Input:
	Background

		The Commercial Space Transportation Industry

Space transportation is the movement of objects, such as satellites and  vehicles carrying cargo, scientific payloads, or passengers, to or from  space. In the United States, commercial space transportation is carried  out using orbital and suborbital launch vehicles owned and operated by  private companies. Key parties involved in commercial space  transportation activities include:
The commercial launch provider—the entity that conducts the  launch of a vehicle and the payload it carries.
The launch customer—the entity that pays the launch provider to  carry a payload into space. Customers include the U.S. government— which has not operated its own launch vehicles since the retirement of  the Space Shuttle in 2011 and primarily relies on commercial launch  providers to, among other things, resupply the International Space  Station, launch satellites, and carry out national security and defense  missions. Customers also include private companies, such as  satellite owners, and researchers.
The launch site operator—the entity that hosts the launch (or  reentry, or both) of the launch vehicle from its launch site. Almost all  launch site operators are either commercial launch providers or state  or municipal government entities.
The U.S. share of the global commercial space transportation market has  grown in recent years. For example, according to FAA, 64 percent of the  33 worldwide commercial orbital launches in 2017 occurred at U.S.  launch sites, up from about 48 percent in 2014.
Commercial launch providers currently use, and are developing for future  use, a variety of vehicles to launch payloads. Historically, launch  providers have carried payloads into orbit using vertically launched  expendable launch vehicles—those vehicles that launch only once. In  more recent years, a launch provider, SpaceX, has introduced launch  vehicles that can be reused for multiple launches, such as Falcon 9 and  Falcon Heavy, where one part or all of the launch vehicle returns to a  landing pad, either on land or on a converted barge offshore, after the  payload is launched into orbit. Commercial launch providers are also  moving toward reusable suborbital launch vehicles, some intended for  human space tourism. These vehicles include horizontal hybrid suborbital  launch vehicles, such as Virgin Galactic’s SpaceShipTwo, and vertical  reusable suborbital launch vehicles, such as Blue Origin’s New Shepard.  Figure 1 depicts examples of expendable and reusable vertical launch  vehicles.
Launch site infrastructure, and those who own and operate it, also varies  across individual launch sites. The type of infrastructure and its design  depends on the type of operations that the launch site supports. For  example, some launch sites may have a launch pad for vertical launches  but not a runway for horizontal launches; others may have infrastructure  specifically to support launch vehicle reentry operations. While many  different types and designs exist, figure 2 below shows a few examples of  major pieces of launch site infrastructure.

		AST’s Roles and Organizational Structure

Within FAA, AST is responsible for regulatory oversight of the commercial  space transportation industry. AST’s primary means of oversight is  licensing or permitting commercial launch and reentry vehicle operations  and non-federal launch sites, as well as conducting safety inspections of  licensed launch providers and site operators. AST is organized into three  management and support offices, including the Office of the Associate  Administrator, and five operational divisions—responsible for the majority  of AST’s primary mission areas, such as licensing and overseeing  launches. In addition, the FAA Reauthorization Act of 2018, signed into  law in October 2018, requires that AST develop an Office of  Spaceports. According to FAA officials, as of May 2019, the size and  design of this office have not yet been finalized.
AST’s workforce size is expected to increase to help accommodate  anticipated growth in the industry and AST’s workload (see table 1). As  of February 2019, AST had 104 full-time equivalent positions and an  operations budget of about $25 million—an increase of 25 full-time  equivalent positions and about $8 million since fiscal year 2015.

		Launch Licensing Regulations

FAA requires launch providers conducting a launch or reentry within U.S.  borders to obtain a license or permit, as well as those conducting a  launch or reentry abroad, if the launch provider is a U.S. entity. FAA  considers a commercial launch to be one in which the contract for the  main payload’s launch was open to international competition or the  launch was privately financed without government support.
FAA also requires, with some exceptions, a site operator’s license,  which authorizes an entity, such as a state or local government, to host  commercial space launch operations from a specific launch site. FAA is  to conduct safety inspections of licensed commercial space transportation  launch operations, which involves monitoring of pre-operational,  operational, and post operational activities.
In February 2018, the National Space Council recommended that DOT  update the regulations on launch and re-entry licensing to better  accommodate changes that have occurred in the industry. The White  House subsequently directed DOT to publish a proposed rule by February  1, 2019, with a revised framework that allows more flexibility in how  companies can meet the regulatory requirements. DOT published a  notice of proposed rulemaking for the revisions to its licensing regulations  in April 2019.

	Funding for Infrastructure at Active U.S. Commercial Launch Sites Has Shifted from Federal to State, Local, and Private Sources

		Federally Funded Construction

Around the mid-20th century, the federal government began constructing  the infrastructure that supports the majority of commercial orbital space  launches today. The Department of Defense (DOD) constructed launch  sites to support ballistic missile testing and satellite launches, including  sites that are now home to Cape Canaveral Air Force Station in Florida  and Vandenberg Air Force Base in California. Those sites conducted their  first test launches in 1950 and 1958, respectively. The National  Aeronautics and Space Administration (NASA) was created in 1958, and  began acquiring land adjacent to Cape Canaveral Air Force Station in  1962 to support its human spaceflight lunar program; this land is now  home to the Kennedy Space Center.
In recent years, nearly all FAA-licensed launches in the United States  occurred at three federal ranges, which were originally built by the federal  government (see fig. 3). All 61 of the FAA-licensed commercial orbital  launches from 2015 through 2018 occurred at launch sites that are on or  co-located with federal ranges, with 44 of the 61 launches taking place at  Cape Canaveral Air Force Station and Kennedy Space Center  (collectively referred to as “Cape Canaveral”). In addition, one of the 11  licensed commercial suborbital launches occurred at a launch site co- located with a federal range.
While the federal government made the initial infrastructure investment at  federal ranges, the launch complexes used for commercial launch  operations at these sites are now operated under use agreements by  non-federal entities, such as state governments or commercial launch  providers. For example, four of the launch complexes at Cape  Canaveral are operated by commercial launch providers, while two others  are operated by the State of Florida. Two other federal ranges have  launch pads that are also operated by non-federal entities—Vandenberg  Air Force Base in California and the Mid-Atlantic Regional Spaceport,  which is co-located with NASA’s Wallops Flight Facility in Virginia.
The Air Force and NASA generally still have responsibility for maintaining  common-use infrastructure—that is, infrastructure that may be shared by  multiple users, such as access roads and fuel pipelines. As part of the  operators’ use agreements (the details of which vary depending on the  launch site and launch site operator), however, funding for improvements  to infrastructure used solely by that site operator is generally left to the  site operator. This arrangement is in part because the infrastructure  improvements are necessary to support the unique needs of specific  commercial launch vehicles using those sites.
At another launch site, the federal government followed a different  infrastructure investment model. In the 1990s, the Air Force partnered  with the state of Alaska to help fund the construction of a state-owned site  to support federal government launches and missile testing rather than  constructing a new federal range. This site, known as the Pacific  Spaceport Complex – Alaska, conducted its first government launch in  1998. Major infrastructure includes two launch pads with shared vehicle  integration and transfer facilities. According to spaceport officials at this  site, in addition to government launches, Alaska Aerospace, a state entity  that operates the site, has contracts with three commercial launch  providers, which anticipate conducting commercial orbital launches there  in the future. Appendix II provides additional information on launch sites  co-located with federal ranges, as well as funding sources and  characteristics for other U.S. commercial launch sites.

