We want to build like the McDonald's of spaceports, like a model that can be repeated over and over and over again anywhere around the world. And the best way to do that is to build them on ships. It's easier to build the same ship over and over and over again than it is to find land on the coast over and over and over again. And so we spent the first year of the company's existence sort of testing that thesis with customers. We have about $250 million of non-binding, but commercial letters of intent. So that's a pretty good demand signal for what we're building. We tested our prototype, a subscale prototype back in May. So this like computer image that you're seeing later on, you could show the actual demonstration.

And I'm always really proud how much the demonstration looks like the computer image. Now the rockets were a lot smaller on the demo. But anyway, we proved that the, the, the logistical, the operational, the regulatory, kind of all the basics that you need for a space port just on a much smaller scale in May. Specifically, with the vessel, we modified it we launched four rockets in one day. It's pretty cool.

We raised a non-trivial amount of money this year. We raised about almost $3 million. We have a DOD contract. We have essentially a congressional mandate. The House Armed Services Committee instructed DOD to begin planning. for a sea launch demonstration to orbit. And we're building up our team. We're bringing on a VP of engineering starting on January 15th.

And yeah, we're going to start hitting it hard next year, 2024. We've got the funds to complete the design of our full-scale system. We're going to commercialize our subscale system. So you'll be able to buy a sea launch in the Gulf of Mexico for your sounding rocket or for your payload next year. And we're also building. a containerized ground station that can be leased out. So if you need a ground station to receive telemetry from your launch vehicle in a remote location,

you could use our ground station. It's completely self-contained. All it needs is power. It uses Starlink and InMarsat to connect to the internet. And that'll be another product that we roll out next year. We're still trying to raise the money to build the full-scale system to launch satellites to orbit. I've got a couple of irons in the fire, not ready to make any big announcements about that yet, but the big news there is that we've signed a letter of support with Firefly, and they are

providing us technical expertise, frankly, technical interchange meetings on a weekly basis to launch eventually a Firefly Alpha from our orbital system. So it's pretty busy. We're making some progress. Success is not assured, but we're steady, we're methodical, and the underlying drivers of the demand here continue to remain in place. Let's see. China operates three C-based launch platforms,

so they recognize the resiliency and the redundancy benefits of C-based launch. You know, like if a C-5 hurricane destroys Cape Canaveral or see, you know, rising seas make it harder to operate there, both of which are happening. We offer the U.S. Space Enterprise, the launch enterprise, to be able to have resiliency, have redundancy, continue to access space separate from a place like Cape Canaveral and watch sites.

So I'll pause there. I'm just really enjoying the video. I'm a little distracted. Me too. I know. That's good. That's the best that Astrockets ever looked. IMO. Yeah.

Yeah. It was doing great. No shade to you. Oh, dear. Oh, yeah. That's cool. I think it's neat. It's like the, I laughed and you said the rising seawars.

Like, oh, my God, we're building space port companies that are resilient to climate change. That's great. Okay. I'm glad that we have to do that. We're doing it. No, it's cool. I think it's some neat idea. Because I think the scale of it is probably what's going to be important, right?

Because I know we've seen a couple, like, and I listen to your interview, and then you're going to say, like, you're going to correct me on what I'm going to say. That's fine. We can do that. We can do that little song and dance. You know, we've seen a few attempts at C-launch, and they like, they've kind of been like so-and-so successes, right? And I know you're going to say they've been technical successes, but something else, right?

But maybe see what I've never really tried. Yeah, yeah, yeah. And I feel like the. You're talking about the scale was important. You're talking about the Boeing system. There's a couple, I think, right? Yeah, Boeing and the Europeans did it too,

I think, in Kenya and like all sorts of stuff like that, right? So the Italians built like a fixed platform off the coast of Africa, I think Kenya, and maybe they did like a couple of launches and then, you know, nothing

to happen. But yeah, that Boeing project. Look at that guy. Lifting that rocket right there. Yeah. The Boeing project, yeah. I mean, they only launched 36 times and made like $100 million dollars of revenue and like had a failure and then came back from it and continued to launch like a dozen times.

Like, what a flash in the pan. Like everybody comes to me and they're like, oh, but Boeing failed at sea launch. And I was like, okay, like how many dozens of launches did that have? That sentence also used to play a lot better pre-2020. Like, that was, you know, that's not, no, it's like, okay, you know, show me a good project at the moment that's not like off the rails entirely. So that's probably more defensible these days. Yeah, I mean, operating at sea is hard.

