National Aeronautics and 

Space Administration

Commercial Orbital 

Transportation Services

A New Era in Spaceflight

NASA/SP-2014-617

Commercial Orbital 

Transportation Services

A New Era in Spaceflight
ii

On the cover:

Background photo: 

The terminator—the line separating the sunlit 

side of Earth from the side in darkness—marks 

the changeover between day and night on the 

ground. By establishing government-industry 

partnerships, the Commercial Orbital Transportation 

Services (COTS) program marked a change from 

the traditional way NASA had worked. 

Inset photos, right: 

The COTS program supported two U.S. companies 

in their efforts to design and build transportation 

systems to carry cargo to low-Earth orbit. 

(Top photo—Credit: SpaceX) SpaceX launched 

its Falcon 9 rocket on May 22, 2012, from Cape 

Canaveral, Florida. 

(Second photo) Three days later, the company 

successfully completed the mission that sent 

its Dragon spacecraft to the Station. 

(Third photo—Credit: NASA/Bill Ingalls) Orbital 

Sciences Corp. sent its Antares rocket on its test 

flight on April 21, 2013, from a new launchpad on 

Virginia’s eastern shore. Later that year, the second 

Antares lifted off with Orbital’s cargo capsule, 

(Fourth photo) the Cygnus, that berthed with 

the ISS on September 29, 2013.

Both companies successfully proved the capability 

to deliver cargo to the International Space Station 

by U.S. commercial companies and began a new 

era of spaceflight.

ISS photo, center left: 

Benefiting from the success of the partnerships 

is the International Space Station, pictured 

as seen by the last Space Shuttle crew that 

visited the orbiting laboratory (July 19, 2011). 

More photos of the ISS are featured on the first 

pages of each chapter.
iii

Preface

This document provides a history of the NASA Commercial Orbital 

Transportation Services (COTS) program executed by the Commercial 

Crew & Cargo Program Office from 2006 to 2013 at the Johnson 

Space Center, Houston, Texas. The story was superbly written by 

Rebecca Hackler in coordination with Rebecca Wright of the JSC 

History Office. They spent countless hours interviewing dozens of 

key leaders and participants who shaped the direction and outcome 

of the program. Their work is greatly appreciated as well as all those 

who dedicated many years of service to the success of COTS. 

It was certainly an honor and privilege for me to have the opportunity 

to lead this effort and work with such extraordinary and inspirational 

people. I am hopeful history will show our work over these few 

short years had long-lasting, transformational effects on the future 

of commercial spaceflight in America.

Alan Lindenmoyer,

Program Manager

February 2014 

For more information on NASA Commercial Crew & Cargo 

Program, visit www.nasa.gov/cots
iv

Contents

Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Chapter 1: Laying the Foundation . . . . . . 1

NASA and Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Key Concepts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Chapter 2: Concept to Reality . . . . . . . . . 15

Leadership and Coalescence . . . . . . . . . . . . . . . . . . . . . . . . . 16

Legal Team and Space Act Agreements . . . . . . . . . . . . . . . . . 19

Thinking Like an Investor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

International Space Station . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Foundation Ready . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Chapter 3: Competition . . . . . . . . . . . . . . . . . 25

Round 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Round 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Unfunded Space Act Agreements . . . . . . . . . . . . . . . . . . . . . 33

Chapter 4: Program . . . . . . . . . . . . . . . . . . . . . . 35

Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Chapter 5: Commercial Partners . . . . . 49

Space Exploration Technologies Corp. . . . . . . . . . . . . . . . . . . 50

Rocketplane Kistler . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Orbital Sciences Corp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Chapter 6: Collaboration . . . . . . . . . . . . . . . . 77

International Space Station . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

Federal Aviation Administration . . . . . . . . . . . . . . . . . . . . . . . . 85

Chapter 7: First Steps Toward 

Commercial Crew . . . . . . . . . . . . . . . . . . . . . . . . 87

Commercial Crew Development . . . . . . . . . . . . . . . . . . . . . . . 88

Commercial Crew Program . . . . . . . . . . . . . . . . . . . . . . . . . . 90

Chapter 8: Legacy . . . . . . . . . . . . . . . . . . . . . . . . 91

From Contingency to Dependency . . . . . . . . . . . . . . . . . . . . . 92

The COTS Model: A New Way . . . . . . . . . . . . . . . . . . . . . . . . 95

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99

Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102

COTS Model for NASA Public-Private Partnerships . . . . . . . 103

Chronology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110

COTS Oral History Interviews . . . . . . . . . . . . . . . . . . . . . . . . 114

Bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118
v

Introduction

In May 2012, the SpaceX Dragon made headlines as it 

became the first commercial spacecraft to deliver cargo to 

the International Space Station (ISS). In September 2013, 

NASA saw a second commercial partner, Orbital Sciences 

Corp., follow with its own resupply mission to the ISS.

These successful missions represented the fruition of 

six years of intensive work executed under partnership 

agreements between NASA and the commercial space 

community—partnerships that both resulted in the 

availability of cost-effective cargo transportation services 

for the Agency, and the advancement of the U.S. 

commercial space industry. 

NASA’s support was critical to the companies’ success. 

Said Gwynne E. Shotwell, President of the Space 

Exploration Technologies Corp. (SpaceX), “We would not 

be the company that we are today without the support 

of NASA,” continuing, “We’d probably be limping along, 

trying to change the world, but limping instead of running.”1

Orbital President and CEO David W. Thompson echoed 

the sentiment as he described how NASA was “very helpful 

in helping us work through various kinds of problems that 

came up,” concluding that “it’s been a great relationship.”2

These partnerships had their origin in 2005, when NASA 

Administrator Michael D. Griffin was appointed and, with 

the support of the presidential administration and Congress, 

allocated a fixed $500 million contribution from NASA’s 

budget for the instigation of commercial transportation 

capabilities to low-Earth orbit. The new Commercial Crew 

& Cargo Program Office (C3PO) at the Johnson Space 

Center (JSC) in Houston, Texas was charged with the task 

of “stimulating commercial enterprise in space by asking 

American entrepreneurs to provide innovative, cost-effective 

commercial cargo and crew transportation services to the 

[international] space station.”3

From 2006 to 2013, under the Commercial Orbital 

Transportation Services (COTS) program managed by 

C3PO, NASA acted as an investor and advisor with 

three different and distinct companies in the space 

transportation industry to promote the development of 

U.S. space transportation capabilities on the frontier 

of human exploration. 

If successful, this program promised to support President 

George W. Bush’s 2004 Vision for Space Exploration by 

filling a gap in resupply services to ISS. New commercial 

vehicles could take over the task of ferrying cargo to and 

from low-Earth orbit after the planned 2010 retirement of 

the Space Shuttle, allowing NASA’s new spacecraft, the 

Orion capsule and Ares rocket, to explore space beyond 

the Moon and eventually on to Mars.

In addition to allowing NASA to focus on extending 

humanity’s presence in space, COTS would stimulate 

efforts within the private sector to develop and operate safe, 

reliable, and cost-effective commercial space transportation 

systems. Besides supporting ISS, these commercial 

capabilities could ultimately benefit the U.S. economy 

by making domestic launch vehicles more competitive in 

global markets. In turn, lower launch costs could bolster 

opportunities for other space markets to grow.

One of the first of NASA’s commercial partners selected 

in August 2006, SpaceX, represented the unequivocal 

success of the COTS model. Shortly after its successful 

ISS demonstration mission in May 2012, the company 

quickly provided two critical resupply service missions to 

the orbiting laboratory under NASA’s follow-on Commercial 

Resupply Services (CRS) contract. 

The other partner chosen in the initial selection was 

less fortunate. NASA terminated its relationship with 

Rocketplane Kistler (RpK) in October 2007 after the 

company failed to raise sufficient private funding to 

continue vehicle development. Orbital Sciences Corp., 

selected as a COTS partner to replace RpK in February 

2008, completed its ISS demonstration mission in the 

fall of 2013, and joined SpaceX as the second company 

NASA would rely on for cargo delivery services to ISS. 

This report charts the origins and execution of the NASA 

COTS program, including the elements and people that 

ultimately made the COTS model a success.
vi
CHAPTER 1 – LAYING THE FOUNDATION 1 chapter 1

Laying the Foundation

NASA and Industry

Key Concepts
2 CHAPTER 1 – LAYING THE FOUNDATION

Since its founding in 1958, NASA has 

focused on government-owned and 

-operated space missions. Throughout 

the Mercury, Gemini, Apollo, and 

Space Shuttle programs, the space 

agency hired contractors to develop 

launch vehicles and spacecraft. 

Contractor operations were subject 

to government insight, defined as 

“NASA’s ability to penetrate” into 

these companies’ “vehicle design, 

development, test and operations,” 

as well as strict oversight, or “the 

watchful and responsible care and 

management” of contractor activity.

4

These early relationships set the 

pattern for NASA-industry relations for 

decades to come. 

Commercialization in 

the Space Shuttle Era

When NASA began development of 

the Space Shuttle, the new vehicle 

was envisioned as a reliable, low-cost 

method of launching government 

and commercial payloads into orbit. 

The first Shuttle mission, STS-1, 

occurred on April 12, 1981, shortly 

after President Ronald Reagan began 

The NASA Commercial Crew & Cargo Program Office (C3PO), formally 

established in November 2005, represented the culmination of years, even 

decades, of initiatives to encourage the growth of the private spaceflight sector 

in the U.S. Although the Commercial Orbital Transportation Services (COTS) 

government-private sector partnerships established by C3PO represented a 

new way of doing business in the realm of human spaceflight, such symbiotic 

relationships have occurred throughout U.S. history. 

The year 1869 saw the completion of the first transcontinental railroad that 

allowed for continuous travel between America’s east and west coasts—a 

project that would not have been possible without the support of government 

bonds and land grants. In the first half of the 20th century, the 1925 Contract Air 

Mail Act (more commonly referred to as the Kelly Act) incentivized commercial 

aviation by allowing the U.S. Post Office to contract with private companies for 

mail delivery. This eventually led to the use of commercial aircraft for affordable 

passenger travel, as air travel transitioned from a dangerous, daredevil pastime 

to a routine operation. 

