Appendix 13. Template for Memorandum of Assessment of Potential Impact on the NAS
Federal Aviation Administration (FAA) Order JO 7400.2, Procedures for Handling Airspace Matters, describes the commercial space launch reentry (L/R) site licensing process. The process includes development of a Memorandum of NAS Impact - Air Traffic Organization Space Operations (ATO Space Ops) must work with affected Air Traffic Control (ATC) facilities to conduct a NAS impact analysis of the proposed operation. As the Air Traffic Organization (ATO) point of contact (POC) for commercial space operations, the ATO Space Ops must provide a Memorandum of Assessment of Potential Impacts on the NAS to the FAA Office of Commercial Space Transportation (AST). The focus of this Memorandum (also referred to as “Memo”) is on the proposed L/R site's potential impact on the NAS from an airspace perspective. The Memo is ATO's documentation to communicate this information to the AST. Other organizations within the FAA conduct other analyses associated with the site licensing process, including environmental studies and safety assessments.
The purpose of the Memo is to:
• Identify and document any potential issues early in the site licensing process.
• Describe airspace characteristics (i.e., factors) and associated airspace operational implications to consider when evaluating a proposed commercial L/R site for a license. These factors form the basis for an airspace assessment process that can be:
◌ Applied consistently by ATO.
◌ Used by AST and ATO as they communicate potential airspace issues with the L/R site applicant.
◌ Used to educate L/R site applicants about NAS characteristics and how they can result in potential operational constraints.
• Provide the platform for discussions between air traffic facilities and ATO System Operations Services (AJR) Space Operations to determine whether and what types of operational constraints may be warranted for the proposed L/R site.
[This memo should be developed using the latest FAA template]
Date: [Date Memo is issued]
Subject: Memorandum of Assessment of Potential Impact on the NAS for Proposed [launch/reentry site name]
To: Office of Commercial Space Transportation (AST) [optional, point of contact name, title and/or office within AST]
From: Air Traffic Organization (ATO) [optional, point of contact name, title and/or office within ATO]
This Memo documents the FAA's assessment of the potential impact of the proposed [launch/re-entry site name] on the NAS from an airspace perspective. This Memo and any subsequent License to Operate a Launch/Re-entry Site (as defined in 14 Code of Federal Regulations [CFR] Part 420 and Part 433) do not relieve a licensee of its obligation to comply with all federal, state, and local laws or regulations and do not confer any proprietary, property, or exclusive right in the use of airspace or outer space. Additionally, this Memo does not, in and of itself, authorize a Vehicle Operator to conduct licensed or permitted launch or re-entry operations. It is part of and supplemental to all license and permit requirements, and is in no way intended to circumvent the terms and conditions contained in any license or permit issued.
The findings documented in this Memo are based on information provided by the site applicant. If any of these assumptions change, these findings may not apply and an update to the assessment may be necessary.
Additional information is provided in the following annexes:
• Annex 1, Airspace Assessment Factors
• Annex 2, Airspace Assessment Graphics
• Annex 3, NAS Impact Assessment Detailed Findings
Annex 1 Airspace Assessment Factors
This section provides details about each of the airspace factors evaluated and documented in this Memo.
Airports: This factor addresses the airports that may be affected by the proposed launch/re-entry (L/R) site aircraft hazard area(s) (AHA[s]). The airport types evaluated include: Commercial Federal Aviation Regulation (FAR) 139, public (non-FAR 139), private, and military. These airport types include heliports, seaplane bases, balloonports, glideports, stolports, and flightpark/airport. Operations counts consist of the number of airport arrivals and departures and should be included for FAR 139 and Public (non-FAR 139) airports.
Operational Considerations: Impact to airport operations can cause a ripple effect throughout the NAS. These impacts may include rerouting and delaying operations.
Airspace Class: Airspace of defined dimensions within which ATC service may be provided to instrument flight rules (IFR) and visual flight rules (VFR) operations in accordance with airspace classification. Within controlled airspace, all aircraft operators are subject to certain qualifications, operating, and aircraft equipage requirements.
Note: The Memo focuses only on airspace Classes B, C, and D.
Department of Homeland Security (DHS) Unmanned Aircraft Systems (UAS) Mission: The assessment identifies whether any DHS UAS missions coincide with the proposed L/R site AHA(s).
Operational Considerations: Regular use of airspace to support DHS UAS missions may limit
opportunities for L/R operations that would require the same airspace for their operations.
Instrument Flight Procedures: An Instrument Flight Procedure is a published procedure used by aircraft flying in accordance with the Instrument Flight Rules (IFRs) that are designed to achieve and maintain an acceptable level of safety in operations. The procedure types assessed in the Memo include:
• Conventional and Area Navigation (RNAV) Standard Instrument Departures (SIDs)
• Conventional and RNAV Standard Terminal Arrivals (STARs)
• Specials (industry designed procedures)
• Some or all segments of procedures may need to be closed to accommodate L/R site AHA(s). Closure/cessation of these procedures may result in rerouting of traffic, ground delays, and/or airborne holding.
• Some procedures are used for multiple airports and/or are used more frequently than others. Closure of these procedures may have a greater impact than those used less often.
International Considerations: The assessment identifies whether the proposed L/R site AHA(s) overlaps or is adjacent to international airspace.
Operational Considerations: L/R site AHA(s) that cross into international airspace will require
cooperation and coordination between the FAA's international office and the appropriate Air Navigation Service Provider (ANSP) for that country to permit activation of L/R site AHA(s). For countries where a coordination process is not established, additional planning is required.
NAS Initiatives: Includes any current or pending airport, airspace or procedural proposals (e.g., NextGen) that may affect or be affected by the L/R site AHA(s).
