Killing private space


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The financial foolishness in Congress, by Republicans this time, continues. In making its budget recommendations for NASA, the report [pdf] of the House Appropriations Commerce, Justice, Science, and Related Agencies subcommittee also demands that NASA immediately choose one commercial company for its commercial space program. (Hat tip to Clark Lindsey for spotting this.)

The number of ways this action is counter-productive almost can’t be counted.

To begin, here is the relevant section of the report, in full.

Commercial crew.—The Committee supports the goal of achieving independent and redundant access to the International Space Station (ISS) but remains concerned about many aspects of NASA’s approach to the commercial crew development program. First, the Committee believes that the program’s total estimated development costs of $4,868,000,000 are too high given that the current commitment to the ISS leaves NASA with only a few years to make use of commercial crew services and no sufficient additional market has been clearly demonstrated in the absence of NASA as a base customer.

Second, the current structure of the program has insufficient safeguards in place to protect the government’s interests in intellectual or physical property developed with Federal money in the event that companies are terminated from or opt to leave the program. As such, there is a risk of repeating the government’s experience from last year’s bankruptcy of the solar energy firm Solyndra, in which the failure of a high risk, government subsidized development venture left taxpayers with no tangible benefit in exchange for their substantial investment.

Third, the Administration appears to be pursuing potentially inconsistent goals for the program: (1) the achievement of the fastest, safest, most cost effective means of domestic access to the ISS, and (2) the ‘‘seeding’’ of a new commercial spaceflight industry. Given the overwhelming importance of the first of these goals, any funding, time and effort expended in pursuit of the second is potentially a distraction from other necessary work, and, in an environment of fiscal constraint, a dilution of limited resources.

Finally, the program’s current acquisition strategy lacks any defined plan to transition from the planned Space Act Agreement (SAA)-based Commercial Crew Integrated Capability (CCiCap) round of awards to a Federal Acquisition Regulation (FAR)-based certification and service contract. As a result, the strategy presents a significant risk of costly, lengthy delays as NASA attempts to retroactively assess competitors’ designs on safety and other standards and companies attempt to make changes in fully mature integrated designs to address instances in which NASA cannot verify that a necessary qualification criterion has been met. The Committee believes that many of these concerns would be addressed by an immediate downselect to a single competitor or, at most, the execution of a leader-follower paradigm in which NASA makes one large award to a main commercial partner and a second small award to a back-up partner.

With fewer companies remaining in the program, NASA could reduce its annual budget needs for the program and fund other priorities like planetary science, human exploration or aeronautics research. In addition, an accelerated downselect would allow NASA to focus its remaining funds and technical assistance resources on the most promising contender, potentially enabling that competitor to produce a final capability faster than otherwise possible. It would also allow NASA to return to its previous acquisition strategy of holding an open competition (to include current funding recipients and new entrants) and following a more traditional FAR based management approach, avoiding a complex transition from SAAs late in the development process and allowing the government to better protect its interests in intellectual and physical property developed with taxpayer funds. Finally, this strategy is more consistent with current overarching fiscal guidance included in the fiscal year 2013 House budget resolution. In a climate of decreasing non-defense discretionary spending, the Committee does not believe that the Administration’s proposed budget runout for commercial crew is sustainable.

For all of these reasons, the Committee believes that the advantages offered by an immediate downselect and a return to FAR based contracts outweigh the potential benefits of maintaining the current program structure. As a result, the Committee directs NASA to execute the program as described above and in accordance with a fiscal year 2013 funding level of $500,000,000, which is equal to the level agreed to by Congress and the Administration in the NASA Authorization Act of 2010 (Public Law 111–267). [emphasis mine]

For Congress to micro-manage this program so tightly is guaranteed to increase costs. There is no way these Congressmen can know that now is the appropriate time for NASA to pick one commercial company and let the others sink or swim on their own. In fact, considering how early it is in the development of these space vehicles, it is almost certainly too soon, and by demanding that NASA make its decision now illustrates clearly how little these Congressmen know about the state of commercial space.