I'm not going to lie. Like, it's expensive, you know, it's complicated. But it's harder to build new launch pads on land, you know. and the demand for new launch pads is growing. I mean, we're seeing SpaceX missions being delayed by other SpaceX missions because of a lack of launch infrastructure. Now, that's kind of like hidden from the rest of industry at this point, but when Blue Origin starts operating and, you know, eventually

and other entities start operating down at the Cape, we're going to see a real crunch in demand there. I mean, we're already seeing it with the delayed Falcon heavy launch, you know, there's going to be a domino effect with delayed Starlink launches and delayed, you know, national security launches and so on and so forth. And that's directly tied to a lack of launch infrastructure. There's also the fact that the quirk of Earth is that the east coasts of continents have the warm water. So they are developed because people like to swim in the warm waters.

And those are also the really useful spots to launch to orbit from. So, like, the fact that we discovered rocketry so late in our development also led to all of the good spots being taken at this point. Yeah, that's right. There's a lot of recreational and environmental stakeholders that want to operate on every coast, not just eastern coasts. I mean, try to build up. Yeah, but I'm going to be in East Coast to lead us for a minute. Like, come on. Like, we could swim in our waters.

In the middle of winter, it's as warm as your water on the West Coast, people. Like, just we got the good current. That's all I'm saying, Tom. Hey, how many of you don't have to argue with me? I think it's great. But, yeah, I mean, try to build anything on the coast in California, though. I mean, it's pretty tough over there, too. We got nice flat coasts out here with warm water.

Yeah, yeah, yeah. Yeah, and a lot of people ask me, why don't we launch to orbit from inland sites? You know, the United States has something like, I forget the number now, 14 licensed spaceports. not counting the federal ranges, not counting Keith Canaveral and Vandenberg and I think Wallops is included in that because it's a NASA range. So there's like all these space ports, why don't we use them? And the answer is you can't get to orbit from those inland sites or to be more precise, a commercial company can't get FAA approval to go to orbit from those inland sites

because rockets still blow up a lot. And so those missions, a rocket, even a small orbital, rocket, like an astro rocket just is too risky. It can't meet the FAA risk criteria to get a license to launch from inland. So even though we're blessed with all these wonderful spaceports, you know, places like Spacort America and Mojave and so on and so forth go down the list, for the foreseeable future, until rockets become like orders of magnitude more reliable, you're not going to see any launches from those inland sites, at least not to orbit. You can still do great things.

a super heroic upper stage engine revolution that let us launch our first stage directly straight up in the air. Once you get to that point, you could like, mega. It just like makes a quick like turn. Yeah, like super loft a thing and then a huge dog leg, you know? It's a vertical dog leg maneuver. Yeah, it's a vertical dog leg. Hmm. Yeah.

Listen, I'm not the one, John Goff and crew out here are writing these blog posts all the time of like mega lofted in the trajectory. I'm not doing these blog posts. I've just read them, okay? I'll put some supporting material in the comments. You never say never, right? Like, seriously, like maybe there's some balloon technology. I don't know.

Screw balloons. I'm out on balloons. I'm out on balloons. They go straight up and, yeah. Hear me out. A Boeing 747. We could use more. It sounds familiar.

Yeah. Take care of that first 40,000 feet. And we're like, we're going to. That's all you need. Yeah. Even though they lift it off from the desert to fly over the ocean. That is maybe the premier example of what Tom's saying. They went out of the desert.

The funny thing about that system was the airplane was the first stage. So, like, they didn't gain anything in terms of, it's not like they can have landed at JFK or Newark or something. Like, that whole site was still a spaceport, as if it was as if it was cannabral or something like that. So not the whole site, but much of the site was still a space board. So the regulations are very, very restrictive for a reason. And the FAA would say they work, right? Nobody's ever been killed or injured or no member of the uninvolved public. Right.

So just a person driving down the highway or a farmer in his field or whatever has never been injured or killed by a commercial space. operation. So they say they have a perfect safety track record and I agree with them. And, you know, it's kind of hard to argue, number one, with perfection. And number two, you don't want to be the, you don't want to be the like FAA commercial space administrator who like lost the perfect record. Right. And so they're really, really serious about doing that. But the tension that commercial space has, by commercial space, I mean like the FAA office of commercial space transportation. You have a very long name, a terrible acronym. With an acronym. sense. Where did that come from?

It's awful. All of the functional stove pipes inside of the FAA begin with A. So like the Office of Vehicle Safety is AFC. Yeah, the Office of Airports is ARP. The Office of the

General Council is AGC. Like, you know, but, and I think that comes from like DOT their stove pipes, like aviation is A. I think maritime is M. So whatever.