These examples demonstrated the positive benefits of public-private 

partnerships for advancing U.S. goals and strengthening the American economy 

through investment in innovative technologies. More than 50 years after Alan 

B. Shepard’s historic spaceflight, visionaries in the aerospace community 

endeavored to extend the same type of symbiosis to the realm of commercial 

space transportation. 

Commercial companies have been involved in NASA programs as contractors 

since the Agency’s founding in 1958, but it was not until the 1980s that 

commercial advocates began to more actively seek turnover of routine space 

operations to the private sector. Multiple NASA programs laid the foundation 

for the Commercial Orbital Transportation Services (COTS) program, beginning 

with early efforts to privatize Space Shuttle and Space Station operations. 

Although not all these programs reached completion, the principles established 

for successful relationships with the private sector would become pillars of the 

Agency’s mission to develop commercially-available ISS transportation services.

NASA and Industry
CHAPTER 1 – LAYING THE FOUNDATION 3

his administration. Hopes for the new 

system were high with “a sense that 

a new era was dawning in space, one 

in which commercialization would play 

an important part.”5

This optimism was encouraged by the 

pro-commercialization space policy 

Reagan endorsed. During the signing 

ceremony of the 1984 Commercial 

Space Launch Act the president 

stated, “One of the important 

objectives of my administration has 

been, and will continue to be, the 

encouragement of the private sector 

in commercial space endeavors.”6

Several startup companies emerged 

in the 1980s to take advantage of 

the opportunities they foresaw in this 

new era of commercial spaceflight, 

including Orbital Sciences Corp., 

cofounded by David W. Thompson, 

and Space Services, Inc., founded by 

David Hannah and Gary C. Hudson 

with the expertise of former NASA 

personnel such as Mercury astronaut 

Donald K. “Deke” Slayton.7 In the first 

few years of Shuttle operations, two 

companies also proposed to build a 

fifth, privately-owned Shuttle orbiter to 

complement the fleet of NASA’s four 

existing vehicles.8

In September 1984, NASA 

Administrator James M. “Jim” Beggs 

established an Office of Commercial 

Programs that “encouraged 

the private sector to become 

more involved in using space for 

commercial purposes and increased 

NASA’s efforts to find privatesector uses for NASA-developed 

technology.”9 The same year, 

Congress passed the Commercial 

Space Launch Act that aimed to 

encourage the growth of the private 

expendable launch vehicle (ELV) 

industry. The Office of Commercial 

Space Transportation (AST) was 

established in the Department of 

Transportation to provide the dual role 

of regulating commercial launches 

and encouraging the growth of the 

commercial spaceflight industry.10

For many observers in the 1980s, 

commercial space transportation 

seemed to be off to a promising 

start. However in January 1986, a 

devastating accident resulted in the 

loss of the Space Shuttle Challenger, 

its crew, and payloads during launch. 

As a result, many questioned the 

role of NASA as the primary satellite 

delivery route to space. Despite 

the Agency’s attempts to keep 

its customers, President Reagan 

issued a statement on August 15, 

1986, banning commercial payloads 

on Shuttle. Aerospace companies 

resumed production of expendable 

President Ronald Reagan visited the Mission Control Center at the Johnson Space Center and spoke with the crew on board 

Space Shuttle Columbia during the STS-2 mission. During his administration, Reagan supported plans for commercialization of 

the Space Shuttle, encouraging the private sector to create a viable space transportation industry.
4 CHAPTER 1 – LAYING THE FOUNDATION

launch vehicles for private 

customers, aiming to provide 

cheap and reliable means of getting 

commercial satellites to orbit.11

Early Space Station 

Commercialization 

Efforts

The Space Station Program, formally 

announced by President Reagan 

on January 25, 1984, offered other 

potential options for the commercial 

use of space. Some early concepts 

for the orbiting habitat included 

privately-owned modules attached to 

the core station structure. 

A number of proposals from 

commercial companies offered to 

house experiments on independent 

platforms. These included Space 

Industries, Inc., headed by Maxime 

A. Faget, former JSC Director of 

Engineering and lead designer for 

Space Shuttle and the Mercury 

capsule. Space Industries proposed 

to build an Industrial Space Facility 

(ISF) that would remain in low-Earth 

orbit and be serviced by visiting 

Shuttle astronauts as needed. 

However, the ISF was defeated 

after a series of controversial 

Congressional hearings in 1988, 

as NASA saw the private platform 

as a direct threat to its own space 

station program.12

Of the multiple commercial space 

initiatives of the 1980s, only the 

SPACEHAB pressurized module, 

in which astronauts could conduct 

experiments in the Shuttle’s payload 

bay, would fly in space.13

SPACEHAB’s first module in space provided a laboratory that more than doubled the pressurized workspace for crew experiments. 

The inaugural flight of this commercially-developed unit was in June 1993 on the Space Shuttle Endeavour as part of the STS-57 mission.
CHAPTER 1 – LAYING THE FOUNDATION 5

“Faster, Better, 

Cheaper”

Under Administrator Daniel S. Goldin, 

who held the position from 1992 to 

2001, NASA embarked on a mission 

to build “faster, better, cheaper” 

spacecraft. Managers recognized 

that in order to accomplish this feat 

they would need to alter customary 

practices. They based projects 

such as the Mars Pathfinder on the 

Lockheed “skunk works” unit that 

discovered a successful formula 

for quicker and more efficient 

aircraft development. Designers 

reduced the number of people 

involved and simplified elaborate 

management oversight structures. 

Limiting the organization’s size 

helped promote “group cohesion,” 

and team members were given 

more independent decision-making 

authority without the burden of 

outside interference.14

Reusable Launch Vehicles

After the breakup of the Soviet Union 

in 1991, several space transportation 

companies emerged in response to 

the new economy created by the 

end of the Cold War. Names in the 

U.S. included Pioneer Rocketplane, 

Kistler Aerospace, and Rotary Rocket, 

Inc.15 These companies and their 

founders would play a significant 

role in future NASA programs that 

aimed to increase cooperation with 

the commercial sector.

Although these new companies 

aimed to break into the impending 

satellite communications industry, 

their projects for low-cost launch 

systems also had relevant NASA 

applications. After a decade of 

Shuttle operations, which turned 

out to be more expensive and 

less reliable than originally 

projected, “the problem of low-cost, 

routine transportation into space 

was judged on all sides to be of 

overriding importance.”16

The NASA program to develop 

second-generation reusable launch 

vehicles (RLVs, the first-generation 

RLV being the Space Shuttle) 

in cooperation with commercial 

companies in the 1990s included 

the X-33 and X-34 spaceplanes. 

For the X-33 project, NASA allowed 

companies to develop their own 

concepts, without the government 

“dictating the design.”17

Orbital Sciences Corp., a future COTS 

partner, was an active participant in 

the X-34 project. Foreshadowing the 

COTS message of limited oversight, 

John E. Mansfield, NASA Associate 

Administrator for Space Access 

and Technology, claimed, “We are 

partners with industry and not their 

managers.”18 Although these vehicles 

were cancelled mid-development, 

the X-33 and X-34 projects showed 

an increasing willingness by NASA to 

institute a new form of collaboration 

with industry, especially as budgets 

grew tighter.

Around the same time NASA also 

worked to transfer Shuttle operations 

to the private sector. An independent 

Space Shuttle management review 

in February 1995, headed by former 

Flight Director and JSC Director 

In 1996, Lockheed Martin began work on the X-33, a government-industry partnership 

to lower the costs of sending payloads to space. The rocket plane (illustrated in this 

artist concept) was to demonstrate the capability of private industry to build and operate 

reusable launch vehicles for space transportation. The program was cancelled in 2001.
6 CHAPTER 1 – LAYING THE FOUNDATION

Christopher C. Kraft, recommended 

that responsibility for Shuttle 

operations be delegated to a 

consolidated prime contractor. 

In addition to recommending that 

NASA remove the restriction on 

commercial payloads, the report 

also stated, “Increasing industry 

involvement in the operation of the 

space shuttle can be viewed as 

one of the first steps toward the 

commercialization of spaceflight.”19

By the late 1990s, NASA began a 

more concerted effort to consider 

options for future space transportation 

architectures that would allow 

“assured access to space”—a matter 

of growing concern for the space 

agency—including combinations of 

Shuttle, ELVs, and privately-owned 

RLVs.20 In February 1998, NASA 

Chief Engineer Daniel R. Mulville 

spoke about engaging with industry 

to develop commercially viable RLVs. 

At the time, RLVs in development 

included, for example, the fullyreusable Roton envisioned by 

Gary C. Hudson’s Rotary Rocket 

Company, Inc.21 Mulville believed 

these next generation systems would 

develop cargo capability first, before 

moving to human-rated systems for 

astronaut transportation. 

However, Mulville stressed that 

companies would determine the best 

route for their particular business 

needs: “This is not something we do 

by ourselves. This is a partnership 

opportunity. It’s a way for us to work 

with industry.” Many of the themes 

Mulville explored in his remarks 

would become hallmarks of 

NASA’s cooperation with industry 

in future years. These included 

NASA becoming a customer of 

low-Earth orbit transportation 

services (as opposed to owner 

of the vehicle), thereby allowing the 

space agency to focus on research 

and development for exploration 

farther into space. Another theme 

that would continue to emerge in 

discussions of the commercialization 

of low-Earth orbit was the “significant 

hurdle” for companies to be able 

to profitably market their services in 

the private sector.22

In September 1998, NASA awarded 

five one-year contracts for the study 

of a more cost-effective space 

architecture in order to provide insight 

into how the Space Shuttle would 

be utilized in the future. The five 

companies, including Boeing and 

Orbital Sciences Corp., suggested 

concepts such as launch vehicles, 

in-space transfer vehicles, the 

type of infrastructure necessary 

to support these systems, and 

priorities for investment. The next 

month, Congress passed the 

Commercial Space Act of 1998. 