Moreover, down-selecting to one company will eliminate the healthy competition NASA now enjoys in this program. Having multiple companies competing for the final contract can only keep costs down, as each company knows that if they spend too much and go over budget, NASA is likely not to chose them in the end. And the proof that this is so can be seen by how little this program has actually cost NASA, especially when we compare it to the budget for the Congressionally-mandated Space Launch System (SLS), which is budgeted six times higher and will not launch its first human into space for almost a decade. Meanwhile, the commercial space program is producing five different spaceships, all of which intent to launch within the next five years, for a total budget that is far less than SLS will spend in only two years.

Maybe the worse part of this committee report is the demand that NASA use its older more traditional “FAR-based management approach” rather than the simpler less expensive SAA contracts that the agency has been using to successfully subsidize the entire commercial space program. Insisting that NASA use the FAR contractual system will only guarantee that costs will rise, as those contracts require a great deal of paperwork and documentation as well as intense micromanagement by NASA. Elon Musk has already said that if NASA uses the FAR contracts he would be unable to work with NASA and would pull out of the deal.

So, why are these so-called conservative Republicans doing this? The clue is the demand to go to FAR contracts. They are likely being advised by people in NASA who don’t like the fact that the commercial space program is not really under their control. By switching back to FAR, the NASA bureaucracy will regain power over the construction of these private spaceships, thus justifying their jobs as well as bringing a lot more of the money into NASA rather than giving it to these companies.

This report must not stand. If the United States is going to have a real aerospace industry, NASA and the government have got to get out of the way.

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36 comments

  • Joe

    These congressmen simply do not believe that there is currently an LEO market beyond transferring four people to and from the ISS twice a year. Therefore, in their opinion, having four competitors chasing that limited market makes no sense. They are concerned with the “up front” development costs to be spent in the next years (up to perhaps 2020).

    As near as I can tell from your post, you are more concerned with eventual operating cost; based on the “build it and they will come” philosophy that if a potentially cheaper transportation system (“potentially cheaper” if it can acquire a much bigger LEO market) is developed the market will “come”. Maybe it will (or maybe it will not), but the people putting up the money are not convinced. Repeatedly attacking them (however much fun you may find it) is not going to convince them.

  • Patrick

    Hilarious. $500M for commercial crew is “a dilution of limited resources” and $xxB for SLS gets a pass.

    Thank goodness we have these guys looking out for us.

  • Fred Willett

    “They are putting up the money” is a myth.
    Under SAAs the private company puts their own money in the pot. For example For commercial cargo SpaceX got a total of $398M but the NASA audited costs for developing Falcon 9 and Dragon are $870M. The difference put in by SpaceX itself.
    I don’t have the figures for Orbital, but they would have been of the same order if not less as their award from NASA for their COTS deal was less.

  • Joe

    “They are putting up the money” is a myth

    They are being asked by the Obama Administration to put up $830 Million dollars this year. They are not proposing to give ‘commercial space’ nothing. They are talking about $500 Million dollars. Whatever you choose to say, that is not a myth.

    For the lower (but still significant) amount of money they are suggesting a modified approach to support what the supposed Government interest in this is, to supply crew transport to the ISS. The government is not in any way compelled to shell out additional taxpayer dollars to encourage anything else. If you want them to do more, convince them to do more. Here is a hint: Repeatedly attacking them (however much fun you may find it) is not going to convince them.

  • wodun

    Well, SpaceX could fund this all on their own. They have several $b in backlogged launches. There is a market for their launch services.

    Also, right now it is rather hard to avoid interacting with the government on the development of launchers.

    IIRC, SpaceX gets money by providing a service to the government. The goal is to transport cargo to the ISS but they don’t get paid at the end but incrementally as they meet certain milestones. The government isn’t just “giving” them money.

    The only real difference between COTS, CCDEV and NASA business as usual is the method of contracting, fixed price vs cost plus.

  • wodun

    So let’s see, we can get 4 different crew vehicles, 2 different launchers, and 2 cargo transports all for a fraction of the cost of SLS.

    Even if all of the proposed business plans fall through, it is still significantly less money than SLS. But if the business plans can be implemented it will be revolutionary for the space industry and our country.

    Seems like an easy decision.

    Too bad the space cadets are not a large enough group to primary these congressmen.

  • Coastal Ron

    Let’s see if you can figure out which transportation program I’m talking about just by describing the current and known demand:

    Capability A – No customers who had defined or funded payloads demanded it be built, and only one customer is forecasted to use it (although they currently can’t afford to use it enough to justify it). Oh, and there are existing commercial alternatives.