It's just like bureaucracy. It's stupid. Right. Yeah. So the Office of Commercial Space Transportation, AST, they have this tension where like, yeah, they want to keep everyone safe and keep their perfect safety record. But at the same time, they have the statutory requirement to encourage, facilitate, and promote. And so I think they do a pretty good job of threading that needle. for my time in the office, there were a lot of, there was a really actually pretty good tension

where the staff would be like, this is ridiculous, we can't allow it to happen, this is so stupid. And the leadership would be like, let's figure out how to make it happen safely. Like, what do we need to tell the applicant, the rocket company that they need to do in order to meet the regulatory risk criteria and protect the overall public from what are arguably pretty volatile, pretty crazy, you know, giant bombs that were lighting on fire and shooting through the air. And so there's a lot of resources. There's a lot of training. There's a lot of, emphasis on obviously safety, but also encouraging the industry. And the past 20 years of commercial space dominance in the U.S. is a testament to that. It's a lot harder to get regulatory approval

out in like say the UK. So I'm told. You can have somebody from Virgin Orbiton and make it tell me. Yeah. I have a. Go ahead. I'm here. I mean, Tom, like, you just teed that up for Jake.

Because he's been like, what do I? I don't know. I got so many things. Yeah. I got, like, I have so many questions. I'm trying to assemble them like Lego bricks into like greater questions so that I can get them all out at by the end of the show. That's the dumb ones first.

Go. Yeah, I know. Okay, no, it's a good segue from what you're doing with. Maybe an end goes down, pointy end goes up. Got it, got it, got it. So, like, we're seeing, you know, we're seeing more rocket launches now than we ever have. Like, obviously, you know, SpaceX has really ramped it up. There's rocket lab doing quite a bit of volume. We've got all these new entrants coming up.

So, like, if you look at, like, the graph of, like, launches per year, we're, like, moving into that hockey stick sort of situation right now, right? And it occurs to me that, like, in any kind of regulatory journey, from nothing to I launch a rocket from my own space port. There's sort of like two steps to that, right? There's like the vehicle, which is like, is the vehicle doing all the right things it has to do to be safe and whatever? And then there's the location, the port itself.

Is it set up in a way that it creates a safe environment to operate it in front? Right. And so my first big question is like, how much is of those two things, like if the FAA had to like divide their attention, How much time are they spending trying to regulate the location versus the vehicle? Is that like a 50-50 split or is it way off in one direction? No, it's way off on the vehicle side. It's way off on the vehicle side.

So the FAA has an office of spaceports. The regulatory, how can I put it, emphasis or like what the FAA is trying to do with the spaceport regulations is ensure that the uninvolved public can't like, wander onto the space port. So it's basically access control, right? And the big thing and a spaceport has to prove is that they can control access to their facility and, and prevent people from driving on, planes from flying over, boats from, you know, boating in and so on and so forth. It's like a list of things that have went wrong with SpaceX operations over the last three years. I'm like, I remember that story. I remember that story.

The guy with the YouTube video underneath the stars. The boats, the DEM2 boats. Yeah, exactly. And so now that the SpaceX, like, the Brownsville thing is weird because they're not a licensed spaceport. They're an exclusive use site. So that's, like, that's a clue to you that when Jake, you start the, like, Jake Rocket Company and you're like, I'm going to go buy a piece of land somewhere and I'm going to start. at my launch site, if all you're launching are Jake Rockets, you don't need a spaceport license. All of your spaceport-related compliance activities get packed into the vehicle license

that you need to launch your rockets from your site. And so, SpaceX, when they're launching from Brownsville, all of the spaceport-related stuff that they need to do, the access control, you know, talk. talking to the Coast Guard, talking to the FAA, like making sure the air is clear, making sure, you know, all that coordination, all that is done through the Part 450 license, the vehicle operator's license. Same with New Shepherd out in West Texas. That's an exclusive use site. Now, if you're international, another twist, right, Rocket Lab down in Mejia, they're not in the U.S. So the FAA authority only kicks in at ignition. So all the like spaceport related stuff, the ground safety, the access control, the air traffic coordination, FAA has nothing to do with that.

Nothing to do with that. That's all under New Zealand authorities. FAA authority begins at ignition, not extinction, ignition, ignition for an international site. this stuff's kicking in that's the next time listen they're just returning to flight tonight all right give them a break so yeah

to answer your question like the part 450 license the vehicle operators that's like 99% not 99 it's like 95% of what FAA does and that's where the rubber meets the road so when an entity is like

hooray we got our spaceport operator's license I'm like cool that's awesome Let's see if you could get a vehicle actually fly from that. That's the easy part. Yeah, yeah. And that's why you see, again, to reference my earlier comment, there's a number of spaceports in the U.S.

that have never even had a suborbital flight, right? And so getting the authority or getting the approval to actually get your launch, that's the real mark of an operational spaceport. So what are we hearing about then? Thinking about the starship stuff, like all of that has been like recently very much about the, the site and, you know, fish and wildlife and the nature reserve and the shower of concrete. And it's all been like very like launch site style stuff. Yeah, Had zero.