• Some NAS initiatives may result in new and/or changes to existing airspace and/or procedures.
• Benefits associated with new and/or modified airspace and/or procedures may be reduced if affected by the L/R site AHA(s).
• During construction initiatives modified routes and/or technologies may be used to/from an airport.
Other L/R Sites: This factor addresses the implications of locating the proposed L/R site near other existing L/R sites. The Memo addresses the impact of other L/R sites with AHAs that could intersect with the proposed L/R site AHA(s).
Operational Considerations: If the proposed AHA(s) intersects with airspace used by other L/R sites, close coordination of schedules will be required for L/R operations. This may become more of a
constraint if either/both anticipate growth in operations over time.
Parachute Jump Areas: Consists of airspace in which parachute jump operations are routinely conducted. Airspace for parachute jump areas may be protected in a variety of ways. Special Use Airspace (SUAs) may be used if the parachute jump area is in support of the military.
Operational Considerations: If the proposed AHA(s) intersects with airspace used for parachute jump areas, close coordination of schedules will be required.
Published Routes: Published routes are designed for the management of air traffic operations for the provision of air traffic services. The types of published routes assessed in the Memo include:
• Air Refueling Routes
• International Routes
• Military Training Routes
• Victor Airways
This factor does not include SIDs, STARs, or Standard Instrument Approach Procedures (SIAPs). SIDs and STARs are part of the Instrument Flight Procedures Factor. SIAPs are not evaluated in the airspace assessment process.
Operational Considerations: Closure/cessation of published routes may be needed to accommodate
operations at the proposed L/R site. These closures may result in rerouting of traffic, ground delays, and/or airborne holding.
Special Activity Airspace (SAA): Consists of airspace of defined dimensions in the NAS wherein activities must be confined because of their nature, or wherein limitations are imposed upon aircraft operations that are not part of these activities, or both. The Memo addresses SAAs s that may coincide with the proposed L/R site AHA(s). It does not include temporary SAAs, such as Temporary Flight Restrictions (TFRs), Temporary Military Operation Area (TMOA) and Altitude Reservations (ALTRVs) since they are not routinely activated on a regular basis nor in the same location. SAA types assessed in the Memo include:
• Air Traffic Controlled Assigned Area (ATCAA)
• Alert Area (AA)
• Controlled Firing Area (CFA)
• Military Operations Area (MOA)
• National Security Area (NSA)
• Prohibited Area (PA)
• Restricted Area (RA)
• Warning Area (WA)
• If the proposed L/R site AHA(s) coincide with SAA that is used frequently, it will severely constrain when the L/R site can operate.
• Access to airspace that coincides with SAA requires approval/discussion with the using agency of that SAA. Multiple using agencies associated with SAAs require increased coordination.
Traffic Management Initiatives (TMIs): TMIs are techniques used to manage demand with capacity in the NAS. The assessment focuses on existing route flow structures that are maintained and/or used by the Air Traffic Control Systems Command Center (ATCSCC) regularly (e.g., National Severe Weather Playbook and Holiday Airspace Release Plan [HARP]).
Operational Considerations: If the proposed L/R site AHA(s) coincides with areas where TMI route flow structures are regularly used, NAS operations may be further delayed. This impact may have a
ripple effect on other NAS users and result in additional TMIs.
Visual Flight Rules (VFR) Routes/Areas/Flyways: VFR flyways are general flight paths not defined as a specific course, for use by pilots in planning flight into, out of, through, or near Class B airspace to avoid complex terminal airspace. An air traffic control clearance is not required to fly these routes. Uncharted VFR routes/flyways may follow rivers, coastlines, mountain passes, valleys, and similar types of natural landmarks or major highways, railroads, power lines, canals, and other manmade structures.
Operational Considerations: Identified routes/areas/flyways may require closure of some or all
segments to accommodate the proposed L/R site operations. Closure/cessation of these routes/areas/
flyways may result in rerouting of traffic, ground delays, and/or airborne holding.
Annex 2 Airspace Assessment Graphics
[Insert graphics that help depict assessment and associated findings. Graphics included may be from the Terminal Area Route Generation, Evaluation and Traffic Simulation (TARGETS) Spaceport Capability and other data sources/tools leveraged for the assessment. When possible, include at least one graphic for each factor. As appropriate, graphics should be labeled as notional.]
• Proposed L/R site location (potential sources: TARGETS Spaceport Capability, Google Earth, VFRMAP.com)
• Airports (potential source: TARGETS Spaceport Capability)
• Airspace classes within the area of interest (potential source: TARGETS Spaceport Capability)
• Airways (potential source: TARGETS Spaceport Capability)
• SIDs and STARs (potential source: TARGETS Spaceport Capability)
• VFR Routes/Areas/Flyways
• SUAs (potential source: TARGETS Spaceport Capability)
• FAA Facility Airspace Sectors
• TRACON boundaries
• Charted Temporary Flight Restrictions (TFRs)
Annex 3 Detailed NAS Impact Assessment Findings
The purpose of this annex is to archive details associated with each factor. This includes information from the Evaluation of Airspace Factors as well as additional details prescribed in the instructions. These details are the backbone of the Memo and may serve as input into other evaluations, including the L/R Site Letter of Agreement (LOA) and Vehicle Operator License.
This annex is for FAA records only and is not intended to be shared outside the FAA.
Date: [Date assessment was completed]
Prepared by: [ATO point of contact name, title, and/or office within the ATO]
Assessment Parameters: [Data provided by L/R/ Site Applicant from Memo Body]
Airspace Assessment Findings: [Insert factor details here. The TARGETS Spaceport Capability contains reports that may be inserted in this section.]