		State and Local Government Funding

While the federal government has not directly funded the construction of  infrastructure at launch sites in recent years, state and local  governments have done so. According to interviews we conducted and  our review of publicly available documents of state-government entities  that were formed to promote space-related development, state and local  governments are investing in infrastructure to obtain the economic  benefits of attracting space-related businesses to their areas. In two  cases, state governments became operators of launch sites co-located  with federal ranges and invested in infrastructure improvements at those  sites to support commercial orbital launch vehicles.
The Commonwealth of Virginia—through Virginia Commercial Space  Flight Authority, an independent state entity created in part to develop  and promote Virginia’s commercial space transportation industry— invested $90 million in improvements to a launch pad at the Mid- Atlantic Regional Spaceport. This represented a share of the total  costs, which were shared by Northrop Grumman Innovation  Systems, a commercial launch provider that has an agreement to  use the pad for commercial launches, including cargo resupply  missions to the International Space Station.
The State of Florida—through Space Florida, an independent special  district that serves the state’s space-related needs—has provided  over $140 million in infrastructure investments. Those investments  upgraded launch pads and the supporting infrastructure at Cape  Canaveral, as well as provided grants matched by commercial launch  providers for improvements to infrastructure used by those providers.
In other cases, state and local governments have invested in wholly new  commercial launch sites or are adapting existing airport infrastructure to  use as launch sites. According to these launch site operators, these sites  are currently used for suborbital launches but could support orbital  launches in the future.
The state of New Mexico funded the construction of the commercial  launch site known as Spaceport America through $225 million in state  appropriations and local taxes in two counties. The state also has a  20-year lease agreement with Virgin Galactic, which plans to conduct  commercial suborbital space tourism launches from the site. This  launch site, with its 12,000-foot-by-200-foot runway, hosted one FAA- licensed suborbital test launch in 2018.
In California, the Mojave Air and Space Port (Mojave) is a general  aviation airport that obtained an FAA license to conduct commercial  suborbital launches in 2004. In addition to continuing its general  aviation operations, Mojave currently provides a runway and mission  preparation area to commercial launch providers testing vehicles  designed for orbital and suborbital launches. This site hosted three  FAA-licensed suborbital test flights in 2018. According to a  representative from Mojave, the site generally funds infrastructure  maintenance with rents and user fees, while launch providers build  their own facilities. In July 2018, Mojave also received a $1.4 million  grant through FAA’s Airport Improvement Program for the purpose of  extending an airport taxiway. According to a Mojave representative,  the location of the taxiway extension will be available for hangar  development by both aviation and commercial space users on a first- come, first-serve basis. The project was completed in April 2019.

		Private Funds

Commercial launch providers fund infrastructure improvements at existing  launch sites—both co-located with federal ranges and elsewhere—to  ensure the sites are tailored to their unique launch vehicles. For example,  under its agreements to use launch pads at the federal ranges at Cape  Canaveral and Vandenberg Air Force Base, SpaceX representatives told  us they invested “hundreds of millions” of dollars in new infrastructure  and infrastructure improvements, such as constructing new liquid fuel  lines and improving launch pad cooling systems. According to SpaceX  representatives, the company made these investments to support the  specific needs of its launch vehicles and the rapid pace at which it is  currently launching. Virgin Galactic and Stratolaunch—two other  commercial launch providers developing suborbital and orbital launch  vehicles, respectively—funded the construction of hangars and testing  facilities for their launch vehicles at Mojave Air and Space Port.
Three of the seven commercial launch providers that we spoke with  constructed or are currently constructing new launch sites for their  exclusive use. Representatives from two of them said doing so allows  them to schedule launches without having to compete with other launch  providers at existing launch sites. Two of these commercial launch  providers also told us they had not received any government funding for  these sites, while the third told us it had received some support from the  state government where the site is located.
As the commercial space transportation industry continues to evolve, it  may lead to more investments in launch sites that are not currently  supporting commercial orbital launches. For example, some commercial  launch providers are developing launch vehicles consisting of a rocket  launched from an airplane in flight, enabling launches from runways  rather than launch pads. This could change how and which entities fund  launch site infrastructure.

	Launch Customers in Our Review Consider the Launch Provider’s Capabilities and Price, among Other Factors, When Deciding Where to Launch

Commercial space transportation is a global industry. We identified seven  countries, including the United States, that have launch providers with the  capability to support an orbital launch of a commercial payload (see fig.  4). In 2017, 7 of the 22 FAA-licensed launches conducted in the United  States contained a payload from a non-U.S. launch customer, including  several communications satellite operators and one civilian space  agency, according to FAA. Similarly, some U.S. launch customers we  interviewed said they have used non-U.S. launch providers.
According to representatives of the seven domestic and non-U.S.  companies we interviewed that use launch services for placing their  products into Earth orbit or other trajectories, several factors influence  their selection of a launch provider. Many of these representatives  acknowledged that as part of their business decision, a prerequisite is  that the launch provider’s vehicle and launch site must have the  capabilities to meet the customer’s mission requirements, such as having  the capability to bring the payload to the desired orbit at the desired time.  That capability, in turn, depends on factors such as the lift capacity of a  provider’s launch vehicle—which dictates the maximum weight the  vehicle can carry—and the geographic locations of its launch sites. For  example, launch vehicles operating from sites closer to the equator can  place payloads into certain orbits using less fuel due to Earth’s rotational  velocity. The direction a launch vehicle can travel from a launch site also  affects the orbits into which the vehicle can most efficiently place a  payload. For example, Vandenberg Air Force Base in California—which  allows launch vehicles to travel west over the Pacific Ocean—is more  efficient for certain orbits, while Cape Canaveral—which allows vehicles  to travel east over the Atlantic Ocean—is more efficient for others.
Beyond selecting a launch provider that has capabilities to meet a launch  customer’s mission requirements, six of the seven launch customers we  spoke with said the price of a launch is a key deciding factor. For  example, a representative from an international satellite operations  company told us that the company achieved significant savings by  procuring a series of launches from its selected provider. According to the  representative, using a different launch provider would have cost almost  twice as much—a price that would have forced the company to delay its  launch plans. According to data published in FAA’s Annual Compendium  of Commercial Space Transportation: 2018, there is wide variation in the  commercial price of launches worldwide, ranging from an estimated $62  million to $178 million per launch. The exact price paid for many  launches is considered proprietary by both launch customers and  commercial launch companies, and is therefore not reported publicly.  Moreover, price can be affected by the size and weight of the payload,  the intended orbit being reached, and other mission-related factors. As a  result, direct comparison of launch prices is difficult.
In addition to price, a launch provider’s availability and reliability are also  key factors, according to launch customers we spoke with. Six of the  launch customers we spoke with mentioned availability as a key factor,  which is the launch customer’s ability to reserve a place on the launch  provider’s launch schedule. For example, a representative from a  domestic small satellite operations company said it can be difficult to find  available launches in the United States because the company relies on  sharing launches with larger payloads, and few U.S. launches travel to  the company’s desired orbit. As a result, the company has procured  launch services from Indian and Russian launch providers. Five launch  customers mentioned reliability—generally a launch vehicle’s history of  successful launches—as a key factor, in part due to the financial impact  of a failed launch. For example, a representative from a non-U.S.-based  satellite operations company said that in the event of a failed launch,  insurance would generally cover the cost of the lost payload, but not lost  revenue that would have been generated by the payload in orbit.
Some launch customers noted that choosing a launch provider is a  complex decision, and that the key factors they consider can be  interdependent. For example, the representative from the non-U.S.-based  satellite operations company said that while a launch provider may offer a  lower price on a less reliable vehicle, the lack of reliability could increase  the customer’s payload insurance costs, effectively increasing the launch  price. A representative from a company seeking to launch into deep  space told us they would only consider a provider that is not only reliable  but also has years of successful operations and a proven business plan.