Or what is it? Stage zero, right. Yeah. I mean, like, you know, all the water use and the the fueling facilities and all that. So what's that? I mean, there's no such, there's no just because. because SpaceX at Brownsville does not need a space port license, a Part 420 license, which is a launch site operator license, or a Part 433 license, which is a reentry site operator,

they've separated those. Touchy subject. No. Just because SpaceX needs neither of them because they're operating as an exclusive user, they are the only entity that's operating out of Brownsville, so they're an exclusive use site. there's no free lunch, right? They still have to do everything that's required under a Part 420 and Part 433 license. Even if they were operating at, say, Cape Canaveral, which Starship will be operating out of there, you know, whatever, in a couple years, they're building a pad there.

The Part 450 license, there's a relatively short, like, paragraph in it. It's a pretty smart. And it basically says, you have to comply with NEPA. You know, you have to do an environmental rule. You have to comply with me, but that, and it's like maybe a hundred words long. That one little section has these like tentacles that reach out across the entire, almost the entire U.S. government. And it results in a lot of, a lot of regulatory work. Gotcha.

And so that's how, that's why the FAA has to consult with other federal agencies like the Fish and Wildlife Service. I think the reason... He's not kidding. It's literally this one section. Yeah, that's it. That's it. Yeah. This is the only three mentions are NEPA. No, no, but there's only, if I did you search for NEPA, there's only three of them. There's this one that says they have to comply by it and here's your requirements. So, yeah. And all this drives all the traffic on Twitter, Jake. This is that's right. That's correct. That's correct. Yeah, that's my hunch is that Elon doesn't

want that regulation change because he gets so much Twitter engagement done of it. Yeah, Tom, remind us when you left the FAA. Oh, gosh, you're going to put me on spot now. This is 2023, so let's be 2021, 2020, something. I'm trying to run this back to see if you were the guy that everyone was waiting on to show up at Bocca that one time to review stuff. That wasn't me. Yeah, who's the guy they had to fly on in Florida?

overnight to go to that one. Yeah. Can we get him on the show without anyone knowing that it was him? Yeah, I don't know about that. Just blink if you can get them, go on or book them, you know. We'll send him the scheduling link. You know, I often wonder why the FAA isn't a little, well, I know why they're not more transparent. I kind of, I wish they were.

but there is a lot of back and forth that happens. And a lot of the reason the FAA is not more transparent is because in many instances, the operator is iterating. And the operator is saying, all right, here's our data. And the FAA is like, are you sure that's your data? Because if you tell us this is your data, we're going to evaluate this. And then the operator's like, oh, no, wait, wait, wait, we want to change our data. It's like, okay, so there's like a churn where or the operator says, yeah, this is our data,

evaluate this. And then the FAA is like, well, here are the results. Here is our evaluation of the data you presented. And the operator is like, we don't like that. And the FAA is like, well, that's the data you presented to us. If you want us to give you a different answer, give us different data to evaluate. And so there's a lot of churn there. That's often why things take a long time is because the operator, the applicant, is changing their mind.

Or sometimes the vehicle is changing, right? They submit something. And then six months later, the FAA is like, here's your answer. And the operator is like, the vehicle's changed. Like we're three versions past that. There's something in the regulations called continuing accuracy. So when an operator makes a continuing accuracy submittal, we change this valve or we're going to have a new trajectory or whatever. You know, the outer mold line is the same.

The mass is the same. The propellants are the same. But this is like this tweak. Then the FAA has to like take that into account and it changes. So there's a lot of churn. Yeah. So do you go back go to bat for your your old friends at the office that One thing we always hear is that like we need more budget in the federal

government budgets to hire more people at this office and be able to do the work that we're like were you swamped the whole time you were there Are how do I how should I receive this storyline? It is it is accurate I I am like When secretaries of whatever or like people in the government are like, we need more money. You know, we don't have enough money. We don't have enough people. I almost always roll my eyes because I'm like, oh, like billions of dollars is not enough.

