When they made their announcement a couple weeks ago, I was interested to see that the interiors of the two fuselages of White Knight Two and SpaceShipTwo are identical. Virgin implied that they might be selling seats in WK2, either for passengers who just wanted a ride (with parabolas) or for future SS2 passengers. Which had me scratching my head. Had they considered the fact that WK2 is an airplane, not a spaceplane, and that it's in a different regulatory regime?
Maybe not:
The US Federal Aviation Administration has informed Flight that it will require WK2 to be certified before it is used for anything other than as a launch platform for SS2.
If it's a launch platform, then it falls under the launch license process by FAA-AST, but if it is used for other purposes, such as crew training, it is in a different category, and has to be certified by FAA-AVR, the much larger part of the agency that deals with aviation.
I've long been on the war path to get people to use these terms properly, because they really do mean things.
Certifying an aircraft under (presumably) Part 121 (and perhaps even the more stringent Part 127) for commercial passenger transportation (think of it as the FAA equivalent of NASA's elusive "man rating") is a long and expensive process. It can increase the development cost of the vehicle by anywhere from one to two orders of magnitude. As an example, there was a small executive jet was prototyped by Scaled for a couple million a few years ago, but it was estimated that it would cost a couple hundred million to get it certified. Which is one of the reasons that you can't buy one today. It never happened.
Now Virgin Atlantic Airlines is obviously familiar with FAA processes and procedures, and has an operators certificate. But they've never been involved with the development of an aircraft in the way that Virgin Galactic is now. My question is: does their business model account for estimated WK2 certification costs?
Which raises a second question. For this kind of market (informed passenger/adventure travel) is the current FAA certification regime overkill? This is the issue that prevented Zero G from going into operation much sooner--they had a certified aircraft (a Boeing 727) but it wasn't certified for parabolic flight, and they had to spend years and a lot of money (I have no idea how much, but I imagine millions) to get a special type certification for this flight regime. So while we've made good progress in loosening the constraints for space flight, one wonders how much more progress we could have made (and how much less viable WK2 is from a business standpoint) because of our one-size-fits-all aviation regs?
Wanders by, reads the stuff, bites lip to avoid obvious statements (but this very topic has been discussed around these parts and similar many times) and wanders off again.
If the FAA regs are too costly, well, nobody is forcing Virgin to have their launches in the USA. I am sure that there are some nations out there that would welcome Branson... the Isle of Man, perhaps?
I think that a Manx company would still be subject to UK regulations, and it currently has none with respect to launch, and they're largely equivalent to the US for aviation.
Which raises a second question. For this kind of market (informed passenger/adventure travel) is the current FAA certification regime overkill?
Yes.
However, I think there is a broader question whether the current FAA certification regime isn't overkill in all markets.
Nobody is going to operate an airline using aircraft that are not up to the design, production and testing standards of Boeing and other first-rate manufacturers. Nor would Boeing et al lower their standards in the absence of an FAA certification process. Even if Boeing didn't care about safety, there is too much liability for Boeing shareholders to accept less-than-best standards. And no insurance company would insure an airline that didn't use safe equipment.
For general-aviation aircraft, where certification costs probably represent a larger proportion of design and development costs than they do for large, transport aircraft, FAA certification resembles drug regulation. By this I mean that high regulatory costs probably discourage innovation that in the long run would improve safety more than regulation does.
I'm pretty sure that the Isle of Mann would be subject to CAA authority for aircraft operations.
Isn't there a global agreement for passenger aircraft operations which would make it hard to find a country to operate from where the application FAA/CAA regulations wouldn't apply?
South Africa has some pretty relaxed rules about passenger flights in combat aircraft, as does Russia, but I'm not sure that's an equivalent case.
Rand, They did in fact suggest a at least one or two ancilliary markets at the announcement, which I mentioned in my writeup the other day. All those that they mentioned were for use _after dropping SS2_. But I assumed they might be looking to separate 'lone' flight versions of these, as well as others.
Clearly the lone flights fall under the fAA statement. Unfortunately I suspect the ones done after dropping SS2 would as well...
While I don't like the FAA's action, it doesn't surprise me. It's one thing to use WK2 to carry SS2 to drop altitude. It's another to use it as a paying passenger carrying aircraft. Under current FAA regulations, they don't have much latitude in requiring WK2 certification.
Certification is a very expensive process. It involves not only expensive flight testing of the aircraft but also of the production process (since they want to build more than one WK2, IIRC). The engines, avionics, and all systems also have to consist of certified components. That means if they use custom avionics like they did in WK1 & SS1, they'll have to certify those as well. None of this is cheap.
For general-aviation aircraft, where certification costs probably represent a larger proportion of design and development costs than they do for large, transport aircraft, FAA certification resembles drug regulation. By this I mean that high regulatory costs probably discourage innovation that in the long run would improve safety more than regulation does.
Ain't that the truth! Even modern aircraft piston engines mostly use magnetos for the ignition system that belong on a 1930s tractor, not a modern airplane. FADEC technology is available but only on a few piston engine designs. It's disgraceful. Today, it can cost well over $20 million to certify a two seat fixed gear lightplane for production. A small bizjet can cost a few hundred million dollars to get certified and in production (ask Eclipse).
Perhaps Branson believes they can begin SS2 operations without carrying passengers in WK2 until the revenue stream improves. I have no idea.
Here in Australia anybody can pay for a ride in all sorts of interesting aircraft - P51's through to 2 seat Mig 15's. Seems to come under some sort of "adventure aviation" category. Yes, there are accidents.
As these people are flying just for the experience and not to transport themselves from A to B it would seem quite reasonable that this kind of commercial aviation be distinct from the rest of commercial aviation which transports passengers and goods in order to get them to another place and which the FAA was really designed to regulate.
Homebuilt aircraft and the EAA are living proof that certification by the FAA of smaller aircraft long ago passed the point of diminishing returns. Fortunately my homebuilt has one magneto replaced by an electronic ignition which features such stunning innovations as variable ignition timing.