	DOT Published a Proposed Rule in April 2019 but Related Rulemaking Activities Affect When Regulatory Changes Will Be in Full Effect

		FAA Accelerated Plans to Streamline Regulations to Respond to a Presidential Directive

According to FAA officials, FAA has been considering changes in its  licensing regulations since 2015 and recently has accelerated these  efforts. Dating back to 2015, according to FAA officials, FAA had been  taking an iterative approach by first making “quick wins”—that is, making  administrative changes or straightforward regulatory revisions—with a  long-term goal of fully consolidating and streamlining the regulations over  a period of several years. FAA’s approach changed, however, when in  May 2018, a Presidential Directive was issued that addressed both the  timing and content of FAA’s regulatory updates. The directive contained a  deadline to publish a proposed regulation for public comment by February  1, 2019. It also directed the Secretary of Transportation to replace the  current prescriptive regulations for commercial space launch licensing—in  which a certain technology or action is required—with a regulatory  framework that is performance-based—in which applicants have flexibility  in how they achieve required outcomes, such as a specific level of safety.
In response to this directive, DOT published a notice of proposed  rulemaking (NPRM) in April 2019 to solicit comments on a proposed rule  that will incorporate performance-based requirements. According to  FAA officials, they had planned for the NPRM to be published by  February 1st, 2019, consistent with the deadline in the directive, but the  publication was delayed due to the lapse in DOT’s appropriations that  took place in early 2019. A timeline of key actions related to launch  licensing regulation is shown in figure 5 below.
The preamble of the NPRM states that the proposed rule intends to  satisfy the requirements of the Presidential Directive, including  consolidating and revising multiple regulatory parts to apply a single set of  licensing and safety regulations across several types of operations and  vehicles, and replacing prescriptive regulations with performance-based  rules. The preamble further states that these changes will give industry  greater flexibility to develop means of compliance that maximize their  business objectives while maintaining public safety.
The proposed rule also seeks to address recommendations made by an  Aviation Rulemaking Committee (ARC) that was created in March 2018  as a forum for industry to discuss procedures and requirements for launch  and reentry licensing. For example:
The ARC recommended that FAA propose rules to eliminate  potentially duplicative requirements for launches at federal ranges.  Currently, launch providers at federal ranges are subject to FAA’s  requirements in addition to those of the range operator (NASA or the  Air Force), which may be duplicative of each other. The preamble to  the NPRM states that, while FAA has not included language to  eliminate duplicative approvals, FAA would continue to work with the  appropriate agencies to streamline launch and reentry requirements  at ranges and federal facilities.
The ARC also recommended more flexibility in licensing such that a  single license structure could accommodate a variety of vehicle types  and launch or re-entry sites. The preamble states that the proposed  rule would, among other actions, eliminate the current limitation  specifying a launch license covers only one launch site.

		Completing Other Related Rulemaking Activities and Finalizing Guidance Will Affect When Applicants Operate under the Revised Regulation

As part of the rulemaking process, FAA must comply with a number of  requirements before the final rule can be issued. FAA is statutorily  required to provide a period of time to solicit public comments on the  proposed regulation. FAA must then reasonably respond to public  comments submitted on the NPRM and determine whether any changes  to the proposed rule may be required as a result of the comments. Some  changes made in response to comments would allow AST to proceed  with publication of the final regulation. However, major changes not  contemplated in the NPRM could necessitate a supplemental NPRM,  which could affect the timing of the final regulation’s publication.
FAA provided 60 days after publication in the Federal Register for the  public comment period. And, while officials told us that they plan to work  toward publishing the final rule by the end of 2019, the schedule was  affected by DOT’s lapse in appropriations. They also noted that the  quantity and content of the public comments and the time and resources  required to respond to them will influence that date. Officials estimate that  the public comments could number in the thousands. Further, there is a  lack of industry consensus in some areas. For example, according to the  cover letter accompanying the final ARC report, the report did not include  specific recommendations that were agreed upon by all participants.  Almost half of the industry stakeholders that participated in the ARC and  provided comments on the ARC final report (8 of 19) did not fully concur  with the report. Industry stakeholders disagreed on issues such as the  requirements for testing flight safety systems, which would be considered  as part of the licensing process. The lack of consensus among ARC  participants suggests that the NPRM may also generate significantly  different perspectives.
Furthermore, FAA officials emphasized that the NPRM addresses a  highly complex and technical issue, using a wholly revised performance- based regulatory framework, an approach that could affect  implementation timelines. We found in the past that the complexity of the  issues addressed by rulemakings is a major factor influencing the time  needed to issue a regulation.
FAA officials told us they intend to complete other related activities that  support the rule, such as finalizing guidance documents to provide  transparency and help ensure that licensing applicants understand the  new requirements. Such guidance may, for example, provide examples of  how to comply with the new performance-based requirements. FAA also  intends to implement new administrative tools to help AST review  licensing applications more quickly. Specifically:
Guidance: FAA released a number of draft guidance documents in  the form of Advisory Circulars with the NPRM. These Advisory  Circulars cover a range of topics, such as providing ways for  applicants to comply with requirements for flight safety analysis and  lightning hazard mitigation, and provide at least one way an applicant  could demonstrate compliance with each performance-based  requirement in the proposed rule. FAA officials told us that they plan  to publish these Advisory Circulars in final form simultaneous with  publishing the final regulation. Through the ARC process, FAA sought  input from industry on the standards that should be used to  demonstrate compliance with the performance-based regulations. In  the long term, however, FAA told us that they are encouraging the  industry to develop voluntary consensus standards that the FAA could  then accept as an acceptable way of demonstrating compliance.
Administrative Tools: FAA officials said they are in the early stages  of looking at ways to reduce the administrative burden on FAA and  licensing applicants during the licensing process. For example, FAA  officials told us that in 2019 they will be examining ways to automate  and streamline the licensing process. FAA officials told us that they  would like to implement a system whereby applicants, for the first  time, would submit applications electronically to an FAA-sponsored  system rather than by hard copy or attachments to an email.  According to the preamble of the NPRM, FAA’s proposal would allow  an applicant to submit its application by email as a link to a secure  server, and would remove the requirement that an application be in a  format that cannot be altered. In addition to easing the burden of  developing paper applications, FAA officials told us they envision that  an electronic system would enable both FAA and industry to view the  application during the application process and more easily  communicate about its progress.