Like you've got like tens of thousands of people who work at NASA and you need more money. Like what the hell? But okay, at the FAA, Office of Commercial Space Transportation, there's, what, 125 people, probably about 20% of them are like admin staff. So like contracting, budget, HR. maybe like when you boil all that down, there's maybe like 20% of that are actually like the tip of the spear working with companies. And then maybe about another like 40 to 50% or like analysis or analysts. They're like, you know, the license evaluator will say, hey, software guy.

Like what do you think of this autonomous flight termination system code? And it's like thousands of lines of code. And I think now they have two people who can do that, maybe three, right? That's the stuff I wanted to pull out. Like, it's like single-digit people. These poor dudes have to evaluate the SpaceX spaghetti code that comes in. A very needed and defensible vacation sets them back that many weeks. You guys are like computer guys.

You've read other people's code and it's hard. I avoided heavily. Jake does teaching and stuff. I just basically work to free people and write all my own code now. The joke is that hell of other reasons

while Elon Musk is breathing over your neck. Imagine writing that hell of your eye. The amount of stuff that gets like like cluge together over a weekend at SpaceX because Elon got mad on Twitter. Like it's probably, there's probably been some real flunky stuff

that gets sent over it. And it might work, but it doesn't look pretty. It's probably not easy to read. So there are two days in there. There was two guys. two guys who did two men at the time when I was working at Asher, two males who did system safety. And system safety is sort of like the qualitative side of Part 450.

You describe how you're going to do things. And it's not like flight safety analysis or code where it's very qualitative. data. Like, you either meet the risk criteria or you don't, right? There's a lot of math behind it. System safety is, it's very subjective, frankly. And the FAA would disagree with that. They would say, oh, no, you know, we have an advisory circular and there's lots of precedent, you know, from the Air Force and NASA. But when it boils down to it, it's like the language in the regulation is, is the risk remote or extremely remote. What the hell does that mean?

And it's like, well, go to, you know, mill standard 882E. And it'll explain to you. Okay, so you're reading Mill Standard 882E. And there's this chart. And it's like, if you're in the red, it's bad. If you're in the green, it's good. It's like, well, like how many times do I need to test this gizmo to know if I'm in

the green? Well, it depends. It's like, what? Just tell me. me what I need to do. And there were two guys at FAA who did that. And they were swamped. They're just completely, I think now they have more folks. I think they've trained up a couple more. But maybe there's half a dozen systems safety. And they are kind of like the arbiters of system safety. And now they have more resources to share with the industry than they did

when I was at Astra and they're learning and industry is getting better. But it's, I mean, system safety is still pretty subjective. And it's based on how NASA and the Air Force did it for like 50 years or whatever, which is not how commercial space can do. Like not how commercial space can afford to do it, number one. Yeah. And it doesn't need to do it. Like this isn't a nuclear missile.

This isn't a crude, well, in most cases it's not a crude spacecraft, right? In some cases it is. I've seen a lot of those in the last couple years. I don't know about that. Yeah, but for your average, you know, expendable, you know, launch vehicle that's just taking satellites up, like, flying NASA standards to that, filtered through FAA regulations can be challenging both for the applicant and for the FAA. And then you boil, and then there's just not a lot of people there to read all that documentation. I mean, we're talking about hundreds of pages of documentation, like P&ID diagrams, like computer computers. code. This is not like, you know, watching cartoons. Like, it's hard. You have to sit there and read it.

So, yeah, I think they do need a lot more resources. And it's, the other thing is like, your average person who has this experience, they can go work for SpaceX. They can go work for Blue Origin. They can work for like a million lunar lander companies. Or they can go be a regulator. That's tough. Yeah. Yeah, hard to feel that's a great point. Yeah, yeah. We need more budgets solely to get the talent.

Yeah, that's interesting. Yeah, exactly. Okay, so when I'm thinking about this, because we've had, you know, storylines of tension between the companies and the regulators, you know, over the last couple years. Most of it's centered around both Chica, obviously. But, you know, we've heard that narrative.

It's not just SpaceX, right? They've said that they're held back by regulations or whatever. And when I think about it, there's kind of like three possible reasons for that. And it's like a spectrum, right? So on like one side, you could have, it's like the companies just need to chill out. Like they're moving too recklessly and too quickly and too unsafely. And the regulations are causing tension for good reasons. That's like one scenario, right?

And then like you can move down the spectrum and it could be like the companies are fine and the regulations are fine, but FAA is just understaff. Like it's just like a resource problem there. Or you can move to the full other end of the spectrum. you can say, no, the regulations are garbage and they're making us do a bunch of stuff that we don't need to do. It doesn't matter whether the companies are doing well or the FAA is doing well. The laws are bad, right? Like, I kind of imagine this like spectrum. And I have a really, really hard time trying to figure out what's true when you figure out. When you ask that question,

why is there tension? Like, I just straight up do not know. And I'm just curious to know what you think I don't think there's nearly as much tension as everyone, like, thinks there is and, like, maybe wants there to be, like, people like drama. No. Yeah. Some shows have a whole alarm based on the concept of hot drama. So, like, let's take a little chill-fill on that. Yeah, yeah, yeah.