    Capability B – There has been demand since the ISS became operational 11 years ago, and there is a defined need through at least 2020, likely through 2028. In addition, there are seven nations that have signed MOU’s stating that they are interested in utilizing this same capability once it becomes operational. To date, all demand is being satisfied by one foreign provider.

    Now try and figure out which one gets what funding, and it’s support in Congress:

    1. $30B in planned funding, the builders add in no money of their own, and the program has solid support in Congress.

    2. $320M has been approved so far, and Congress expects the program could cost up to $4.5B. The builders also add in their own funding for the program in what’s called a public/private relationship. Oh, and Congress is less than enthusiastic about the program.

    Figure it out? Doesn’t make much sense, huh?

    So when people like poster Joe say it’s justified to be suspicious of a “build it and they will come” market approach for Commercial Crew, he is perfectly fine with a “build it and they will come” approach for the SLS program, despite it’s far larger upfront cost, and despite the lack of ANY customers. Really doesn’t make sense, huh?

  • Blackjax

    It is pretty clear by now that many in Congress want to see the program fail without having to take responsibility for canceling it outright. It would be difficult to design a policy to hamstring the program moreso than this one does and to prevent Commercial Crew from ever being viewed as a success. I expect the final nail in the coffin will be to heavily push for NASA to downselect to the least inspired design from the most expensive competitor, who will make only the most tentative efforts to apply their vehicle to any other markets than NASA or make it cost effective. Wait for it, Boeing will get the nod.

  • Bob, have you seen this article? http://www.aviationweek.com/Article.aspx?id=/article-xml/asd_04_26_2012_p04-01-451887.xml

    JSC to do Boeing’s “commercial” crew operations. Understand Chairman Hall’s motivation now?

  • Joe

    “Well, SpaceX could fund this all on their own.”

    So Space X internet supporters keep saying and yet they keep asking the government for money. If they can really do this “all on their own”, let them.

  • Good catch Trent. Nor am I surprised. However, though Hall might be angling for Boeing to get the job, there is no obvious way at the moment for him to give it them.

    He might be anticipating a big Republican victory in the fall. With Romney as President, Hall could then lobby the new administration to give the work to Boeing.

    The danger of this politically will be that SpaceX will still stand out as the leading private company, especially if the test launch next week succeeds.

  • Joe

    I know you guys cannot conceive of anyone disagreeing with you for reasons other than:
    – Stupidity
    – Insanity
    – Corruption

    But, you are aware that JSC is not in Hall’s district, right?

  • You are correct, Joe. I only found this out later today in talking to a radio guy in Houston.

    Nonetheless, your desire to make believe the arguments by me and others can only be boiled down to “stupidity, insanity, and corruption” is evidence you really don’t want to read what people are writing. Consider the comments of wodun and Coastal Ron, both of whom spent a great deal of time outlining the cost differences between commercial space and SLS (as I have earlier). This is not name-calling, but a citation of actual facts that make mincemeat out of all the arguments against commercial space presented by Hall and others in Congress.

    Commercial space is accomplishing what SLS promises to do, in less than half the time for about 1/6 the cost. It is that simple. More important, based on past experience (the many costly failed attempts by NASA to build a shuttle replacement), we have every reason to believe that SLS will never accomplish anything it promises anyway. It is time to try something different.

  • Joe

    Robert,

    Thanks for the honest response.

    If I may, I am going to stay away from the SLS vs. ‘Commercial Space’ debate here (sorry, but I have been through it so many times I am not going to risk getting meta carpal tunnel syndrome typing it all out again).

    My point is a different one. Hypothetically granting all your assertions, you are losing the ‘Congress Wars’. I think we can at least agree that there appears to be a consensus building House/Senate, Authorization/Appropriation, Republican/Democrat, Liberal/Conservative that they are not going to fund (at $800 Million + per year) a program to pursue 4 different contractors with 4 different designs all chasing a market that they perceive as consisting of two launches per year to the ISS.

    I know you believe that the potential market is much greater than that, but they do not. The Administration (as far as I can tell) has not even tried to convince them of it and no one else has done so effectively.

    Therefore they are looking for a more near term down-select to achieve for less ‘up front’ money what they think is the only goal of the program, the delivery of limited numbers of crew to the ISS. That may be wrong, but it is not corrupt or stupid.