	AST Has Taken Steps to Better Understand Current Workforce Needs, but Understanding of Future Needs Is Limited by a Lack of Information

In recent years, AST has improved some aspects of how it determines its  workforce needs. Our work on strategic workforce planning underscores  the importance of determining both current and future workforce needs  and identifying potential gaps in employee skills. The improvements made  to date provide AST with greater insight into the optimal number of people  currently needed in certain positions. However, these improvements do  not improve AST’s ability to systematically assess the workforce needs of  its management and support offices, nor does AST project its future  workforce needs. Moreover, AST has yet to collect information on staff  skills and competencies that would enable it to identify potential gaps in  those skills, gaps that further limit AST’s ability to effectively and  efficiently align its available staff resources with current and future  workloads.

		AST Has Improved Measurement and Analysis of Workforce Needs, but Only for Part of Its Office and within Its 2- Year Budget Cycle

To assist FAA decision makers in understanding and meeting AST’s  staffing needs, AST developed and annually updates a 5-year workforce  plan for its office. The current plan—covering the period from 2018  through 2022—indicates that AST’s approach for workforce planning has  a 5-year time frame. However, the plan discusses immediate workforce  and resource needs in general terms. One of the key principles we  identified in our prior work on effective strategic workforce planning is the  importance of determining the workforce needs that are critical to  achieving an organization’s current and future programmatic goals.  Such a determination of workforce needs should include both the optimal  number of staff needed in specific positions and the required skillsets and  levels of expertise for staff.
Since 2016, AST has taken several steps to better understand how it  uses its staff resources in carrying out its mission to license and oversee  space launch operations. The majority of AST’s operations budget— about 75 percent in fiscal year 2018—was used to fund salaries and  related expenses. AST now comprehensively monitors and measures  staff time spent on specific activities and measures and tracks the volume of its work—information it can use to better understand workforce  needs. AST officials told us that these steps facilitate more informed  decision-making about the number of staff needed in specific positions for  the next budget cycle. However, these steps do not provide the  information AST needs to determine the optimal size and composition of  its entire workforce or enable it to project workforce needs sufficiently into  the future.

			Revised Timecard System

AST launched a revised timecard system in June 2016 to more  comprehensively account for staff time spent on specific activities.  According to AST officials and our review of relevant documentation,  including a list of revised time codes, the revised system allows staff to  record hours worked on individual tasks, such as launch observations or  consultations with launch companies prior to application submission (i.e.,  pre-application consultation), training, and leave. Time codes were  revised for all AST staff—that is, staff in its five operational divisions,  management office, and two support offices (see fig. 6)—to account for all  major tasks they perform. AST officials told us that the new timecard data,  in combination with workload metrics, can help inform its current  workforce needs.
For its five operational divisions, AST officials have developed and  continue to refine a set of workload metrics, which, along with other data,  enable AST to identify the resources that are used to carry out key AST  activities, such as licensing and overseeing launches. These metrics track  the number of work activities (e.g., regulatory waivers issued or safety  inspections conducted) that are ongoing or were completed over a certain  time period. For example, in fiscal year 2018, AST was engaged in pre- application consultations with about 23 commercial launch providers and  was evaluating more than 16 license applications on average per month.  Officials analyze these metrics in combination with timecard data to  determine the number of staff hours and average number of days spent  completing specific activities. For example, between March and August  2017, FAA officials reported that for each ongoing project, staff spent an  average of about 60 hours per month on pre-application consultations.  Officials plan to use the results of this analysis in the fiscal years 2021– 2022 budget cycle to help estimate the number of staff currently needed  in specific positions within its five operational divisions.
However, with regard to its management and two support offices— which  represent about one-third of AST’s total staff—AST has not yet developed  workload metrics. Staff in AST’s management and support offices are  responsible for overseeing research and development; advising and  assisting other offices on technical matters; coordinating and liaising with  international entities and other federal agencies; as well as performing  other support operations, such as budget and financial planning.
Officials told us that although they would like to develop these metrics,  they put the effort on hold because of competing priorities within AST,  such as updating its licensing regulations. Officials said that they had first  focused on better understanding the workforce needs of the operational  divisions, which have responsibility for the majority of AST’s primary  mission areas, such as licensing and overseeing launches. In discussing  this approach AST officials stated that recent budget constraints have  limited their ability to address all of their current identified workforce  needs, which, according to their most recent workforce plan, are in nearly  all areas of their office. As a result, officials said that they use their limited  number of authorized positions to fill their most immediate workforce  needs, typically in the operational divisions.
However, without workload metrics that would allow AST to determine the  number of staff needed for its workload regardless of what office or  division, it is difficult for AST to determine the appropriate number and  composition of staff to most effectively carry out its statutory priorities and  help ensure that it uses its limited resources in the most efficient way. In  addition, AST officials told us that they recognize that past hiring  decisions and balance of workload among staff may not have been fully  aligned with AST’s statutory priorities and that the composition and ratio  of staff may no longer be appropriate given the evolution of the industry  and the revised regulatory structure under way. As a result, officials  stated that in the coming months they intend to take a fresh look at the  organization of the Office of Commercial Space Transportation as a  whole to better balance the needs of the industry with the organizational  requirements. In addition to developing an Office of Spaceports, as  required by the FAA Reauthorization Act of 2018, officials told us that  they will consider re-organizing the offices and divisions, as well as the  workload and staff currently within them.