This is the not-hot drama. I haven't used it in years, but some shows. do have that. Yeah, yeah. There's not nearly as much tension as you think there is, but yeah, occasionally a company has to like pound the table and be like, come on, what is this? This is nuts. And, you know, I've been that guy and it's not fun.

But it usually doesn't work, frankly, because the FAA is like, look, you know, it's our way or the highway. What are you going to do? You know? Well, you're like also beholden, right, when you're in that position, you're beholden to stuff written down, whereas a company is beholden to stuff that they wrote down, which is different. Exactly. And so, and so the way those conversations usually go is the company, belly aches and wines and their CEO calls the administrator. And, you know, maybe they call some elected official and there's a big meeting.

Could tweet about it. A week a week goes, maybe you tweet about it. By the way, that never works. Hold on. Hold on. Hold on. I'm so shocked. Hold on.

Hold on. Don't tweet it. Like, that's not cool. From the other part of my life, there is an old adage in the original app store guidelines that Steve Jobs wrote himself that said running to the press never works. And it never works. No, it always works. Everyone knows it's the one thing you wrote that always works.

So I'm going to just hold out that this is the potential lifestyle guideline. It doesn't work for, It really makes things and I'll tell you why. It creates more churned. So for example, Jake Rocket Company, you're not satisfied with how quickly the FAA is processing your launch license. You call up Secretary Buttigieg, your friend, and say, Pete, I need my license. This is such a good timeline.

I love this. Yeah. Remember our time. Harvard when we were speaking Norwegian. That was awesome. And I don't think he went to Harvard. I don't know. I'm not going to back check it. He called B. Buttigieg. And he says, yeah, I got it. So when my point is, when a CEO calls a leader at the FAA, that goes down the chain of command. It's a bureaucracy, right? It's a, it's a, it's a level. And the guys that the people at the bottom actually doing the work have to create a briefing for all the those leaders. So instead of working on your license, now they're like creating a slideback and

explaining to the executives what's going on. And the executives are going to be like, oh, okay, thank you for that briefing. Good job. You know, please continue your work. And a week has gone by. So it doesn't work because once again, there's like three people doing this as you're right. If there was 100, it might work. So we'll bring it back then. Maybe. the manager of the guy running through the code should be able to take that medium while he keep running to the judge. We got to wait until we get more middle management in that layer. That's the solution.

More middle management. We figured it out. Jake, honestly, you're perfect for the- I don't know why the government hasn't figured this one out yet. This seems like it's a really good like- Call. Give Pete a call right now. Have you considered? I think you're like three buckets there.

like all three, there's truth in all three of those, right? Like the companies sometimes screwed up. There's not enough people. We talked about that. But like, the regulations are kind of garbage too. I want to hear what the FAA people are mad about. Like, we never hear that story. And you don't work there anymore, so you can tell us.

Yeah. No one's listening to this show. It's just us three. It's fine. Right, right, right, right. Disregard the hockey stadium people listen. It's fine. So part 450, let's talk about the creation.

story of Part 450 for a second. And the short answer is both the FAA, like the FAA had a lot of problems with the previous regulations. They weren't perfect either. Surprise, surprise. And industry was like,

these regulations stink. We want better regulations. We want to streamline the regulations. That was the buzzword. We're going to streamline the regulations. And FAA is like, all right, cool. Yeah, we agree. I mean, FAA didn't have a choice

because the president was like, do this. Yes. We'll do. Which was good because FAA was like, yeah, we wanted to do this anyway. It typically takes like eight to ten years to do regulatory streamlining. And the White House was like, do it in do it now, do it immediately. And we're like, we could do it in two years, which is lightning fast.

And so that got done. But because it was done very quickly, a lot of the like support resources that usually go with a new regulation, like the advisory circulars and the training, right, for the people who are going to actually, you know, evaluate the submittals that are made under the regulation. That was not done, right? And so you may, some of your audience may recall,

like part 450 was rolled out. It was made effective. And then there was like a year where there were like, I don't know, a dozen advisory circulars. And advisory circulars are like the FAQs, like the how-toes. Like, you know, Jake Rocket Company, you have to comply with Part 450. If you don't know what these words mean, read the advisory circular and it will explain it to you. And not only that, it will give you a way to comply with the regulation, which also didn't exist when Part 450 became affected.