    If you want more government money (which will have to be approved by congress) then you need to convince them (not me – I am just a lowly Engineer down in the trenches).

    At the risk of repeating myself: Repeatedly attacking them is not going to accomplish that goal.

  • Kelly Starks

    True. Lets face it. With the tiny “market” CCDev represents, theirs no way “competition” could avoid driving up costs, hurt safety, etc. There’s just no benifit to the program – worse the expenses threaten a lot of other programs, and future program. Further, theres really only one bidder (Boeing) they could credibly risk giving the contract to. So the only real justification for keeping more”bidders” is pork to new starts, and thats not what we want done with our tax money.

  • Kelly Starks

    >..$870M. The difference put in by SpaceX itself…

    SpaceX has no money – investors put the other half of the money — course the idea of COTS was not that NASA was funding a dev program. It was supposed to be COTS folks get paid for services, not NASA will fund your dev programs, adn maybe contract from you later.

  • Kelly Starks

    >..Well, SpaceX could fund this all on their own. They have several $b in backlogged launches.

    Half of which are NASA contracts Congress is not happy about. Most of the rest are commercials contracting SpaceX as a back up suplier. Both could suddenly disapear, so you can’t exactly get a loan on them.

  • Kelly Starks

    Actualy they said it was more like $5 billion in total program costs.

  • Kelly Starks

    ets look at that logic. 4 dev programs – none strong enough to survive, none with enough capacity to offer anything long term. Why risk the SLS contractors to foster far less capable, and unlikely, new starts?

  • Kelly Starks

    >..2. $320M has been approved so far

    Actually several times that so far. SpaceX alone got more then that alone.

  • Kelly Starks

    Reality check. Who else but Boeing would any unbiased person select?
    In competition with spaceX they have generally been competitive or cheaper
    their quality and safety is vastly higher
    they have a sterling reputation over most of a century in aerospace, and with rockets for about half that,
    They are vastly more capable of commercializing anything
    they have two proposal (CST-100 and the -37C the later derived from a tested operational craft).

    In any realistic fair competition they win.

  • Kelly Starks

    >..SpaceX will still stand out as the leading private company…

    In a competician with Boeing in the crowd? That’s like saying a custom Chopper maker stands out as the leed in a motorcycle convention next to Harley and Kawasaki?

  • Kelly Starks

    > Robert Zimmerman
    > Nonetheless, your desire to make believe the arguments by me and others can only be boiled
    > down to “stupidity, insanity, and corruption” is evidence you really don’t want to read what people are writing..

    And you just proved you didn’t read what he wrote. He said YOUR arguments are no one can disagre with you “.. for reasons other than:
    – Stupidity
    – Insanity
    – Corruption”
    Not that he said you were “Stupid, Insane, or Corrupt”.

    You want this to be true so bad your belittleing disagreement from folks (even congress folks) with completly reasonable points.

  • Kelly Starks

    Man I’m going to be glad when SpaceX goes under and folks will stop screaming they they are the new messiah.

  • Pzatchok

    I bet we could get a few people to the moon if we just auctioned off selected lots with mineral right of course to the highest bidders.

    You have 10 years to develop a fully self contained and human occupied habitation on it or the monies put up in the auction are forfeit along with any land claims.

    The cash raised could be used for a new launch vehicle and system or a linear magnetic launch system.

    Screw the idea that the Moon belongs to the whole of the earth. He who gets there first makes the rules. Whats the rest of the world going to do? Yell or cry?

  • Joe

    Thanks Kelly, good catch.

    It is a little difficult to see how he completely turned what I said 180 degrees, but I did not notice the misrepresentation of my statement by him either. So mistakes happen, I will assume this was an honest one.

  • Kelly Starks

    Good luck getting the ore to market at a competitive price. Though the ideas certainly worth exploring. Giving folks first crack at the wealth of a new territory is historiclly a good way to open that terratory.
    ;)

  • Pzatchok

    For the first 25 years or so the only viable market will be their local market. The moon.

    The biggest problem in this whole idea is finding a nation that’s willing and able to buck the rest of the worlds opinion. A politician that’s willing to push the idea and a citizenry that’s willing to back the idea.