			Workload Projections

AST also has taken steps to improve its ability to estimate its workload for  a 2-year budget cycle, which, according to AST officials, will help them  determine and justify near-term workforce needs. Specifically, from the  new workload metrics discussed above, AST officials told us they had  identified five key activities that best reflect historical workload trends  and that officials then plan to combine with their assumptions about how  the industry will evolve over the next 2 years. Officials told us that they  plan to use this approach for the first time in the fiscal years 2021–2022  budget cycle. In past budget cycles, AST relied primarily on the projected  number of launches to estimate its workload; this number, officials noted,  is the most important factor but resulted in an incomplete reflection of the  five operational divisions’ workload. For example, officials told us that the  workload of its operational divisions encompasses a range of activities  leading up to a launch that would not be captured in its workload  estimates if AST only looked at the number of launches. Now, under their  planned approach, AST officials said that they will better account for the  full range of regulatory activities and the timeline of its licensing process.
While planned improvements to AST’s workload estimates better account  for the full range of AST’s regulatory activities, limiting these estimates to  the 2-year budget cycle reduces AST’s ability to anticipate and respond to  emerging workforce needs. AST recognizes the importance of longer- term workforce planning by developing and annually updating a 5-year  workforce plan. Also, as noted above, key principles for effective strategic  workforce planning emphasize the importance of forward-thinking  planning to help organizations align their workforce to meet future  programmatic goals. According to AST officials, they estimate the  workload for 2 years in part because it is intended to help them identify  and justify workforce needs during the 2-year budget process, as well as  prioritize addressing immediate workforce needs. Officials also said that  substantial uncertainty surrounds longer-term industry forecasts, and  consequently, any assessment of longer-term workforce needs. For  example, they pointed to a number of factors that lead to the  unpredictability of how the industry will evolve, including the variable pace  at which new launch companies progress and the future of the  commercial suborbital launch sector, particularly the nascent space  launch tourism industry. They also noted that a launch vehicle accident or  other risks could affect the industry’s rate of growth.
In our prior work, we have discussed some approaches used by other  agencies to help assess future workforce needs when faced with  uncertainties. One approach involves scenario planning, in which a  federal agency operating in a changing environment used a range of  scenarios, each of which represented different future environments that  the agency may face, to help predict how the scope and volume of its  activities might change in each scenario. For AST, such an approach  could entail developing a range of workload projections based on different  industry and regulatory environments that it thinks it may face, along with  associated workforce management strategies to address those  environments.
AST officials said that they were considering projecting their workload  estimates further into the future and intend to work with FAA’s Office of  Aviation Policy and Plans—the office that helps develop FAA’s 20-year  aerospace industry forecasts—to leverage that office’s forecasting  expertise. However, AST has not established a timeline with milestones  or formally committed to conducting longer-term workload projections.  Longer-term workload projections may be particularly beneficial to AST to  help make well-timed decisions about hiring and training staff and to help  ensure AST has qualified staff available when they are needed. For  example, according to officials, it can take a few years for systems safety  engineers to be trained and have the sufficient experience to lead  projects. Further, AST officials told us that hiring technically qualified  personnel, including positions that require considerable training and  experience to be a fully functioning employee, is challenging. Without an  understanding of its projected workload beyond a budget cycle, AST will  be limited in its ability to effectively and strategically plan for its longer- term workforce needs and take action when the opportunity arises. As  such, AST remains at risk of not having the right number of staff in the  right positions to keep pace with and respond to changes in the  commercial space transportation industry.

		AST Lacks Information to Identify Gaps in Staff Skills and Competencies

Our prior work on strategic workforce planning underscores the  importance for organizations to determine the skills and competencies  that are critical to successfully achieving their current and future missions  and goals. Once the necessary skills and competencies have been  identified, key principles for effective strategic workforce planning call for  an organization to identify—and subsequently develop strategies to  address—gaps between the skills and competencies needed and those  that its workforce has. Those gaps should include both current skills gaps  (i.e., skills that its workforce currently needs but does not possess) and  emerging skills gaps (i.e., skills that its workforce may need in the future  but does not possess). Further, according to federal Standards for  Internal Control, an organization’s management should ensure that the  workforce skills necessary to achieve programmatic goals are continually  assessed. This step is especially important as changes in national  security, technology, budget constraints, long-term fiscal challenges, and  other factors may occur in the environment within which federal agencies  operate.
AST, however, does not currently collect the information needed for it to  conduct a skills gap analysis. Rather, AST has a basic understanding of  the skills and competencies of its workforce. For example, its current  workforce plan includes the following information on AST’s workforce:
Level of education—the percentage and number of employees having  attained bachelor’s, master’s, and doctorate degrees.
Occupation—the percentage and number of employees in mission- critical occupations (e.g., aerospace engineers).
Age—the percentage and number of employees by age range.
Tenure—the average number of years employees have been in their  current position and employed by FAA.
Retirement eligibility—the number of employees who will be eligible to  retire each year during the 5-year period of the staffing plan.
AST officials acknowledged that the workforce information it currently  collects is insufficient to allow them to systematically identify gaps in  specific staff skills or competencies—such as expertise in flight safety  analysis or launch vehicle propulsion—needed for evaluating certain  launch license applications. Officials told us that they do prioritize filling  positions, through hiring or contracting, that address the organization’s  most immediate needs. However, this strategy focuses on positions, as  opposed to identifying specific skills or competencies within those  positions.
AST officials told us that they are planning to develop and annually  administer to staff and managers a skills assessment survey that would  collect information about the specific skills and competencies that  individual staff currently possess. Officials told us that the results of the  survey would allow them to assess the current skills of AST’s workforce  and in combination with other information, such as expected attrition and  retirement rates, help identify current and emerging skills gaps. In July  2018, officials told us that they plan to complete the survey and  administer it in time for inclusion in their workforce plan for fiscal years  2019–2023, estimated to be issued in April or May 2019. However,  officials subsequently stated that their survey plans have been delayed  for multiple reasons, including DOT’s lapse in appropriations. Accordingly,  as of May 2019, AST had neither developed a draft of the skills  assessment survey, nor established a formal timeline for finalizing it or a  plan for periodically administering the survey. Furthermore, officials told  us that they are currently negotiating with the union’s bargaining unit to  gain approval to administer a survey that does not maintain anonymity to  non-management staff. They said that if they cannot obtain the bargaining  unit’s approval, they will need to develop an alternative plan because they  do not believe that collecting anonymous data on staff skills would allow  them to identify skills gaps for these staff.
Officials told us that they also intend to include in the survey skills and  competencies that may be needed in the future. They stated that they did  not know for certain if or how they would identify what those new skills  might be, but that they are considering soliciting feedback from industry  stakeholders, such as through FAA’s Commercial Space Transportation  Advisory Committee, to help identify any future competencies that may be  needed as a result of the evolution in the industry.
Without systematic information on specific skills and competencies of its  entire workforce, AST lacks reasonable assurance that its current  workforce possesses the requisite skills and competencies and may not  be able to efficiently identify opportunities to move staff within AST to help  address identified skills gaps. And, ultimately, AST may not be prepared  to make strategic decisions on how to address emerging skills gaps and  align its staff to achieve future programmatic goals, such as identifying  and acquiring potential new skills and competencies needed under a  revised regulatory structure.

	FAA Is Exploring Technological and Procedural Solutions to More Efficiently Accommodate Commercial Space Operations

		FAA’s Current Approach to Accommodating Launch and Reentry Operations Results in Inefficiencies for Airspace Users and FAA

