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"T Minus Zero (T-0)" or Intentional First Stage Ignition
The FAA also considered defining "launch" as the word is ordinarily understood. This would have limited the scope of a launch license to activities commencing at intentional first stage ignition. Were a launch license to cover only those activities, the launch industry would no longer have been eligible for so-called indemnification for damages arising out of any preparatory activities. The regulatory burden, however, would be correspondingly less. Such a licensee would not, for instance, be required to obtain a license as early in the process as it must for gate to gate, nor would it be required to provide the FAA as much information. Likewise, this approach would have resulted in similar treatment of licensees regardless of the type of vehicle employed or the timing or location of hazardous activities. The FAA carefully weighed this approach, especially in light of those comments advocating a more narrow definition of launch. With the changes brought about by the 1998 revision to the Act, which expands the scope of launch, defining launch as commencing with intentional first stage ignition is no longer an option.
"Gate to gate"
The FAA's practice of licensing ground operations associated with the conduct of a launch, commonly referred to as "gate to gate," was to license all commercial, launch related activities by a launch operator operating within the gates of a federal range. Through this rulemaking the FAA abandons this approach. Under this view, a launch operator's operations were licensed, even if ignition and flight were not imminent and even if the launch vehicle itself was not present at the range. The 1998 amendment to the definition of launch confirms the FAA’s intent to abandon this approach. A launch vehicle must be present for preparatory activities to constitute part of launch.
The "gate to gate" approach constituted an attempt to treat different launch vehicles similarly. Whether a launch vehicle undergoes hazardous integration significantly in advance of flight, as the Delta and Pegasus do, or closer in time as an Atlas does, a license covered the same pre-launch activities: all launch related activities performed by a launch operator within the gates of a federal range. Additionally, "gate to gate" licensing ensured that the FAA required launch operators to demonstrate financial responsibility through the purchase of insurance coverage or other appropriate measures for possible damage arising out of commercial activities to government property. "Gate to gate" licensing received support because of the belief that a launch operator would be indemnified for damage to third parties caused by pre-flight and post-flight ground operations.
The FAA does not define "launch" to encompass all pre-flight activities by a launch operator at a launch site because not all activities are part of the launch of a launch vehicle. A launch operator may be present on the range, and engaged in preparatory activities, but not be working on a launch vehicle or its component parts in preparation for flight. A licensed launch operator may be present at a federal range between launches. The FAA is aware of launch operators who perform construction activities within the gates of a federal range months or years prior to any anticipated flight of a launch vehicle. At that point, the launch operator may or may not be engaged in the type of hazardous activities warranting FAA oversight or indemnification because construction activity, however hazardous, is not part of the process of preparing the vehicle itself for flight.
In support of "gate to gate" licensing it has been suggested that pre-launch licensing authority arises out of the Act's directive to license "operation of a launch site." See 49 U.S.C. § 70104(a). In the case of a launch taking place from a federal launch range, the launch operator is not, in fact, operating a launch site. The site is operated by the federal range. Moreover, it is the FAA’s opinion that a person requires a license to operate a launch site only if offering the site to customers for their launch. Otherwise, activities related to preparation for flight are part of a launch license rather than a license to operate a launch site.
　
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本文鏈接地址：Commercial Space Transportation Licensing Regulations(13)