The Act encouraged the development 

of commercial services by requiring 

the government to “acquire space 

transportation services from United 

States commercial providers 

whenever such services are required 

in the course of its activities.”23

In the late 1990s, reusable launch vehicles were being commercially developed, including 

the Roton by the Rotary Rocket Company, Inc. The cone-shaped single-stage-to-orbit 

manned spacecraft featured helicopter rotor blades and an internal cargo bay.

Credit: Gary C. Hudson
CHAPTER 1 – LAYING THE FOUNDATION 7

Decadal Planning Team 

In June 1999, Administrator Goldin 

formed the Decadal Planning Team 

(DPT), utilizing a core group of experts 

from across the Agency to undertake 

long-term strategic planning for 

NASA’s future direction. In the course 

of the next year, DPT evolved into the 

NASA Exploration Team (NExT). 

For space exploration, DPT/NExT 

envisioned a “stepping stone” rather 

than destination-driven approach. This 

meant that rather than NASA focusing 

on reaching a single goal, such as 

Mars, technologies (including power 

systems and radiation protection) 

should be developed that allowed for 

space exploration in general, allowing 

explorers to methodically venture 

farther into space. 

The NExT annual report for the 2002 

fiscal year listed “full commercial 

use” as one of its main goals. A 

NExT presentation cited both the 

1958 Space Act and the 2000–2003 

NASA Strategic Plan in listing the 

aims to “develop pre-competitive 

technologies with significant 

commercial application” and 

“open the way for U.S. citizens by 

privatization and commercialization of 

the space environment.”24 Although 

Goldin’s term ended in November 

2001 after nearly 10 years as NASA 

Administrator, several of the ideas 

developed under DPT/NExT would 

form key components of future NASA 

policy, particularly the 2004 Vision for 

Space Exploration.

Space Launch Initiative 

While DPT undertook its planning 

studies, in 2000 NASA embarked 

on the Space Launch Initiative 

(SLI), administered by the Marshall 

Space Flight Center in Huntsville, 

Alabama. The goal of SLI was to 

reduce the cost of access to space 

by encouraging the development of 

second-generation RLVs owned 

and operated by the private 

sector. The plan allowed for the 

advancement of multiple, competing 

vehicle concepts that would then be 

methodically narrowed down through 

a series of milestone reviews. In 

2006, the winning concept would 

proceed to development.25

Goldin explained that the “focus 

[is] on developing an integrated 

space transportation plan to meet 

NASA’s needs for human and cargo 

delivery, while seeking synergy with 

the commercial space sector.”26

It is important to note that unlike 

later commercial programs, SLI 

placed a heavy emphasis on NASAdriven and -enforced requirements. 

In 2002, the Government 

Accountability Office reported that 

“NASA believes that much of the 

SLI program’s success is directly 

related to the implementation of 

project management controls and 

appropriate levels of insight,” and 

that the program could not continue 

until NASA was able to define its 

requirements for the vehicle systems 

to be developed.27

At this time, resupply to the 

International Space Station (ISS) 

continued as a growing concern for 

NASA. As Program Manager Tommy 

W. Holloway described: “[ISS] has 

holes in it that you can drive a truck 

through, and getting critical spares up 

to it on time is one of those holes.”28

Alternate Access to Station

The Alternate Access to Station 

(AAS) program formed an important 

part of SLI. In August 2000, AAS 

distributed a total of $902,000 to 

four small businesses—Andrews 

Space, Microcosm Inc., HMX, Inc., 

and Kistler Aerospace Corp.—to 

conduct a 90-day study on the 

feasibility of developing commercial 

vehicles for contingency resupply 

to the International Space Station, 

capable of launching within one 

week’s notice.29 Kistler, which 

in February 2006 would merge 

with Rocketplane Global to form 

Rocketplane Kistler, later would 

be awarded COTS money for the 

development of its K-1 launch system.

Building on that foundation, additional 

AAS studies in the following months 

examined aspects such as what 

sort of space architecture would be 

needed for commercial launches, risk 

reduction activities, and how flight 

demonstrations would be conducted. 

In addition to those listed above, 

some of the 20-plus companies 

that eventually participated in AAS 

included Boeing, Lockheed Martin, 

and Orbital Sciences Corp. Orbital 

was selected as a COTS partner 

in February 2008, and it too had 

formulated early plans for emergency 

cargo delivery to ISS even before 

AAS. According to Robert T. “Bob” 

Richards, Vice President of Human 

Spaceflight Systems, Orbital had 

proposed an unsolicited concept 

called Orb Express that would be able 

to deliver a few hundred kilograms of 

cargo, for example a “critical spare,” 

on a few days’ notice.30

Over the course of the next two 

years, before the cancellation of SLI 

in 2002, AAS participants helped 

develop several of the concepts and 

vehicles that would be seen in COTS 

and follow-on commercial initiatives.31
8 CHAPTER 1 – LAYING THE FOUNDATION

Commercialization 

and the Vision for 

Space Exploration 

The year following the loss of Space 

Shuttle Columbia in February 2003 

would prove decisive for the nation’s 

space policy. While Administrator Sean 

C. O’Keefe led the Agency’s efforts to 

recover from the tragedy of a second 

Shuttle accident, President George W. 

Bush announced his Vision for Space 

Exploration at NASA Headquarters in 

Washington, DC, on January 14, 2004. 

This bold vision planned to return 

humans to the Moon and continue 

onward to Mars with the development 

of the Orion crew capsule and Ares 

launch vehicles, under a new program 

named Constellation. 

And, this new U.S. Exploration Policy 

included a key place for private 

spaceflight companies, by directing 

NASA to “acquire cargo transportation 

as soon as practical and affordable 

to support missions to and from 

the International Space Station.” 

Congress showed its support in the 

NASA Authorization Act of 2005 

by directing the Administrator to 

“develop a commercialization plan to 

support the human missions to the 

Moon and Mars, to support low-Earth 

orbit activities.”32

When he entered as the newlyappointed NASA Administrator in 

April 2005, Michael D. Griffin saw a 

commercial transportation services 

program as a broader piece of 

Constellation: “The commitment 

was that in the long run, when these 

companies had learned how to 

build their rockets and spacecraft, 

they could have the Space Station 

cargo market.”33 Once completed, 

the International Space Station 

would require regular resupply 

of life essentials such as water, 

food, and clothing, not to mention 

critical hardware and experiments 

for scientific research. Commercial 

companies could help provide 

these crucial resupply services, 

freeing NASA to pursue the goal of 

exploration farther into space. 

Ansari X Prize

Further encouraging enthusiasm 

for the commercial space sector, 

Scaled Composites, the enterprise 

of Burt Rutan and Microsoft 

cofounder Paul Allen, won the 

$10 million Ansari X Prize on 

October 4, 2004. The company’s 

SpaceShipOne was the first vehicle 

to fly a human 100 kilometers into 

suborbital space, return, and repeat 

the same feat within two weeks. 

For years, commercial space 

advocates such as James A.M. 

Muncy had implored Congress to 

support commercial space initiatives, 

especially privately-developed 

transportation to and from ISS. 

The flight of SpaceShipOne proved 

that the industry activists who had 

been clamoring for a chance to 

develop private space transportation 

capabilities could in reality develop 

a reusable manned spacecraft 

and achieve human spaceflight, 

independently of NASA.34

Multiple commercial space advocates 

have cited the award of the Ansari 

X Prize as the catalyst for increasing 

government support of private space 

transportation. For these industry 

supporters, SpaceShipOne seemed 

to prove the observation that “the 

high costs of NASA programs are...

dictated by the laws of government: 

Agencies with monopolies are likely 

to do things the safe, expensive 

President George W. Bush announced the Vision for Space Exploration at NASA 

Headquarters on January 14, 2004. He directed NASA Administrator Sean O’Keefe 

(right) and the space agency to develop the plans and the spacecraft to return humans 

to the Moon and continue onward to Mars. Also included in the new policy was a 

provision to pursue commercial opportunities for providing transportation and other 

services supporting the ISS and exploration missions beyond low-Earth orbit.

Credit: NASA/Bill Ingalls
CHAPTER 1 – LAYING THE FOUNDATION 9

way,” and that more efficient 

methods of space development were 

indeed possible.35

Concept Exploration 

and Refinement Study

In September 2004, the Concept 

Exploration and Refinement (CE&R) 

study contracts were instituted 

by Rear Admiral Craig E. Steidle, 

NASA Associate Administrator for 

the Exploration Systems Mission 

Directorate (ESMD). The CE&R funds 

were awarded to 11 companies “to 

conduct preliminary concept studies 

for human lunar exploration and 

the development of the Orion Crew 

Exploration Vehicle.”36

Steidle used his experience 

developing the Navy Joint Strike 

Fighter, in which two competitors 

developed their aircraft independently 

before having a “fly off” to determine 

the winner, to apply competition to 

space vehicle development, aiming for 

a contest by 2008.37

CE&R companies included by-now 

familiar names such as Boeing, 

Lockheed Martin, Orbital Sciences 

Corp., and SpaceHab, Inc. 

Gary Hudson, CEO of HMX, Inc., 

and David Gump established a spinoff 

organization, the Transformational 

Space Corp. (t/Space), specifically 

to bid for the CE&R contracts. 

t/Space won one of the awards 

based on its proposal that outlined 

a space architecture comprised of 

two spirals of development. First, a 

commercial taxi would fly astronauts 

from Earth to orbit (Spiral 1), then 

astronauts would use in-space 

transfer vehicles for transportation 

to and from the Moon (Spiral 2). 