FAA officials and representatives from the commercial space and aviation  industries we met with agree that FAA’s current approach to  accommodating commercial space launch and reentry operations into the  National Airspace System (NAS) is inefficient. FAA has the  responsibility for ensuring the safe and efficient use of the NAS, a limited  national resource, for and by all users, including commercial and  business airlines and commercial launch providers, among others. To this  end, according to FAA officials and documents describing operational  procedures and risk evaluation, FAA takes measures during a  commercial space operation aimed at preventing fatalities, injuries, and  property damage, and ensuring that nothing interferes with the launch  vehicle’s operations.
FAA’s current approach, as described in documents that explain how FAA  mitigates risk to people and property during a space launch, is to close  the airspace around a commercial launch operation—in some cases  hundreds of square miles for several hours—to other airspace users,  such as commercial airlines. Prior to launch, FAA establishes the size  and duration of the airspace closure, also known as an aircraft hazard  area, and, days ahead, notifies potentially affected airspace users about  the upcoming closure. FAA calculates the size and boundaries of the  aircraft hazard area generally based on the risk to life and property posed  by a launch vehicle’s expected trajectory, as well as potential trajectories  in the case of a vehicle’s failure and the subsequent paths of falling  debris. The duration of the closure is generally dependent on the period  of time in which the launch or reentry is expected to occur—known as a  launch window—which varies by the type of launch or reentry vehicle,  among other things. The aircraft hazard area extends from sea level up to  unlimited height, and generally does not change in size or shape during  the entirety of the launch window (see fig. 7).
According to FAA officials, the designated aircraft hazard areas are larger  and remain in effect longer than may actually be needed to ensure public  safety. For example, according to FAA officials and launch  documentation, to protect public safety, the duration of an airspace  closure is always longer than the launch window. In fact, in some cases,  the airspace closure may be scheduled for more than 3 hours, which is  substantially longer than the time typically required for space launch and  reentry operations from Cape Canaveral (about 30 minutes). FAA officials  explained that they are not able to monitor or respond to dynamic  circumstances associated with space launch vehicles in the NAS in real- time. As a result, FAA closes the airspace for when and where it is  potentially—rather than actually—hazardous.
FAA officials told us that the agency’s approach to date for  accommodating space launch operations into the NAS has helped ensure  public safety during launches. For instance, during fiscal years 1989  through 2018, FAA reported that it licensed 357 launches or reentries,  and in this time there were no fatalities, serious injuries, or significant  property damage to the uninvolved public. However, according to FAA  officials and research, FAA’s approach creates inefficiencies in how the  airspace around launch operations is used—such as causing flight delays  for commercial airlines. FAA officials and commercial space industry  representatives said it also makes scheduling these operations more  challenging for launch providers, and affects FAA’s operational efficiency.  The effects on each of these groups are described below.
Commercial airlines. FAA has estimated that, in fiscal year 2017,  about 1,200 commercial airline flights were directly affected—that is,  rerouted or delayed—around 22 space launch operations, resulting in  an estimated 39,000 additional miles flown. The majority of these  miles were flown in proximity to Cape Canaveral in Florida, which  hosted the majority of domestic launches that year. FAA further  estimated that, of the 15 space launches from January to October  2018 around Florida where airspace tends to be busy due to the high  volume of commercial airline traffic along the East Coast, an average  of 60 aircraft per launch were directly affected. For all commercial  launch sites, FAA estimates that the number of directly affected  aircraft ranged up to 153 for an individual launch with an average of  fewer than 10 aircraft per launch outside of the Florida area.  According to FAA officials, these estimates are based on historical  data on the number of aircraft that typically fly through that area at the  time of the airspace closure. Because launches can be delayed by  hours or days for reasons such as unforeseen weather conditions or  technological issues, airlines and other affected airspace users may  face challenges when attempting to plan around a launch to avoid  flight reroutings and delays. Representatives of a major airline trade  association told us that the spread of launch activity beyond Cape  Canaveral, as well as the development of new launch vehicles, has  heightened their concerns about inefficiencies in how airspace around  launch operations is used.
Launch providers. The size and duration of aircraft hazard areas can  make it difficult for FAA to find time slots to accommodate commercial  space launches because of its responsibility to ensure the efficient  use of the national airspace, a limited resource. All the launch  providers we spoke with that had conducted launches at U.S.  commercial launch sites said they have been able to find suitable  launch windows that met with FAA approval. However, one launch  provider told us of an occasion when FAA had denied the originally  requested launch date and time because it fell within a time of  unusually congested airspace. In addition, more than half of the  launch providers told us that they anticipate challenges obtaining  approval for a requested launch date or time in the future.
FAA. In addition to effects on NAS users, FAA officials told us that  FAA itself also experiences operational inefficiencies in managing air  traffic during launches. This inefficiency is, in part, because FAA’s  current policies and procedures were developed for aircraft operations  and either have not yet been fully adapted for commercial space  operations, or a relevant policy or process is missing altogether. For  example, FAA’s current procedures for launch providers and FAA to  follow when they request, schedule, and conduct launches require  different FAA facilities to negotiate unique agreements for each  separately licensed operation or activity. This process can be time- consuming. For example, one launch provider told us that it took 1½  years to finalize minor changes to a letter of agreement. As we  discuss later, FAA is taking steps to standardize these letters.

		FAA Aims to Increase Efficiency of Launch Integration through New Technologies, Procedures, and Industry Coordination

According to FAA documentation and officials we spoke to, FAA aims in  the long term to increase utilization of the NAS by integrating launch  vehicle operations into the NAS with other users, rather than its current  approach of segregating launch and reentry operations through airspace  closures. Specifically in 2011, FAA began identifying actions it could take  and developing plans to address challenges associated with closing  portions of the airspace during launch operations. It did so in light of the  increasing frequency of commercial space launch and reentry operations  and the spread of operations to new locations. According to FAA officials,  the actions and plans continue to evolve as FAA learns more and reacts  to anticipated changes in the commercial space transportation industry.
Further, officials told us that FAA’s vision for full integration of commercial  space launch operations cannot be defined by a single solution or an end  goal because the demands of these operations on the NAS are constantly  changing. Consequently, FAA officials said that full integration of  commercial space operations into the NAS will reflect a collection of  visions or approaches that improve predictability and efficiency while  maintaining safety. For example, according to FAA documents and  officials we spoke to, FAA’s approach for experimental launches will  always be to close the airspace around the launch to other users. In  contrast, FAA may develop standards for some launch vehicles, such as  hybrid launch vehicles with repeated successful operations, which specify  a safe distance and duration of separation in the airspace.
FAA has two key internal documents to help guide the development and  implementation of its actions as it seeks to better integrate commercial  space launches and reentry operations into the NAS and reduce FAA’s  operational inefficiencies.
A concept of operations: FAA officials expect to finalize a concept of  operations in 2019, which will provide a long-term, high-level vision for  FAA’s efforts to efficiently integrate commercial space operations.  According to FAA officials, it will describe, among other things, FAA’s  existing approach to and associated shortfalls in accommodating  commercial space operations, as well as proposed tools, policies, and  procedures to address those shortfalls. According to FAA officials, it  also will inform FAA’s current and future efforts to identify needs for  new or modified technologies, tools, procedures, and policies.
Roadmap for the Integration of Space Operations in the National  Airspace System (Roadmap): This document serves as a planning  and tracking tool for FAA’s operational arm—the Air Traffic  Organization—to use as it seeks to more efficiently manage the  airspace during commercial space launch and reentry operations  while maintaining safety. It identifies, prioritizes, and tracks the  specific changes needed to begin addressing the related shortfalls  that FAA officials told us will be discussed in the concept of  operations. According to the Roadmap, some of the activities are  exploratory, and FAA expects that new activities will be identified and  added to the development schedule as FAA continues to work with  stakeholders to determine how best to manage the airspace, and  conceptualizes and develops key technologies. The first Roadmap  was released in November 2016, and, according to FAA officials, FAA  plans to update it annually. FAA officials told us they expect to release  the third and most recent version in 2019. The activities it identifies  are divided into: short-range (to have been completed in calendar  year 2018); mid-range (through 2022); and long-range (through 2023  and beyond) time frames, during which FAA plans to develop and  incorporate new technologies, policies, processes, and regulations.
In completing the actions needed to implement the approaches outlined in  the Roadmap, FAA officials told us that they are actively working with  FAA’s Performance Analysis Directorate to develop a set of metrics to  measure the progress and effectiveness of its actions. Officials also  highlighted that because the demands of commercial space operations on  the NAS are constantly changing, as noted above, there is no defined end  goal. To this end, the purpose of any metrics officials develop will be to  help determine if their actions are helping increase efficiency while  maintaining safety, not measure their progress toward a goal of full  airspace integration. FAA officials told us they plan to have a set of  metrics completed by early 2019. Some of these metrics will likely use  currently available data, such as the number of aircraft rerouted and how  many additional miles rerouted aircraft fly, while others are still being  identified. Further, FAA officials told us that FAA coordinates actions  related to commercial space integration through an interagency working  group established in 2015. The group meets monthly and members  include officials from across FAA lines of business, as well as other  federal agencies, including the Department of Defense.
The Roadmap shows that FAA’s actions to better integrate commercial  space launch and reentry operations into the NAS include, but are not  limited to: developing new technologies; updating and assessing needed changes to policies, procedures, and  coordinating with aviation- and space-industry stakeholders.