    We also have to get NASA out of the equation. They will just work to turn it into a lifelong job and try like heck to get a few friends in on the gig. Much like it is now. Heck after 15 years developing the shuttle for the military as a spy satellite recovery tool they totally missed the boat and were out developed by private industry who made the first images by CCD in 1971. By the 80’s digital camera systems were being launched for spy satellites.
    They spent the next 20 years trying to justify the Shuttle to the US people. A ship that in reality never needed to be built. At least in the way it was originally designed.
    They could have turned it unto a heavy lift cargo rocket system with an interchangeable reusable personnel carrier like the shuttle but smaller.

    Private industry is the only real way to make things happen. They would have dropped the shuttle idea in a week and designed something better instead of throwing cash at it for the next 20 years only to drop it at the one moment we finally really needed it. Only to be replaced by promises and hope.

    Sorry about the NASA rant.

  • Kelly Starks

    ;)

    I think as advocates run out of things happening they can pin their hopes on, they get more desperate to believe in anything left. Desperate people lose perspective.

    I really do hope things balance out after SpaceX folds.

  • Kelly Starks

    > For the first 25 years or so the only viable market will be their local market. The moon.

    There is no market on the moon – no ones there. ;)

    Saying your going to send crews to the moon, to sell to folks you send to the moon is nonsensical — its just pork, like paying folks to dig holes then fill them.

    Also it completely contradicts your original idea of getting folks to develop the moon for the minerals.

    > The biggest problem in this whole idea is finding a nation that’s willing and able to buck the rest
    > of the worlds opinion. ==

    No the biggest problem is no one can figure out a way to make any money at this. If you could do that, the rest falls into place.

    >== 15 years developing the shuttle for the military as a spy satellite recovery tool ==

    Oh hell no. The mil hardly wanted shuttle at all and certainly that wasn’t on anyones to do list.

    > They spent the next 20 years trying to justify the Shuttle to the US people. A ship that in
    > reality never needed to be built. ==

    It was the first real attempt to make a craft that could routinely develop and build things in space. It did it so well its been the bulk of all human activity in space. Allthat with a politically compramised design.

    ==
    > They could have turned it unto a heavy lift cargo rocket system with an interchangeable
    > reusable personnel carrier like the shuttle but smaller.

    That would be a very inferior design, especially if you want to develop space economically.

    > Private industry is the only real way to make things happen. They would have dropped
    > the shuttle idea in a week ==

    Actually they have been trying to get the rights to operate it commercially, and market it, for 30 years. Efforts are still going on. If were ever going to do anything significant in space, we’ll need something like the shuttle – hopefully more refined.

  • Pzatchok

    The shuttle was originally designed to specifically carry Hexagon http://www.foxnews.com/scitech/2011/09/19/declassified-us-spy-satellites-reveal-rare-look-at-secret-cold-war-space/ .All other cargoes after that were designed to fit into the shuttle.

    And the shuttle made a poor launch vehicle at 2030 tons vs. a launch cargo capacity of at most 53,000lbs to LEO and only 14400 for landing.

    They could have dropped the shuttle off the booster, added two more solid rockets and put the shuttle liquid engines under the fuel tank. Thus giving it well over 1000 tons of possible cargo load on top of the liquid tanks. Of course that’s a non reusable vehicle but its cheap and would work great for lifting cargo.

    And other than Hexagon, exactly what cargo have we brought down from space? People and cargo that went up with the shuttle on that trip don’t count.
    Hexagon ended when digital images came into full use. Thus leaving the shuttle without a job just a few years after its first launch.

    The robot arm was added as an afterthought to make it a better construction platform. In fact after 20 years NASA never thought to put a camera on it to inspect the bottom of the shuttle before reentry. They never did come up with a way to capture satellites that were not originally designed to be captured. Which in fact are few.

    And as for mining the moon for ore. Why would you bring it back to Earth? We don’t need it but a moon colony would need it wouldn’t it?

    The first American colonies were established to be profit making enterprises but they didn’t make a profit for 20 years. Until then the colonists needed all their labor and resources to build the colony. Pretty much the same that would happen on the moon.
    The point of a colony on the moon is the simple fact that the first there has the best chance of claiming it all and using it. Just like the American colonies the rest of Europe couldn’t send enough people to start colonies to claim more than the English did faster. They all eventually had to give or sell off their claims.

    I wonder if China would like those resources in 30 to 50 years? Or America?