According to both Hudson and 

Bretton Alexander, former Vice 

President for Government Relations 

at t/Space, the company’s work 

under the CE&R contracts provided 

the direct template for what later 

became the COTS program.38

Around the same time, ESMD 

conducted a parallel market research 

survey with 16 companies—including 

Boeing, Kistler Aerospace, the 

recently formed Space Exploration 

Technologies Corp. (SpaceX), and t/

Space—regarding the companies’ 

potential to develop low-Earth orbit 

capabilities and how NASA could 

favorably engage with them. The 

responses returned in December 

2004 provided guidance on some of 

the key principles for working with 

industry that would ultimately manifest 

themselves in the workings of the 

Commercial Crew & Cargo Program 

Office (C3PO).39

ISS Commercial Cargo 

Services 

Less than one year before C3PO 

was established, in the first half of 

2005, the ISS Commercial Cargo 

Services (ICCS) Program administered 

by the International Space Station 

Program Office at the Kennedy Space 

Center in Florida picked up in many 

ways where AAS had left off. The 

NASA budget for fiscal year 2005 

allocated $140 million toward the 

effort to achieve the new program’s 

objectives, described as “the purchase 

of launch, delivery, and earth return 

services for ISS cargo” in light of 

eventual Space Shuttle retirement.40

As part of ICCS, an industry day 

was held April 25, 2005, at the 

Johnson Space Center to review 

“general technical requirements for 

Gary Hudson and David Gump co-founded the Transformational Space Corp. (t/Space), 

specifically to bid for the NASA Concept Exploration and Refinement Study contract. 

(Left to right) Gump, as t/Space president and Hudson serving as Chief Designer worked 

with Charles Duelfer and Brett Alexander to position the company for commercial 

spaceflight business.

Credit: Gary C. Hudson
10 CHAPTER 1 – LAYING THE FOUNDATION

commercial cargo transportation 

services in support of the ISS.”41

Valin B. Thorn, future C3PO Deputy 

Program Manager, presented the 

main goals and requirements, 

outlining how NASA would be 

acquiring a service to ISS, not the 

spacecraft itself. Thorn’s presentation 

also reviewed the basic capabilities 

for such a vehicle, for example 

the amount of cargo needed for 

resupply, as well as ISS docking 

and berthing requirements.42

ICCS was the direct antecedent 

of the Commercial Crew & Cargo 

Program Office established at 

JSC in the fall of that year. By 

February 2006, when the Agency 

released its fiscal year 2007 budget 

request, ICCS had been transferred 

from the ISS Program Office to 

the Exploration Systems Mission 

Directorate, where it was renamed 

Commercial Orbital Transportation 

Services, or COTS.43

Key 

Concepts

These previous NASA projects and 

programs showed the evolving 

nature of NASA’s relationships with 

industry, as the space agency 

moved towards more cooperative 

forms of engagement with the 

private sector. Several of the key 

concepts from those initiatives 

were applied to the COTS program, 

contributing to the successful 

development of commercially-owned 

vehicles for ISS resupply.

Transfer Low-Earth 

Orbit Operations 

to the Private Sector

Documents from the Space Launch 

Initiative had noted in 2002 that 

“U.S. commercial launch vehicles 

are based largely on decades-old 

technology,” allowing “industry 

partners” to take over more routine 

operations in low-Earth orbit while 

NASA focused “more on science 

research, technology development 

and exploration.”44

NASA initiatives such as SLI and 

AAS were already looking to move 

the government away from day-today operations and help industry 

establish more cost-effective space 

transportation capabilities. AAS 

specifically designated its study 

contracts for small businesses, 

aiming to encourage innovation by 

working with companies in the private 

sector that did not have decades 

of experience with traditional NASA 

procurement and operations. 

During the final Shuttle mission in July 2011, Astronaut Sandy Magnus (above) 

facilitated the transfer of approximately 2,700 pounds of food plus more than 

9,400 pounds of spare parts, equipment and other supplies from the multi-purpose 

logistics module to the International Space Station. For years the Space Shuttle had 

delivered goods to the Expedition crews, the astronauts who resided in space on 

the ISS. However, the Vision for Space Exploration policy included a scheduled end 

of the Shuttle Program. This announcement opened the opportunity for commercial 

companies to transport cargo to the ISS.
CHAPTER 1 – LAYING THE FOUNDATION 11

Limited Government 

Investment

For years, advocates of commercial 

spaceflight had observed that 

government investment has been 

used throughout history to promote 

industry and exploration, reaching as 

far back as 15th-century monarchs 

funding voyages across the Atlantic 

ocean.45 In a 1999 commercial 

spaceflight policy seminar, James 

M. “Jim” Beggs, former NASA 

Administrator and General Dynamics 

Corp. Executive Vice President 

and Director, pointed out that “this 

country has subsidized transportation 

for everything over its history. We’ve 

subsidized the railroads. We’ve 

subsidized the aviation industry. Now, 

we’ve got to spend some money and 

subsidize the space transportation 

business.”46 The parallels of the 

transcontinental railroad and Kelly 

Air Act would become mantras of 

commercial space supporters.

Also inherent in this idea was that 

government would be providing a 

financial investment for the express 

purpose of advancing the U.S. 

industry and economy. The Joint 

Explanatory Statement of the 106th 

Congress on NASA Authorization 

commended NASA “for seeking 

means of reducing our dependence 

on the Space Shuttle and Russian 

Soyuz and Progress vehicles for 

access to ISS” with AAS funds.47

The theme of reducing U.S. 

dependence on the Russian vehicles 

for ISS transportation would emerge 

throughout the COTS program and 

into later commercial crew efforts.48

Prior to taking the position of NASA 

Administrator, Griffin had seen the 

concept of limited government 

investment in industry projects work 

in practice. Griffin formerly served 

as the president of In-Q-Tel, “which 

in short form could be characterized 

as the CIA’s [Central Intelligence 

Agency] venture capital fund.”49

NASA began looking at options for future resupply services to the International Space Station with the retirement of the Space 

Shuttle set for 2010. By the end of 2005, NASA identified the core operating principles for an innovative program titled Commercial 

Orbital Transportation Services (COTS). A few months later the initiative was launched with an announcement seeking partners from 

the U.S. private sector. Pictured above is the ISS in July 2006 as seen by the crew of STS-121.
12 CHAPTER 1 – LAYING THE FOUNDATION

In-Q-Tel helped finance Keyhole, Inc. 

to develop the company’s geospatial 

data visualization software—an 

application that became known as 

Google Earth after Keyhole was 

acquired by the internet company 

in 2004.50 Griffin’s experience 

using government funds to spur 

development of technologies which 

would benefit the intelligence 

community, and later have 

widespread commercial application, 

allowed him to transfer the same 

principles to the realm of the private 

spaceflight industry. 

Crucially, for this government 

investment to work, supporters 

believed that the NASA contribution 

must constitute only a limited 

proportion of the total investment; 

the rest would come from private 

sources. In fact this was not a new 

concept. NASA’s first Administrator, 

T. Keith Glennan, envisioned that 

private industry would provide most 

of the financing for the research and 

development of communications 

satellites in the 1960s, although in 

practicality the majority of funding was 

provided by NASA.51

According to this model, government 

involvement would help impart a 

certain “cachet” that would attract 

additional outside investors, but 

the company itself was expected 

to contribute a significant amount 

of money to the project.52 In other 

words, companies needed to put 

“skin in the game,” a phrase used in 

the investment community to describe 

a company’s own commitment to its 

product. This concept described the 

COTS program philosophy that NASA 

and the company were partners, each 

with a stake in the venture.

“Buy a Ticket, 

Not a Vehicle”

Hand-in-hand with the idea of limited 

government investment came the 

important distinction that NASA 

would not be purchasing the vehicles. 

Rather, NASA would help selected 

commercial companies to develop 

cargo transportation services to 

low-Earth orbit, which NASA would 

then be able to buy in the same 

manner as one would buy a ticket on 

a commercial airliner.53

The Commercial Space Act of 

1998 specified that commercial 

space transportation services be 

acquired as a commercial item,54

and the NASA officials who executed 

the program often compared this 

concept to handing a package to a 

courier delivery service. This analogy, 

previously made during Alternate 

Access to Station, indicated 

missions would “demonstrate an 

alternative access capability for the 

ISS,” after which “funds will be used 

to purchase services when they 

become available.”55

NASA had first been introduced 

to this “radical” concept in the late 

1980s, when pro-commercial forces 

advocated that NASA buy ELV 

services, rather than the vehicles 

themselves.56 They claimed the 

government would save 25 percent, 

owing to reduced costs for vehicle 

oversight, privileges NASA was 

reluctant to relinquish. After fierce 

resistance and battles with the 

Department of Commerce, NASA 

began acquiring ELV services in 

1988.57 In 1990, the purchase of 

commercial launch services was 

implemented into law with the 

passage of the Launch Services 

Purchase Act. The Act required 

NASA to “purchase launch services 

for its primary payloads from 

commercial providers whenever such 

services are required in the course 

of its activities.”58

Now, the same principle would be 

applied to cargo transportation flights 

to low-Earth orbit under COTS.

Performance-Based, 

Fixed-Price Milestones

In NASA’s traditional relationships 

with industry, the government is 

obligated to pay the additional cost 

of unforeseen slips in scheduled 

development. Therefore, in the view 

of commercial advocates, contractors 

often have the incentive to do more, 

less-efficient work, as they know they 

will not be financially responsible for 

delays and cost overruns.59

The 2004 ESMD market research 

study proposed the idea of 

“milestones with actual performance 

establishing credibility for future 

funding.”60 In other words, payment 

would only be guaranteed after 

the completion of predefined 

objectives—not on a continual 

basis as is customary under the 

system of a cost-plus contract in 

which companies are awarded a 

contract for the total cost of the work 

performed, plus an additional amount 

for profit. Under this alternative 

concept, any additional work required 

to complete the milestones would 

be the financial responsibility of 

the company, not the government. 

Furthermore, these milestones did not 

necessarily need to be the same for 

each contractor. 
CHAPTER 1 – LAYING THE FOUNDATION 13

Administrator Griffin used the 

metaphor of a home builder to 

describe the approach: “I envisioned 

it as being somewhat like the 

arrangement when you build an 

expensive custom home. ... [The 

contractor] gets a small upfront 

payment to get started, earnest 

money it might be called, and he 

gets milestone payments when he 

completes the foundation and gets 

the framework up, when he gets 

the roof on, when he gets the 

walls in.” Griffin added, “But, he 

doesn’t get all the money until he 

has furnished all the product.”61

Non-Contract 

Approach

Even before the first Space Shuttle 

flight in 1981, NASA had begun 

to examine alternative options to 

traditional procurement contracts. 