			Technology

FAA’s technology efforts are related primarily to collecting real-time data  on a launch vehicle’s position and path, automatically generating the  required aircraft hazard area, and integrating those data into the existing  structure of the air traffic control systems. As a result, FAA officials said  that FAA may ultimately be able to dynamically change the size and  duration of the aircraft hazard area in some types of launches, thereby  reducing the amount and duration of airspace closed to other users.
In the short term, FAA is assessing how existing air-traffic control  technologies and procedures could be used to help reduce the effects of  launches on other NAS users. According to an FAA official, for example,  four initiatives currently used to manage air traffic during other airspace  constraints could potentially be used during space launch operations.  One initiative would enable air traffic controllers to strategically control the  number of flights approaching the aircraft hazard area so that if these  flights were in the hazard area at the time of a launch vehicle failure,  controllers could still clear the area quickly enough to protect public  safety. This FAA official told us that if they decide to pursue these  initiatives, they hope to complete some of the necessary steps to do so by  summer 2019.
For potential use in the longer-term, FAA is piloting prototypes of two key  technologies by running them alongside existing air-traffic control systems  during selected launches, thereby testing their capabilities without their  being fully operational.
The Space Data Integrator (SDI) is designed to receive real-time data  on launch vehicle position and movement and display real-time  aircraft hazard areas to enable improved situational awareness. FAA  officials told us that, as FAA is assessing approaches to shift from  static to more dynamic hazard area calculation capability, initial SDI  capabilities will likely be deployed in advance of more integrated and  improved real-time hazard area generation capabilities. In addition,  FAA officials told us that they are exploring alternative acquisition  strategies that could enable partial system implementation for the  technology by 2022. Because FAA has not made a final investment  decision, the date of system-wide implementation of SDI is unknown.
According to FAA officials, the Hazard Risk Assessment and  Management (HRAM) tool, if pursued, is intended to help  automatically communicate SDI data to air traffic control systems and,  in the future, to present air traffic controllers with information that  would allow them to decide how to best manage the airspace.  Officials also said that HRAM involves modifying an existing air traffic  management tool, currently has very limited capabilities, and is still  only under consideration as a possible approach. Over the next year  these officials plan to work on some of the tool’s components, assess  what types of data are valuable to air traffic controllers, and determine  whether to continue developing this technology or consider alternative  technologies.

			Policies, Procedures, and Regulations

According to the Roadmap, FAA has identified policies and standard  operating procedures that need to be created or updated to enable it to  better manage the operating environment during space launches. Actions  taken to date include, for example: developing training materials to inform air traffic personnel about  commercial space operations in the NAS; developing a high-level strategy for integrated space vehicle  operations going forward; and  standardizing the terms of reference for commercial space operations  for use by FAA, NASA, and DOD.
In addition, according to the Roadmap, FAA plans to standardize some  letters of agreement—the document specifying procedures that a launch  provider and FAA use to request, schedule, and conduct launches.  Officials said they hope to issue documentation of these changes by  September 2019. FAA officials told us that these changes will result in  letter of agreement templates for use by FAA. FAA officials said FAA also  plans to continue reviewing its regulations, policies, and procedures to  identify other areas that need updating or entirely new language.

			Industry Coordination

FAA is taking steps to foster coordination between commercial space and  aviation industries to help develop and increase buy-in for new and  revised approaches to improve the efficiency of the national airspace for  all users. Most notably, in November 2017, FAA chartered an aviation  rulemaking committee to examine the issue of equitable airspace access  among various users. Committee members include a mix of commercial  space transportation and aviation industry representatives. Topics being  addressed include identifying potential criteria that FAA may use when  considering competing user priorities for airspace, as well as potential  tools that could help mitigate the effects on other airspace users during  launch operations. FAA officials told us that the committee anticipates  issuing a report and recommendations to FAA in April 2019, and some  members of the committee highlighted that the meetings benefited their  understanding of other users’ unique needs; economic benefits; and  experiences with regard to integrating space operations.
Also, an FAA official said the agency has sponsored four “Industry Days”  events since 2014 for the commercial space industry. At each event,  multiple FAA offices discussed their roles and responsibilities associated  with space launches and answered questions from industry. For the first  time, at its 2018 event, FAA invited aviation industry representatives to  encourage continued dialogue between the commercial space and  aviation industries. FAA officials also noted that they solicited ideas on  priority actions from participants and are currently reviewing those ideas  to help inform their next steps. Separately, FAA expanded the  membership of its Commercial Space Transportation Advisory Committee  to include representatives of the aviation industry in addition to the  commercial space transportation industry to foster further dialogue  between these groups.

	Conclusions

The commercial space transportation industry provides a service that has  become essential to many aspects of government, business, and society.  The capability to launch payloads into space enables national security  missions, mobile communications, and scientific research, among many  other applications. AST’s role as a regulator of commercial space launch  providers is fundamental to the continued safe growth of the industry.  With the anticipated growth and potential organizational restructuring of  AST, as well as the evolution of the commercial space transportation  industry, it is vital that AST ensure that the size, composition, and skills of  its workforce are aligned with its projected workload, based on anticipated  future mission and programmatic goals. AST’s workforce plan states that  AST needs additional staff in nearly all areas. However, current budget  and long-term fiscal pressures heighten the need for agencies to  strategically manage their workforce, a process that includes making  strategic decisions about how and where to prioritize limited resources.  AST does not have a complete understanding of its current and projected  workload, nor does it know the number of staff and types of staff skills  and competencies necessary to meet those workload needs. Without this  information, AST risks managing its workforce reactively to a rapidly  changing environment instead of strategically planning for the future.