Now, they're like, to get out of jail, not a get out of jail free card, but like, the way this was mitigated was the old regulations there, the legacy regulations, they are still in existence. So like the Falcon 9s are all still flying under the old regulations, Part 417. And those regulations will remain in place until like 2026. So like Falcon 9 is good. What else? Virgin Galactic, like they're good. You know, anything that had a license before Part 450 is good.

It's all the new vehicles and the new operations. So Starship, Astra, Relativity, go down the line, ABL, you know, all the new, new folks that need to comply with Part 450. And so what, what doesn't the FAA like? The FAA doesn't think when an applicant shows up and they're like, we don't know how to do this because you don't have the support documentation, but here's our best shot. which leads to what I talked about earlier, turn, where the FAA is like, no, this is garbage. Like, this is not at all what we meant, you know. And so iteration, turn, turn, turn.

The other problem with 450 is the old regulations used to be very formulaic. It was basically, there was one cookbook you had to follow to get your license. And that was good because it was very predictable, but it was bad because it was very inflexible, right? If you were not a vertically launched expendable vehicle like an Atlas 5, it was really hard for you to get a launch license. You had to kind of like collage the operation into these very inflexible regulations. Well, 450 is much more flexible.

Now it's, I forget what the phrase is, but basically instead of telling you how to do it, we just say, look, you just have to meet this level of safe. safety and you can choose your own adventure. Yeah, you can make a spin launch if you want. Like, we're not deciding that your thing will work, just that it won't kill anyone else that you didn't expect to be in danger. The body monster, anti-gravity machine, like, whatever. My stupid, a vertical dogleg machine.

Yeah, yeah, you can do whatever you want. Stupid, side story, like, we had a guy who would come regularly with his anti-gravity machine. SvDM. And it was wild. Yeah. Anyway, you had a guy that would, wait, hold on, I cut off a great story. Yeah, we had a guy who would, who would submit his, like, plans for his anti-gravity machine. And we have, you know, somebody comes in and they say, I want a license.

And you have to look at it and be like, this does not. This does not comply with the laws of physics. And actually, if you read the, there's a line in the regulation somewhere where it's like, applications must, like, comply with the laws of physics. Like, it has to be obvious on its face that there's come. Because we have so many people showing up with, like, random stuff. We're like, I want a launch license. And it's my right, you know?

I'm like, no, it doesn't comply. I'm part of that. I got to pull this up. Yeah. So, for my laser-powered dolphin. writing machine. Yeah. Incredible.

I love it. Oh, wow. So, but under 450 now, it's, it's like kind of like choose your own adventure. You get to, and what that means is like, instead of a, like, immediately getting into the like evaluation of a company's cookbook, right? Like, oh, have you, have you met this regulation? Check the box. No, no, no.

The first like year or, you know, hopefully less as time goes on. But in recent history, it's taken many, many months for the FAA and the company to agree on the ground rules, right? This is how we, the company, propose to meet the regulation. Do you FAA agree? And the FAA will be like, no, we do not agree. And here's why. Or, yeah, we do agree. And, you know, that takes a while.

and then the applicant can be like, okay, here's all of our data per the rules we just agreed to, please evaluate this. Right, right, right. And by the way, the Fish and Wildlife Service might be like having all sorts of concerns. And the air traffic control folks might have issues. Like there's all these other entities outside of just AST in Part 450 that are also like the company has to respond to. And I think that's part of the frustration that companies have with just the licensing process in general is that not only is the core licensing stuff really complicated and becoming more time intensive under 450, but like all these other government entities now are like, it seems like they're just getting involved for the first time. They've always been involved, right? But the rockets are getting bigger.

They're getting more complicated, using new fuels. And so now the Fish and Wildlife Service, for instance, is like, this is entirely new. Like, we don't know how a giant LNG-fueled rocket is going to behave and affect the birds and the turtles and stuff versus a typical kerosene fuel rocket. So all that means more analysis for the company and the government and so forth. This was some great end of your content here, Jake. I feel like we're sticking the landing on 2023 right here Hello Hello, everybody there?

No, I'm serious I feel like I feel just I feel way better like Yeah, yeah Yeah My dreams of a vertical dog bike machine Have been dashed and The other like, you know

As you're wrapping up here The the possible like fourth scenario I'm just getting started Why? He's only halfway through his American greatness Stein or whatever that is over there No but You know

There's a possible like fourth thing on this spectrum of these three buckets they had, right? The fourth one could just be like everything's normal and we're just having an industry that's changing very fast and this has to just shake out and that's the process and it's okay, right? That'd be the other sort of like a perfect storm here where it's like industry is innovating like crazy demand for launch is through the roof. Yeah. There's there's a labor shortage generally but particularly in the federal government. The regulations have changed. The technology is changing. It's yeah. those folks at AST have very exciting but very challenging jobs in the best of times.

