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Kistler Aerospace Corporation (Kistler), concerned that the proposed regulations governing expendable launch vehicles (ELVs) might serve as a model for rules governing reusable launch vehicles (RLVs), argued against including ground operations within a launch license. Kistler recommended, instead, that, for a liquid-fueled vehicle, launch be defined to commence with the fueling of a vehicle. In support of this position Kistler first noted that defining launch as commencing with the arrival of a launch vehicle at a federal launch range, may not or should not apply to the launch of an RLV, pointing out that although an "RLV may ‘arrive’ at the launch range initially, it thereafter returns directly and repeatedly to the launch range. Clearly, however, the RLV is not constantly in a ‘launch’ state." Kistler at 7. Kistler also argued against the FAA position that pre-flight activities constitute uniquely hazardous activities. "Many of these activities are entirely routine industrial activity and pose no unique hazards." Kistler at 7. Kistler maintained that subjecting all these activities to FAA review and prohibiting them without the issuance of a license would constitute an unnecessary and costly regulatory burden. Moreover, if the FAA were to require a license for ground activities, Kistler and its customers would have to sign cross-waivers with its contractor and subcontractors, its customers and the contractors and subcontractors of its customers. This, Kistler maintained, "would distort the normal commercial allocation of risk and legal remedies for fault and, consequently, would increase insurance costs to the licensee." Kistler at 7-8.
Kistler recommended, for a liquid fueled vehicle, that launch commence with fueling. This is because fueling is closely proximate in time to flight and may be directly attributable to space flight, unlike other activities, which Kistler characterized as routine industrial activities not directly attributable to space flight. Kistler at 8. Kistler did not describe the other "routine industrial" activities. Nor did it describe its basis for distinguishing between routine industrial activities and those that are directly attributable to space flight. Nonetheless, its point of view is interesting, indicating as it does, that there is an insurance market for ground operations, and one apparently affordable to a start up company such as Kistler.
Kistler also advised that it believes that an RLV launch ends with the landing of the RLV, and would include any "proximate consequences" of the landing. Kistler at 9. Kistler was silent with respect to what it considers a proximate consequence. Kistler would not include post-launch ground activities within the definition of launch.
Lockheed Martin also filed comments, which included correspondence from Marsh & McLellan, an aviation underwriter. Lockheed Martin stated that it "views with serious reservations the Office’s proposed definition of ‘launch’ that would narrow the scope of a license issued by the Office and effectively standardize the treatment of all launch systems from federal ranges, without regard for the[ir] unique attributes…." Lockheed Martin at 1. Lockheed Martin supported the FAA’s proposal to dispense with gate to gate as a means of defining launch, agreeing that it resulted in illogical exclusions. Lockheed Martin at 3. It maintained, however, that "vehicle at the gate" achieves the same illogical exclusions of hazardous activities depending on whether they take place before or after a vehicle’s major components arrive at a federal launch range. Lockheed Martin at 3. Lockheed Martin also believes that the FAA’s concerns regarding congressional report language were groundless. Lockheed Martin at 3-
4.
Lockheed Martin proposed that the FAA adopt an activity test to determine what may be included within the scope of a launch license. Lockheed Martin at 6. The FAA should "address hazardous risks associated with a particular launch campaign," presumably on a case-by-case basis for each license it issues. Lockheed Martin at 6. Lockheed Martin believed it would be instructive for the FAA, in considering hazardous risks, to consider the Public Law 85-804 indemnification that the Department of Defense contractually offers its contractors. Lockheed Martin at 5. It noted that DoD contracts for Atlas, Titan and Delta launch services provide government indemnification for "unusually hazardous risks," which include, in part, the burning, explosion or detonation of propellants, liquid fueled rocket engines or solid fueled rocket motors, or launch vehicles or their components during testing, transporting, launch preparation or launch. Lockheed Martin at 5. "Unusually hazardous risks" also include, according to Lockheed Martin’s list, the toxic or other unusually hazardous properties of propellants or inert gases, their constituent ingredients, or their degradation products and the flight or surface impact of launch vehicles or components or fragments thereof. Lockheed Martin at 5.
　
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