	Recommendations for Executive Action

We are making the following four recommendations to FAA:  1.  The Associate Administrator of AST should develop workload metrics  that encompass the whole office and that would allow AST to  determine an appropriate workforce size and composition.  (Recommendation 1)  2.  The Associate Administrator of AST should establish a timeline for  finalizing workload projections that extend beyond the 2-year budget  cycle and that include an approach for addressing uncertainty.  (Recommendation 2)  3.  The Associate Administrator of AST should ensure that its skills  assessment survey collects information from staff on skills and  competencies in those areas that are both currently needed and may  be needed in the future. (Recommendation 3)  4.  The Associate Administrator of AST should develop and document a  plan for periodically assessing whether staff possess the necessary  skills and competencies to achieve programmatic goals, such as  annually administering a skills assessment survey. (Recommendation  4)

	Agency Comments

We provided a draft of this product to DOT and NASA for review and  comment. In its written comments reproduced in appendix III, DOT  concurred with our recommendations. DOT and NASA also provided  technical comments that we incorporated, as appropriate.
We are sending copies of this report to the appropriate congressional  committees, DOT, NASA, and other interested parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at 202-512-2834 or KrauseH@gao.gov. Contact points for our  Office of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made major contributions to this  report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

Our objectives for this report were to: (1) describe how the construction of  infrastructure at selected U.S. commercial launch sites has been funded;  (2) describe key factors that influence where orbital launches occur; (3)  summarize actions the Federal Aviation Administration (FAA) has taken  to streamline its commercial space launch regulations; (4) examine how  well-positioned FAA’s Office of Commercial Space Transportation (AST)  is to determine its current and future workforce needs; and (5) identify  actions FAA is taking to better integrate commercial space launch  operations into the National Airspace System (NAS).
The scope of this report focuses on topics related to FAA’s oversight of  the U.S. commercial space transportation industry. Therefore, the report  does not discuss launch indemnification and the safety of human  spaceflight, or examine international outer space treaty obligations.
For all objectives, we reviewed relevant statutes, regulations, and  directives governing FAA’s oversight of the U.S. commercial space  transportation industry. In addition, we interviewed AST officials and  conducted semi-structured interviews with all seven commercial space  launch providers that had conducted an FAA-licensed launch operation  as of January 2018.
To describe how infrastructure at selected commercial launch sites has  been funded, we first identified, through review of FAA information on  launch site operator licenses and launch licenses, all U.S. commercial  launch sites—those that have an FAA site operator license to conduct  commercial launch operations and those that may not have a site  operator license but have hosted FAA-licensed launch operations. From  these 15 identified U.S. commercial launch sites, we selected 9 for review  because the launch site has hosted FAA-licensed launch operations  between January 1, 2015, and December 31, 2018. We reviewed relevant  publicly-available documents, such as launch sites’ business plans, user  guides, and other planning documents related to U.S. commercial launch  sites. We interviewed the eight launch site operators of the nine selected  launch sites. The perspectives of the selected launch site operators are  not generalizable to those of all launch site operators; however, the  information obtained provides a balanced and informed perspective on  the topics discussed.
In addition, we interviewed members of the Commercial Spaceflight  Federation’s working group on commercial launch sites. See table 2 for a  full list of entities interviewed.
To describe key factors influencing where orbital launches occur, we  reviewed data from FAA’s 2018 Annual Compendium of Commercial  Space Transportation as well as FAA data on recent launches within the  United States. We interviewed representatives from seven launch  customers, selected based on the following criteria:
The company is not a government entity.
The company’s payload was commercial, as documented in FAA’s  commercial space launch compendiums.
The customer had multiple launches in 2016 and 2017, with at least  one of those launches occurring in 2017.
The customer has had at least one launch in the United States that  was licensed by FAA.
Among the companies that met these criteria, we chose our final  selections to have a mix of the following characteristics: domestic and non-U.S. companies,  those that had launched exclusively at one launch site versus multiple  launch sites, and  those that are involved in traditional space activities, such as satellite  communications companies and remote-sensing companies and  those that are pursuing non-traditional space activities, such as  asteroid mining and satellite servicing.
The perspectives of the selected launch customers are not generalizable  to those of all launch customers; however, the information obtained  provides a balanced and informed perspective on the topics discussed.
To summarize actions FAA is taking to streamline its commercial space  launch regulations, we reviewed relevant statutes, regulations, and FAA  guidance. We also reviewed FAA’s documents related to the rulemaking,  including its schedule of rulemaking activities and the Streamlined Launch  and Reentry Licensing Requirements notice of proposed rulemaking  issued in April 2019, and reviewed and analyzed the Streamlined Launch  and Reentry Licensing Requirements Aviation Rulemaking Committee  final report. We interviewed FAA officials and representatives of the  Commercial Spaceflight Federation about FAA’s ongoing and planned  actions related to the rulemaking. Finally, we reviewed the minutes from  the June 2018 meeting and attended the October 2018 meeting of the  Commercial Space Transportation Advisory Committee, in which FAA  officials and industry representatives discussed FAA’s actions on the  rulemaking.
To examine how well-positioned AST is to make strategic decisions about  its current and future workforce needs, we reviewed FAA documents,  including its budget justification and workforce plans from the past 3  years. We also reviewed FAA’s year-end reports on its workload metrics  from fiscal years 2017 and 2018, and portions of FAA’s preliminary labor  analyses using its revised timecard data and workload metrics. We  identified key principles on effective strategic workforce planning from our  previous work to use as criteria to assess FAA’s actions. We interviewed  AST officials about their plans and actions to improve its workforce  planning and assessed those actions against the identified key principles  for effective strategic workforce planning. We focused our analysis on  those principles that are related to determining current and future  workforce needs.
To identify actions FAA is taking to better integrate commercial space  launch operations into the National Airspace System, we reviewed and  analyzed relevant FAA documents, including a document that discusses  FAA’s vision for integrating commercial space transportation operations  into the NAS and the Roadmap for the Integration of Space Operations in  the National Airspace System. In addition, we interviewed FAA officials  within AST, Air Traffic Organization, and the Office of NextGen regarding  their ongoing and planned actions for improving the integration of  commercial space transportation operations into the NAS. We also  interviewed industry stakeholders to obtain perspectives on this topic.
These stakeholders included representatives from Airlines for America, a  trade association for the U.S. airline industry, and from launch providers.  Finally, we attended an FAA-sponsored industry conference in October  2018 on FAA’s airspace integration efforts.
We conducted this performance audit from July 2017 to May 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: Selected Characteristics and Capabilities of U.S. Commercial Launch Sites

Table 3 shows selected characteristics and capabilities of U.S.  commercial launch sites included in our review of infrastructure funding.  Table 4 includes other U.S. commercial launch sites that did not have  FAA-licensed activity from 2015 to 2018 and were not included in our  review of infrastructure funding.

Appendix III: Comments from the Department of Transportation

Appendix IV: GAO Contact and Staff Acknowledgments

	GAO Contact

	Staff Acknowledgments

In addition to the individual named above, Heather Halliwell (Assistant  Director); Gretchen Snoey (Analyst-in-Charge); Namita Bhatia Sabharwal;  Giny Cheong; Gerald L. Dillingham; Camilo Flores; Joshua Garties;  Richard Hung; Delwen Jones; Elke Kolodinski; Maureen Luna Long;  Malika Rice; Travis Schwartz; and Andrew Stavisky made key  contributions to this report.