And this is like this is like crazy times, you know? Yeah. Okay. Yeah. All right. So I think the real facts we came away from here is don't tweet at the FAA. Don't tweet. Tom was definitely the guy flying to Boca Chica and you won't tell us.

It's a free country. You can tweet all you want. But it's not going to do it. Listen, Twitter is now his exclusive use zone, Jake. So there's no regulation he has to it. Exclusive access social media site. You don't need an operator. You don't need a license.

You don't need a license. Oh, man. We've got to do part two of this, Jake. This is, I feel like we barely got down your question list. I might need to, like, marinate on this and then, like, come back for more specific questions. So what are your guys's predictions for IFT3? When is it going to happen? Are you going to see it in before Q1, first three months of the year?

I think that's a pretty safe prediction. Yeah, I'm good with that. I'm good with that. I'm good with a March. I'm in there. I'm in there on before Easter. What do you think, Jake? Yeah, I'm on board with Q1.

It feels like, I know there's like a mishap investigation, but it feels like that one's going to be a lot more straightforward. then this one's fine it blew up two times they both were expected it's fine everything's good yeah i would have stamped this if i was in that office i would stamp the shit already that's good yeah hot staging works they clearly blew the hell out of that ron launch vehicle i was fine i'm going to stamp this paperwork before pete wooding it called me yeah yeah i'm good on that one it's fine i mean that was that super heavy explosion was had to be one of the biggest explosions in spaceflight history that thing was enormous like

All the videos were zoomed in and had to zoom way out to see how big an explosion was. So I feel like they did, they overcorrected. If anything, if I'm the FAA, I'm like, maybe you did a little too much on the whole flight termination system. Go halfway between where you were before and where you are now. That would be amazing. That's a word. Yeah, they're like, that was a lot. Got to tone that back.

Elon Musk is like, put more ordinance on. It's a little extra separation boost for the ship. Yikes, yikes. I can tell you that everybody in FAA, I mean, they don't like to share this. So this is some inside baseball, but they're fans too. You know, one of my favorite days at ASC, I think I may have shared this last time was during the first Falcon Heavy launch. And everybody was like cheering. And it was just like, it was a really exciting day in the office to see that vehicle go.

see those two boosters come back. I mean, yeah, they're human too. They put their pants on one leg at a time just like everybody else. And almost everybody loves a rocket launch. They wouldn't go into that job if they weren't one of us. Like these are 100% one of us, you know? Yeah. And so they have to be, you know, the like stiff regulator and kind of,

they have to be dick sometimes. Like they get it. It's part of the deal. But they're fans too. Right. Stuck the landing. There we go. Tom, where should people follow along if they are not checking out what you're working on these days?

Yeah, I mean, I'm on I'm on X. I'm on LinkedIn. Those are my two main hangouts. I think my, you know, send me an email, do email. Yeah, that's probably the best way to reach me. I'm pretty accessible. I like to chat with people. Can confirm.

Can confirm that. That's true facts right there, Jake. Speaking of Starship, though, next week, Jake, this is it. This is the Allf nominees. Off nominees next week. It's our favorite show of the year, all the weirdest and wackiest space stories that didn't go right this year or didn't go as expected, but in a whimsical fun kind of way. So we're going to look at, you know, Starship is going to make some entries into the list this year. Heavy performance this year on the Starship side of things, yeah.

Last year it was all about SLS, and this year it might all be about Starship. We'll see. But yeah, so that's coming up next week. We're very excited about it for our last show of the year. Sadly, no Astra entries this year, though, Tom, don't worry. Last year, they had a nice part of that last year. So we'll see if they return to the off nominees in future years, then that would be great. The space port company is not on the list.

I'll be happy. There's always hope, though. There's funny things we just for up still. Yeah, if you dropped that rocket and it shot out of your hand into the, see, that would have definitely been on the list, but... Yeah. No. No, it's a...

No, they didn't Jojo Rabbit that, at that point. I don't know if anyone's seen the movie Jojo Rabbit, but that's a good reference if you have. So, if not, I highly recommend that movie. It's hilarious. Hilarious. Hilarious reference. All right. Tom, thanks for being out.

My pleasure, guys. Anytime. And, uh, good holiday. Happy New Year and... For sure. See you later, everybody. Bye. Bye, everybody.

One, two, three, four. Bye.