In 1979, NASA signed the first 

Joint Endeavor Agreement with the 

McDonnell Douglas Astronautics 

Company to examine the production 

of pharmaceuticals in space. 

The space agency did not provide 

any funds to McDonnell Douglas, 

but allowed cost-free use of the 

Space Shuttle for microgravity 

research experiments.62

Alternate Access to Station also 

recommended new business 

approaches, reporting to the 53rd 

International Astronautical Congress 

that “NASA commercial contracting 

policies present a perceived 

barrier” to commercial companies 

interested in entering the space 

transportation market.63 These 

standard commercial contracting 

policies—what one commercial 

advocate called the “suffocating effect 

of NASA’s dominance”—involved 

cost-plus contract awards governed 

by the stringent Federal Acquisition 

Regulation (FAR).64

NASA implemented the use of performance-based, fixed-price milestones to invest in its COTS business partners. Funding was 

issued only after the completion of predefined objectives, and any cost overruns would be the financial responsibility of the company, 

not the government. This illustration shows actual completion dates. Milestone Schedule charts are included in the Appendix.
14 CHAPTER 1 – LAYING THE FOUNDATION

The FAR dictates an intense process 

to ensure fairness in government 

acquisitions of goods or services, but 

“is not known for its efficiency and can 

be quite cumbersome.”65 Furthermore, 

smaller startup companies felt 

some FAR measures left them at a 

disadvantage. For example, proposers 

were rated on their past performance, 

and companies with no history of 

government contracts could receive a 

maximum rating of neutral.66

Under cost-plus contracts, 

companies must rigorously follow 

NASA-imposed requirements 

and are subject to strict supervision 

by civil servants, potentially 

hindering innovation. Designing 

to specific NASA orders also 

reduced the possibilities for sales to 

customers outside the government. 

To alleviate these constrictions, 

the 2002 AAS report noted that 

“disruptive innovations can be a 

catalyst for change in the industry,” 

adding that “AAS could serve as a 

change agent for the governmentindustry relationship.”67

AAS was cancelled before the 

program could determine an 

alternative legal instrument to develop 

a demonstration or “pathfinder” 

vehicle with industry, but options 

under consideration included 

cooperative agreements and prizes.68

To address this concern, the 2004 

ESMD market research indicated 

companies preferred the use of 

NASA’s Other Transaction Authority 

(OTA), granted in the 1958 National 

Aeronautics and Space Act that 

founded the Agency, for a more 

flexible relationship with NASA.69

Through a series of promising but 

incomplete initiatives, NASA adopted 

several core principles of a new way 

of doing business with commercial 

industry. In the fall of 2005, with 

most of the key concepts in place 

and a new Administrator, the Agency 

applied some of these principles to a 

new venture, the Commercial Orbital 

Transportation Services initiative. 

Having developed the precepts 

for transferring operations to the 

private sector—limited government 

investment, purchasing low-Earth 

orbit services (not vehicles), and 

performance based, fixed-price 

milestones—one major area that 

remained to be defined was exactly 

how NASA could use its special Other 

Transaction Authority. How NASA 

would apply this OTA would form the 

cornerstone of the eventual execution 

of the COTS program.

McDonnell Douglas Astronautics Company provided the first commercial experiment 

for the Shuttle Program – a space continuous flow electrophoresis system (CFES). 

The company modified laboratory instruments to take advantage of microgravity, and its 

engineer, Charlie Walker, operated the CFES during spaceflight. Walker (above, STS-41D) 

served as a payload specialist on three missions before the Space Shuttle Challenger 

accident that ended commercial Shuttle payloads.
CHAPTER 2 – CONCEPT TO REALITY 15 chapter 2 chapter 2

Concept to Reality

Leadership and Coalescence

Legal Team and Space Act Agreements

Thinking Like an Investor

International Space Station

Foundation Ready
16 CHAPTER 2 – CONCEPT TO REALITY

After taking the role of NASA 

Administrator in April 2005, Griffin 

assigned a fixed $500 million 

contribution to be allocated over 

a five-year period, focused on the 

development of cargo capabilities 

only. Griffin provided the initial 

direction for the program, including 

the guidance to use fixed-price 

milestone payments, apply limited 

government investment, preserve 

company intellectual property, 

and minimize requirements in 

order to allow for innovation. The 

Administrator’s guidance also 

specified that cargo capabilities 

should be well established before 

companies progressed to the next 

step of crew transportation.74

NASA Headquarters assigned a 

team at the Johnson Space Center 

(JSC) to manage COTS. As Scott 

J. “Doc” Horowitz, Associate 

Administrator for the Exploration 

Systems Mission Directorate 

(ESMD), said, “If you’re going to 

look at supporting the International 

Space Station, where do you want 

to put that work? The International 

With the key concepts and authorizing policy in place, efforts to promote 

the development of U.S. commercial space transportation capabilities 

began to coalesce into an executable program. The new Commercial Orbital 

Transportation Services (COTS) initiative would not be “business as usual” for 

the space agency. The acronym itself provided an indication of the mission; 

“COTS” typically refers to existing “commercial off-the-shelf” items purchased 

for government use.70

NASA planned for its new initiative to be executed in two phases. First, in 

Phase 1 (what became the COTS program), NASA would help commercial 

companies develop the capability to transport cargo and crew to low-Earth 

orbit. Then, in Phase 2 (the future Commercial Resupply Services contracts), 

NASA would award standard procurement contracts to buy these proven 

“off-the-shelf” services for delivery of supplies and scientific research 

experiments to the International Space Station (ISS). 

The Agency was looking to future commercial providers to fill the gap in ISS 

resupply services after the scheduled retirement of the Space Shuttle in 2010. 

NASA Administrator Michael D. Griffin and several of his top officials at NASA 

Headquarters in Washington, DC envisioned commercial capabilities as “the 

primary planned means of supporting ISS transport in the next decade.”71

If the COTS program proved successful, NASA would have available an 

alternative method of reaching low-Earth orbit, so the Ares rocket and Orion 

capsule being developed under the Constellation Program could focus on 

the goals of returning to the Moon and journeying onward to Mars.

William H. “Bill” Gerstenmaier, Associate Administrator for the NASA Space 

Operations Mission Directorate, described COTS as a “high-risk” contingency 

to see what industry was capable of developing.72 Many of the engineers at 

JSC saw the new commercial initiative as a “side bet” or “back burner” option, 

especially because it received a relatively limited share of NASA’s funding.73

Leadership and 

Coalescence
CHAPTER 2 – CONCEPT TO REALITY 17

Space Station is a customer. 

The people who have experience 

with supplying things to the 

International Space Station were 

at the Johnson Space Center.”75

The new organization at JSC was 

named the Commercial Crew & 

Cargo Program Office (C3PO).

Alan J. Lindenmoyer

NASA needed a leader who could 

manage such an innovative program 

within the JSC environment of 

traditional human spaceflight 

operations. In the fall of 2005, 

Gerstenmaier, former ISS Program 

Manager, handpicked Alan J. 

Lindenmoyer to lead the new 

endeavor. Gerstenmaier recalled 

that he looked for a manager with 

procurement and Space Station 

experience, who was also capable 

of pursuing “creative solutions.” 

That is, he sought a leader that 

was “pretty open, pretty innovative, 

yet had enough business sense 

that they could actually pull together 

an organization and pull that off. 

That was Alan.”76

While an undergraduate at EmbryRiddle Aeronautical University, 

Lindenmoyer had first joined NASA 

in 1982 as a cooperative education 

student at the Goddard Space Flight 

Center in Greenbelt, Maryland. After 

receiving his Bachelor of Science 

degree in Aeronautical Studies with 

Engineering and a commercial/

instrument pilot license in 1983, 

Lindenmoyer completed his Master’s 

in Aerospace Engineering from the 

University of Maryland in 1986. 

In 1987 Lindenmoyer joined NASA 

Headquarters as a structural 

dynamics manager for the Space 

Station Freedom Program. By the 

time the COTS program was initiated, 

Lindenmoyer had accumulated 

nearly 20 years of experience 

working on the Space Station. 

After joining JSC in 1990, 

Lindenmoyer also became known 

as a contract and configuration 

management expert, stemming 

from his experiences in the ISS 

Program Office as the Assistant 

Manager for the Vehicle Office, 

Assistant to the Deputy Program 

Manager for Technical Development, 

Manager of the Configuration 

Management Office, and Technical 

Integration Manager.77

Lindenmoyer assembled the 

members of the small C3PO team, 

who worked diligently to prepare 

the main elements of the COTS 

program on a timeline of only a few 

months.78 They defined the three 

goals of C3PO: 

1) To implement U.S. Space 

Exploration policy with investments 

to stimulate the commercial 

space industry

2) To facilitate U.S. private industry 

demonstration of cargo and 

crew space transportation 

capabilities with the goal of 

achieving reliable, cost-effective 

access to low-Earth orbit

3) To create a market environment 

in which commercial space 

transportation services are 

available to government and private 

sector customers79

Draft COTS 

Announcement

Even before the new program 

office was officially incorporated, 

Lindenmoyer and his team began to 

identify the core operating principles 

of the COTS program. On October 

5, 2005, Lindenmoyer convened 

the first “kickoff” meeting of the 

COTS Procurement Development 

Team at the Johnson Space Center. 

NASA Headquarters official Marc 

G. Timm recalled that the dozen or 

NASA asked Alan Lindenmoyer to develop and initiate a new era in spaceflight that 

focused on private industry providing cargo and crew space transportation for the space 

agency. As Program Manager, Lindenmoyer led a small Commercial Crew & Cargo 

Program Office (C3PO) team and directed the operations of the Commercial Orbital 

Transportation Services program from the Johnson Space Center in Houston, Texas. 