  • Kelly Starks

    > The shuttle was originally designed to specifically carry Hexagon ==

    No, congress said shutle had to carry all NASA and DODs cargo, and Hex was the biggest. It was not developed initially for that or any DOD mission.

    >== And the shuttle made a poor launch vehicle at 2030 tons vs. a launch cargo capacity of at
    > most 53,000lbs to LEO and only 14400 for landing.

    No one gives a damn what its take off weight is – just cost per cargo, on orbit capacity, safety reliability, etc.

    >…Thus giving it well over 1000 tons of possible cargo load on top of the liquid tanks. Of
    > course that’s a non reusable vehicle but its cheap and would work great for lifting cargo.

    The pads couldn’t have delt with that, there was no market for cargo of that scale, and it had none of the other abilities of the shuttle. So wahts the point?

    >..exactly what cargo have we brought down from space? ..

    Most of the cargo and system brought up were returned eiather for reuse or servicing. LDEF, synthetic aperture radar, The space lab, Spar, etc etc.

    And remember the shuttle orbiter was cheaper to develop and fly then the Apollo or Orion capsules. Enabled you to build and service things from sats to the station, allowed up to 30% lighter satellites then on a traditional booster.

    >.. The robot arm was added as an afterthought ==

    No it was part of the initial concept as was on orbit construction. Initially they were going to include 2 arms.

    >..They never did come up with a way to capture satellites that were not originally designed to be captured.

    Actually they did, and did recover and service a sat that way.

    > And as for mining the moon for ore. Why would you bring it back to Earth? ==

    Thats where the customers are.

    >==We don’t need it but a moon colony would need it wouldn’t it?

    It would be cheaper to ship prefab parts to build the colony out of (you don’t mine in Antarctica to build the bases there), and a lot safer. You could use lunar soil for concret walls adn stuff, but thats not exactly a mine.

    And of course theres no colony on, or planed for, the moon.

    > The first American colonies were established to be profit making enterprises but they
    > didn’t make a profit for 20 years. ==

    You haven’t outlined how they would EVER be profitable – and generally folks want profit quicker since markets change a lot over 20 years.

    >== The point of a colony on the moon is the simple fact that the first there has the best chance
    > of claiming it all and using it. ==

    We all signed a treaty that we’ld NEVER claim it.

    > I wonder if China would like those resources in 30 to 50 years? Or America?

    Again, if you can’t deliver it to market here cheaper then domestic sources – no, not ever.

  • Pzatchok

    The Saturn V weighed 6 MILLION lbs. Its launch pads were still usable. The total lift off weight of the shuttle system was just 4.5 million lbs.

    We can drop the safety and reliability argument. Ice chunks are now a killer.

    They serviced ONE satellite not designed to be serviced by the shuttle. They couldn’t even get up in time( two years to prep) to save or service our best telescope. Hubble.

    Launch satellites 30% lighter? Lighter than what? A Saturn launch system, which doesn’t need to be used for everything. Sputnic was 15 lbs. Satellites should have or could have been the size of its cargo hold. But we NEVER launched one that big out of the shuttle. They tried to get fancy and launch two at a time but guess what, that could have been done with ANY launch system.
    It sucked butt as a satellite launch vehicle.

  • Kelly Starks

    > We can drop the safety and reliability argument. Ice chunks are now a killer.

    Even with that (utter stupidity) the shuttles still have the best safty record of any maned craft in history.

    > They serviced ONE satellite not designed to be serviced by the shuttle. They couldn’t
    > even get up in time( two years to prep) to save or service our best telescope. Hubble.

    Ah they serviced and restored the Hubble – hence why its been taking picks for a quarter century.

    > Launch satellites 30% lighter? Lighter than what?

    Then the same sat would need to be on a standard ELV.

    >== Satellites should have or could have been the size of its cargo hold. But we NEVER
    > launched one that big out of the shuttle. ==

    Actually we did. Though most sats don’t need to be that big to do their job.

  • chuck

    the marius hills pit is ”open” LAND IN THE PIT…

  • gabe

    >Even with that (utter stupidity) the shuttles still have the best safty record of any maned craft in history.<

    Shuttle= 2 accidents (both fatal) 14 deaths

    Apollo= 2 accidents (1 fatal) 3 deaths

    Gemini=No accidents

    Mercury=No accidents

    'nuff said.

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