Credit: Don Cohen, NASA APPEL
18 CHAPTER 2 – CONCEPT TO REALITY

so participants contributed ideas 

as Lindenmoyer “started drawing 

circles” on a whiteboard “about how 

we can do this, how we can do that, 

and how we could actually make this 

successful.”80 Timm helped C3PO 

incorporate ISS research and resupply 

needs into the program. Many of 

these were based on the Exploration 

Systems Architecture Study conducted 

in 2005 to, among other things, 

“define the top-level requirements and 

configurations for crew and cargo 

launch systems to support the lunar 

and Mars exploration programs.”81

Three weeks later, on October 28, 

2005, NASA released a COTS 

Spaceflight Demonstrations 

synopsis outlining how “NASA/

JSC plans to solicit proposals from 

industry for Earth to orbit spaceflight 

demonstrations of any combination 

of the following mission capabilities.”82

These capabilities were:

A) External unpressurized cargo 

delivery and disposal 

Capability A “delivers cargo 

(payloads) that operate directly in 

the space environment to a LEO 

[low-Earth orbit] test bed and 

provides for its safe disposal.” 

This entailed the delivery of 

equipment to support the test 

bed structure, such as radiators, 

batteries, pumps, and other orbital 

replacement units that allowed 

the test bed to be serviced and 

used as an orbiting laboratory 

over an extended period of time. 

Unpressurized cargo returned from 

the test bed is destroyed as it 

burns in the atmosphere upon a 

controlled reentry to Earth.

B) Internal pressurized cargo 

delivery and disposal

Capability B “delivers cargo 

(payloads) that operates within 

a volume maintained at normal 

atmospheric pressure to a LEO 

test bed and provides for its 

safe disposal.” In addition to 

the structure itself, the crew 

also required regular supplies of 

food, clothing, and equipment, 

pressurized for delivery inside the 

habitable modules. 

C) Internal pressurized cargo 

delivery, return and recovery

Capability C “delivers cargo 

(payloads) that operate within 

a volume maintained at normal 

atmospheric pressure to a LEO 

test bed and provides for its safe 

return to Earth.” This involved 

the challenging task of returning 

materials intact through Earth’s 

atmosphere, especially scientific 

experiments, and other items 

such as malfunctioning 

equipment for researchers and 

engineers to investigate.

D) Crew transportation

Capability D “delivers crew to a 

LEO test bed and provides for 

safe return to Earth.”83 While 

priority number one was to prove 

cargo capability, the program 

also included a crew option to 

be exercised if and when cargo 

capability had successfully 

been demonstrated. This future 

option would require additional 

NASA funding.

The Commercial Orbital Transportation Services program focused on involving the private 

sector with crew and cargo delivery to low-Earth orbit. NASA offered four different options 

to allow companies the flexibility to optimize their unique services and capabilities.
CHAPTER 2 – CONCEPT TO REALITY 19

The inclusion of four different options 

allowed NASA to select a portfolio 

of companies to meet ISS resupply 

needs while allowing companies 

the flexibility to optimize their COTS 

proposal to their unique business 

plans and markets. 

Not long after the draft 

announcement was posted, the 

Commercial Crew & Cargo Program 

Office hosted an industry day in 

Houston, a preproposal conference 

where the COTS approach was 

unveiled. Lindenmoyer’s team 

outlined the goals and objectives 

of the program, and held one-on-one 

meetings with interested companies 

to get industry feedback. This 

unique approach set the tone for 

how the program would actively 

seek to work with industry as 

partners, not overseers. The 

companies’ input from the meetings 

was then collectively assessed by 

NASA and incorporated into the 

final Announcement for Proposals 

released in January 2006. 

While this advance notice gave 

potentially interested companies 

time to prepare their submissions, 

Lindenmoyer and the COTS 

team continued to refine their 

approach. They examined all 

elements of a traditional procurement 

and retained only those elements 

which they believed contributed 

to a fair and equitable competition, 

filtering out those that they 

felt encouraged bureaucratic 

slowdown and waste.84

Legal 

Team and 

Space Act 

Agreements

The legal process for contract 

procurement was well established 

in the 53-part Federal Acquisition 

Regulation (FAR), but COTS was 

not to be a traditional procurement—

or indeed a procurement at all. 

Instead of acquiring a good 

or service, the nascent COTS 

program would be cooperating and 

partnering with industry in order to 

help them develop low-Earth orbit 

transportation services. 

The COTS team needed more 

than their years of engineering and 

technical expertise to make the 

program a success; they relied on 

expertise in the legal, procurement, 

and financial fields. In order to make 

this new type of relationship with 

commercial partners possible—

as true partners, as opposed to 

contractors—a team of specialists 

in procurement, intellectual property, 

and commercial law assembled to 

design the essential legal framework 

for the successful execution of the 

COTS program. 

The COTS effort brought together 

a formidable contingent of 

experts from both JSC and NASA 

Headquarters to assemble the 

essential legal framework that 

allowed for the successful execution 

of the COTS program. Many of 

the NASA attorneys who worked 

on the program would later 

describe their work on COTS as 

a career highlight, enjoying the 

“energy” that came from creatively 

working to put together a new type 

of NASA program.85

As the program was quickly but 

carefully established in late 2005, 

the legal team stayed in constant 

contact and communication with their 

fellow team members, even over the 

winter holiday break, to prepare the 

programmatic framework necessary 

to allow NASA to partner with industry 

for the development of commercial 

ISS resupply services.86

Together, the group assayed 

current legislation and policy and 

determined how NASA could 

cooperate with industry in such a 

way as to stimulate the commercial 

spaceflight industry. NASA’s 

attorneys reviewed the Federal 

Grant and Cooperative Agreement 

Act of 1977 (Chiles Act), codified in 

the NASA Grant and Cooperative 

Agreements Handbook, to ensure 

the Agency utilized the most 

appropriate legal instrument to 

meet the COTS goal of allowing 

companies to develop their 

technology without the customary 

NASA requirements and oversight 

dictated by standard procurement 

contracts. They used “cautious 

innovation,” staying within the bounds 

of existing policy and legislation, 

particularly the Competition 

in Contracting Act of 1984, to 

accomplish the Agency’s mission.87
20 CHAPTER 2 – CONCEPT TO REALITY

Significantly, NASA was not 

acquiring a good or service for the 

Agency’s direct benefit. Therefore, 

COTS was not a procurement. 

Neither was it a grant or a 

cooperative agreement often used 

when NASA provides funding to a 

university for research. 

In this case NASA would need to 

use a Space Act Agreement (SAA), 

based on NASA’s Other Transaction 

Authority (OTA). The OTA was 

included in the founding charter 

of the space agency, the 1958 

National Aeronautics and Space 

Act. It authorized NASA “to enter 

into and perform such contracts, 

leases, cooperative agreements, 

or other transactions as may be 

necessary in the conduct of its 

work.”88 NASA was the first federal 

agency to receive this “catchall” 

authority, originally included to allow 

NASA to undertake any agreements 

necessary to fulfill the Agency’s 

mission in the Cold War Space Race 

with the Soviet Union.89 As NASA 

attorney Amy Xenofos explained, 

“Any time we do a Space Act 

Agreement, it’s because we can’t 

do it any other way.”90

Space Act Agreements had 

previously been used by 

NASA in their reimbursable 

and non-reimbursable formats. 

Reimbursable agreements 

permitted NASA to collect payment 

for services provided, while 

non-reimbursable agreements 

permitted partnerships without 

an exchange of funds. However, 

funded SAAs in which NASA 

provided payments to a commercial 

partner constituted a relatively 

novel way of doing business for 

the Agency.91 The legal team’s 

diligent efforts to document the 

justification of funded SAAs for the 

COTS program laid a firm foundation 

for the program’s successful 

execution, as would be proven in 

the next few years when the legal 

team was able to successfully 

defend against legal challenges 

brought before the Government 

Accountability Office. 

As part of the ongoing effort to 

carefully distinguish this activity 

from a FAR-based procurement, 

the legal team also advised that 

several elements in the selection 

process be renamed. In place 

of a Request for Proposal, 

COTS issued an Announcement 

for Proposals. In place of a 

Source Evaluation Board to select 

commercial partners, COTS 

utilized a Participant Evaluation 

Panel (PEP). The PEP would focus 

not only on submitted proposals’ 

technical merits, but also the 

companies’ financial credentials 

that included the question: 

what was their potential to bring 

a new commercial off-the-shelf 

service to market? 

Thinking Like 

an Investor

As observed at a 1999 commercial 

space policy seminar, “One of 

the great challenges is taking an 

R&D [research and development] 

organization with a lot of history, 

culture, and institutional structure 

and trying to make it more 

entrepreneurial.”92 In order to 

accomplish their goal, the COTS 

team of NASA engineers also 

needed to learn the fundamentals 

of business and investment. 

Dennis A. Stone

Dennis Stone, the COTS Program 

Integration Manager, had been 

following the efforts of commercial 

spaceflight for decades. After 

receiving dual degrees in physics 

and electrical engineering from the 

University of Hawaii at Manoa in 1977, 

Stone joined McDonnell Douglas to 

design software for the commercial 

Payload Assist Module. He then 

worked at Ford Aerospace and 

Rockwell International supporting JSC 

before joining NASA in 1985. In the 

course of his two decades of work 

on the Space Station, Stone became 

increasingly interested in the potential 

of the private spaceflight sector.

In the early 1990s, Stone pursued 

his interest in commercialization by 

studying government-wide lessons 

learned from buying services and 

data instead of systems. He also 

served as ISS Commercialization 

Working Group Chair prior to the 

formation of the COTS program. 
CHAPTER 2 – CONCEPT TO REALITY 21

Stone encouraged C3PO to solicit 

the assistance of a venture capitalist 

to help the team understand how 

NASA could fill the role of investor, 

providing seed money for companies 

to spur the development of space 

cargo transportation systems.93

Venture Capitalist

On December 21, 2005, JSC issued 

a Request for Proposal for Venture 

Capitalist Consulting Services to 

“support NASA in evaluating the 

business and management aspects 

of COTS participants’ proposals,” 

and “assist NASA in assessing 

the business and management 

performance of selected COTS 

partners.”94 Chosen to work with 

NASA was Alan Marty—a former 

physicist, White House Fellow, and 

venture capitalist—who had worked 

with the NASA Ames Research 

Center in California in the early 2000s 

to help that center find ways to 

encourage innovation.95

Marty was able to apply both his 

business acumen and familiarity 

with government processes and 

programs to provide invaluable 

advice to the COTS team. One of 

the tools Marty placed in the hands 

of the COTS team was the book The 

Innovator’s Dilemma by Clayton M. 

Christensen.96 Marty emphasized the 

book’s principle that for innovation to 

be successful, a spinoff organization 

must be set apart from its parent 

organization and all of its entrenched 

processes and values.97

He encouraged the COTS team to 

examine business plans from the 

companies, especially their proposed 

management teams and financing 

plans. Marty impressed upon the 

team that the ability to secure 

financing by the selected company 

was in fact even more important 

than its technical ability. This concept 

contradicted all the prior training 

NASA engineers had received on 

selecting contractors.98

Marty helped apply Griffin’s 

requirement that COTS partners 

provide true “skin in the game”; this 

was vitally important if NASA was to 

commit to its role as investor of the 

resulting systems. The designated 

$500 million for COTS was nowhere 

near enough to finance an entire 

space development program, 

especially after the sum was divided 

and distributed to multiple companies. 

For the COTS model to work, the 

companies needed to be able to 

secure 1) private capital and 2) private 

customers, in order to provide 3) truly 

private services.99 In other words, too 

much government involvement would 

risk “corrupting the market,” making 

this less a commercial enterprise than 

a government one.100

Through close collaboration with 

what Marty would come to recall 

fondly as “really good friends,” the 

COTS team worked to upend the 

traditional NASA contracting culture 

and encourage the growth of a 

commercial space transportation 

industry by acting as a true investor 

and partner.101 In addition to learning 

from Marty, some team members 

participated in NASA’s Business 

Education Program training course.102

Reflecting back on his experiences, 

Marty commended the COTS team for 

their openness, as they were willing 

to truly listen and alter the traditions 

ingrained as career NASA engineers 

in favor of those more conducive to 

technology investment.103

Venture capitalist Alan Marty (right) 

assisted the C3PO team in evaluating 

business and management proposals 

from the potential partners. Marty had 

worked previously with the NASA 

Ames Research Center in California 

to encourage innovation and during 

the Reagan administration served as a 

White House Fellow. 

Dennis Stone advocated partnerships 

between NASA and industry to 

commercialize space. Stone applied 

his knowledge of the commercial 

space industry and potential markets 

while serving as Business Chair during 

the COTS competitions and as C3PO 

Integration Manager.

Credit: C3PO team

Credit: Alan Marty
22 CHAPTER 2 – CONCEPT TO REALITY

Commercial Friendly

The National Aeronautics and Space 

Act includes the following provision 

regarding commercial opportunities, 

present since 1985, the era of 

Reagan’s administration:

“The Congress declares that the 

general welfare of the United States 

requires that the National Aeronautics 

and Space Administration ... seek 

and encourage, to the maximum 

extent possible, the fullest commercial 

use of space.”104

The COTS program aimed specifically 

to allow small startup ventures 

the chance to compete in NASA 

procurements, in addition to the group 

of large, established contractors 

that usually dominated major NASA 

spaceflight contracts. Many of the 

companies interested in participating 

in NASA’s new program belonged 

to what was dubbed the NewSpace 

community of space entrepreneurs 

and supporters who actively worked 

to promote the development of 

commercial spaceflight. Several 

provisions of the COTS SAAs 

were deliberately crafted to allow 

companies of all sizes to participate.

Intellectual Property

With the help of the legal team, the 

terms of the Space Act Agreement 

were written to allow companies 

to retain a great deal more of their 

intellectual property rights in data and 

inventions than was permitted with a 

traditional NASA contract. 

In the COTS program, because these 

partners were not performing work 

directly for the government, NASA 

was not entitled to their intellectual 

property, property and data rights, 

or proprietary information. Tellingly, 

Articles 12 and 13 of the SAA on 

Intellectual Property and Data Rights 

are the longest in the Agreements.105

Creative License

Lindenmoyer and his team were 

conscious of the fact that the volumes 

of detailed technical requirements 

normally levied on NASA contractors 

could be stifling to innovation. In lieu 

of strict requirements, the COTS 

Announcement provided a set of 

straightforward guidelines to allow 

companies to provide the needed 

services to ISS in the manner that 

worked best for their unique potential. 

For example, companies pursuing 

Capabilities B and/or C needed to 

demonstrate the ability to deliver 

8,400 kilograms (about 18,520 

pounds) of cargo to low-Earth orbit 

per year. However, the COTS team 

made a point not to specify other 

factors, such as the dimensions of the 

vehicle, its cargo capacity, the number 

of flights per year, and sites for launch 

and operations.106

Under the Space Act Agreement, 

companies were allowed and even 

encouraged to develop vehicles 

and capabilities that could be 

marketed to potential customers 

outside the government, whereas 

the traditional contract approach 

resulted in systems that would 

be owned and operated solely by 

NASA. “We wanted companies to 

be able to freely innovate, to take 

maximum advantage of whatever 

concept they had, whatever strengths 

they had in their company that could 

bring this capability to market with 

the minimum constraints possible,” 

said Lindenmoyer.107

Committed Partnership

To further encourage private 

investment, the Space Act Agreement 

provided very limited provisions for 

termination by NASA. Traditional 

NASA contracts often contain a 

termination for convenience clause, 

which allows the government to 

end the agreement for any reason 

it chooses. The COTS Space Act 

Agreements, however, could be 

terminated under Article 17 only in 

the case of A) Mutual Consent, B) 

Failure to Perform [i.e., the company’s 

failure to meet the agreed-to 

milestones], or C) Reasons Beyond 

NASA’s Control that included national 

emergencies, declarations of war, or 

“failure of Congress to appropriate 

sufficient funding.”108

In contrast to a traditional cost-plus 

contract, COTS partners would only 

receive payment from NASA after 

they had completed established 

milestones, meaning the company, 

not NASA, would be responsible 

for any cost overruns. Financial 

milestones were set early in the 

program, so if a company failed to 

meet the required amount of private 

financing, the Agreement could be 

terminated early before NASA had 

invested a more substantial sum of 

money into the project. This allowed 

for sharing of financial risk, and gave 

NASA an “exit ramp” in case the 

partner was unable to raise its share 

of the capital.109 Such a scenario 

was not only possible, but indeed 

became a reality after the Round 1 

COTS competition.
CHAPTER 2 – CONCEPT TO REALITY 23

International 

Space 

Station

The other key component of the COTS 

program involved the International 

Space Station itself. The question 

of whether or not to use the ISS as 

the orbital test bed for companies’ 

demonstrations to low-Earth orbit did 

result in a minor legal dilemma. On the 

one hand, the COTS program aimed 

to allow for as much creativity in design 

as possible, without the imposition of 

detailed specifications. On the other 

hand, companies with sights on a 

demonstration mission to the ISS had 

to contend with the Station Program’s 

set of strict, predefined visiting vehicle 

requirements for rendezvous, proximity 

operations, and berthing or docking. 

The inclusion of ISS requirements 

would have violated both the spirit 

and the letter of the COTS model of 

minimal requirements. 

Ultimately, companies were 

presented with the option of using 

the International Space Station to 

demonstrate the capability to deliver 

cargo to a vehicle in low-Earth orbit. 

Consequently, if that option were 

chosen, companies that elected 

to use the Station as an orbital test 

bed would be obligated to meet 

ISS requirements. Although the 

majority of bidders ultimately did 

propose to visit the ISS in order to 

better position themselves to compete 

for a future services contract, it was 

important that this was not levied as 

a strict requirement.110

For those that chose to demonstrate 

to a test bed other than the ISS, 

the draft SAA included an alternative 

set of language. As part of the 

proposed business plan, submissions 

needed to include an Operational 

Readiness Plan that explained how 

the company planned “to offer 

operational services” to ISS.111

With that legal technicality resolved, 

the next issue presented itself in 

the form of the ISS visiting vehicle 

requirements. Hundreds of pages 

with thousands of requirements had 

evolved over the decades-long history 

of ISS development and operations, in 

particular integration with the Russian 

Soyuz and Progress spacecraft, the 

European Space Agency’s Automated 

Transfer Vehicle (ATV), and the Japan 

Aerospace Exploration Agency’s H-II 

Transfer Vehicle (HTV). How could 

startup companies, without the 

detailed background knowledge of 

ISS visiting vehicle integration, have 

a fair chance in the competition? 

The answer lay in the expertise 

of Lindenmoyer’s chosen Deputy 

Program Manager, Valin B. Thorn. 

Vehicles visiting the International Space Station follow strict requirements for rendezvous, 

proximity operations, and berthing or docking. Adhering to these requirements was the 

Japan Aerospace Exploration Agency for its HTV, (pictured above), a large unmanned 

capacity cargo vehicle that first transferred supplies to the ISS in 2009. The vehicle’s 

nickname, Kounotori, is the Japanese word for “white stork,” symbolic of the important 

cargo it ferries to the astronauts living in low-Earth orbit.
24 CHAPTER 2 – CONCEPT TO REALITY

Valin B. Thorn

C3PO Deputy Manager Valin B. Thorn 

graduated with a Bachelor of Science 

Degree with honors from Arizona 

State University, and also attained 

a commercial pilot’s license with 

instrument and multiengine ratings. As 

a member of the Experimental Aircraft 

Association, Thorn had seen firsthand what a small team of engineers 

could accomplish, and strongly 

believed in the potential of commercial 

spaceflight endeavors. Thorn came 

to C3PO with some 25 years of 

aerospace experience, with 15 of 

those focused on ISS. Having led ISS 

systems engineering and integration 

teams such as Vehicle Integrated 

Performance and Resources 

(VIPER) and Strategic Planning 

and Requirements (SABER), Thorn 

possessed a broad-based knowledge 

of how different components of the 

ISS worked together.112

Crucially for the COTS program, 

this knowledge also encompassed 

the requirements for integrating 

a new visiting vehicle into the ISS 

architecture. Already in April 2005 

Thorn had presented “ISS Commercial 

Cargo Services: Requirements and 

Constraints Summary” at the industry 

day at JSC for companies interested in 

providing commercial cargo services 

to the ISS.113

Interface Requirements 

Document

Instead of overwhelming 

companies with multiple volumes 

of documentation, Thorn and a 

small team of support contractors 

synthesized and distilled the most 

crucial information from existing 

Interface Control Documents 

for the ATV and HTV into 

the approximately 130-page 

COTS Integration and Interface 

Requirements Document (IIRD). 

Only a few days after the COTS 

Announcement, on January 25, 2006, 

Thorn’s team released the IIRD 

in an easy-to-follow format. The 

document provided the companies 

an introduction and overview of what 

to expect regarding working with the 

ISS while preparing proposals.114

Consistent with the COTS Model, 

the IIRD introduction included the 

statement that “COTS providers are 

given flexibility to propose rationale 

back to NASA for choosing to modify 

or not meet a stated requirement.”115

Applicants were encouraged to find 

innovative, creative ways of doing 

business, while still operating safely 

and fulfilling the mission to low-Earth 

orbit; the requirements were not 

important in and of themselves, but 

for the ultimate purpose of providing 

commercial cargo transportation 

services to the ISS.

Foundation 

Ready

By January 18, 2006, NASA had 

released the program’s Announcement 

for Proposals with the terms of 

the competition. Included in this 

Announcement was a draft Space 

Act Agreement friendly to commercial 

interests, allowing a degree of flexibility 

rarely seen in a government contract. 

In the span of a few months, the 

unique assemblage of engineers, 

lawyers, procurement specialists, and 

a venture capitalist that comprised the 

COTS team had succeeded in putting 

together the key documents for 

NASA’s new way of doing business, 

transitioning a set of unproven 

concepts into the reality of the 

Commercial Crew & Cargo Program. 

As Lindenmoyer observed, “The 

Space Act [Agreement] itself was so 

commercial friendly, companies loved 

this. They knew this was not business 

as usual. They knew this was going to 

be a different way of doing business, 

and were very supportive of it and 

complimentary of NASA for developing 

this new way of investing.”116

The commercial space transportation 

industry was one step closer to 

its goal of delivering cargo to the 

International Space Station. When 

they embarked on this new, disruptive 

venture, some members of the COTS 

team expressed unflagging confidence 

that the program would work, while 

others at NASA were less certain. 

One thing, however, was clear: the 

JSC team, with help and guidance 

from NASA Headquarters and outside 

experts, was going to give it a try.

C3PO Deputy Manager Valin Thorn 

utilized his knowledge and experiences 

gained from 25 years of working in the 

aerospace field and the ISS Program 

to help guide the new Commercial 

Crew & Cargo Program. As part of his 

contributions, Thorn led the effort to 

consolidate crucial integration information 

in an easy-to-follow document for 

potential industry partners interested in 

flying their vehicles to the International 

Space Station Program.

Credit: C3PO team
CHAPTER 3 – COMPETITION 25 chapter 3

Competition

Round 1

Round 2

Unfunded Space Act Agreements
26 CHAPTER 3 – COMPETITION

Round 1 Announcement

NASA released the Commercial 

Orbital Transportation Services 

(COTS) Announcement for Proposals 

on January 18, 2006.117 After a brief 

introduction explaining the COTS 

background and philosophy, the 

Announcement described NASA’s 

intent to award funded Space Act 

Agreements (SAAs) for spaceflight 

demonstrations to low-Earth orbit of 

the following capabilities:

A: External cargo delivery 

and disposal

B: Internal cargo delivery 

and disposal

C: Internal cargo delivery 

and return

D: Crew transportation

The Announcement also included 

several other key provisions. First, 

because the COTS program aimed to 

develop a U.S. capability to low-Earth 

orbit, the Announcement specified 

that the company be “more than 

50 percent owned by United States 

nationals,” or provide substantial 

evidence of its commitment to 

U.S. interests.118 Companies, of 

course, needed to comply with U.S. 

laws such as commercial space 

launch acts, and the Iran and Syria 

Nonproliferation Act.119

Second, the Announcement specified 

the format and the page count for the 

prescribed proposal contents, limiting 

the submission to 65 to 90 pages 

depending on which capabilities were 

proposed. The COTS selection team 

viewed this abbreviated proposal as 

a first step before conducting the 

decisive face-to-face due diligence. 

Members weighed this so-called “kick 

the tires” stage as a venture capitalist 

would, using it as a prescreening 

mechanism usually not permitted by 

FAR-based procurements.120

According to C3PO Deputy 

Manager Valin B. Thorn, many of the 

companies that submitted proposals 

actually found that preparing these 

consolidated submissions, limited 

to the most important points, was 

actually more difficult than including 

every possible element in detail. 

However, having a concise and tothe-point proposal made it easier for 

evaluators to determine its merit and 

still provided sufficient information to 

differentiate between companies.121

Finally, the draft Space Act Agreement 

found in the Announcement’s 

appendix provided the legal basis for 

key provisions such as intellectual 

property rights. Companies were 

allowed to propose alterations for 

specific needs and to identify their 

unique milestones with requested 

NASA funding for each.

NASA attorney Amy V. Xenofos 

reported that NASA had little idea 

of what kind of proposals to expect 

from companies interested in NASA’s 

new way of doing business.122 By 

not imposing technical requirements, 

the Announcement allowed 

companies to submit a creative 

range of possibilities. Despite this 

The first COTS competition took place in 2006, as the Commercial Crew & 

Cargo Program Office (C3PO) embarked on the operational phase of NASA’s 

new way of doing business with the private space industry.

Round 1
CHAPTER 3 – COMPETITION 27

flexibility, C3PO Program Integration 

Manager Dennis A. Stone stressed 

that a detailed evaluation plan was 

established before proposals arrived 

and was “strictly followed.”123

Participant 

Evaluation Panel

Just as the legal team endeavored to 

help NASA meet its mission through 

the institution of funded SAAs, the 

procurement team contributed 

their knowledge of fair acquisition 

and objective selection practices 

and processes that had evolved 

over decades of NASA-contractor 

relations.124 The Participant Evaluation 

Panel (PEP) was set up to review the 

proposals, and carried over many 

principles and procedures from the 

traditional government procurement 

Source Evaluation Board. 

The variations introduced by COTS 

allowed the PEP to preserve the 

program’s goals of not imposing 

overly strict requirements, and to 

“level the playing field” for startup 

companies with little or no history 

of government contracts. The panel 

understood the importance of 

examining the proposal’s technical 

merit—important for spacefaring 

vehicles aiming to service the 

International Space Station—as well 

as the potential partner’s viability as a 

commercial entity. 

C3PO Manager Alan Lindenmoyer 

chaired the Participant Evaluation 

Panel, overseeing the efforts 

of the three PEP committees: 

technical, business, and financial. 

The committees drew on teams of 

advisors and technical experts, but 

only six members were granted a 

vote: the PEP Chairperson, Technical 

Committee Chair, Business Committee 

Chair, Financial Committee Chair, 

Safety and Mission Assurance Senior 

Representative, and a Contracting 

Officer-Agreements Officer.125

Thorn led the technical committee, 

applying his years of ISS integration 

experience to determine the feasibility 

of the plans to reach ISS. His team 

included representatives from 

multiple NASA centers and a variety 

of disciplines. Bruce A. Manners, 

who would later serve as a COTS 

Project Executive, was one of the nine 

members of this team.

Stone was able to apply his 

knowledge of the commercial space 

industry and potential markets in his 

role as chairman of the six-member 

business committee that also included 

venture capitalist Alan Marty. The 

business committee evaluated the 

company’s potential to “operate 

a sustained, profitable entity that 

may supply the market of space 

transportation services to NASA and 

other customers,” and examined 

aspects such as the experience of 

each company’s management team 

and financial plans.126

Soon after becoming NASA Administrator, Mike Griffin (seated left) assigned a fixed 

$500 million allocation over a five-year period to focus on commercially-developed 

cargo transportation capabilities. Responsible for the new program was Scott “Doc” 

Horowitz (right), NASA’s Associate Administrator for the Exploration Systems Mission 

Directorate. He served as the Selection Authority for the COTS program’s first round 

of Space Act Agreements.

Credit: NASA/Bill Ingalls
28 CHAPTER 3 – COMPETITION

The small, three-member financial 

committee, chaired by Vickie H. 

Gutierrez, evaluated the reliability of 

cost estimates and the requested 

amount of funding from NASA. Mark 

D. Erminger served as the senior 

representative from the Office of 

Safety and Mission Assurance, and 

would continue as the designated 

Safety and Mission Assurance Officer 

for the majority of the COTS program. 

Proposals

In total, NASA received 21 proposals 

from 20 companies “across the full 

spectrum of the industry” by the March 

3, 2006, deadline.127 Scott J. “Doc” 

Horowitz, the Selection Authority at 

NASA Headquarters for the COTS 

Space Act Agreements, described the 

proposals as ranging from “somebody 

[who] was going to build a rocket 

engine in their garage” to some that 

offered to conduct a study without 

building any physical hardware, and 

“everything in between.”128

The companies ranged from major 

names in the aerospace industry 

such as The Boeing Company 

and Lockheed Martin Corp. (which 

submitted two proposals, one for 

all four capabilities, and one for only 

Capability B), to established but 

smaller-scale launch companies such 

as Orbital Sciences Corp., to littleknown startups such as PanAero Inc. 

and Venturer Aerospace.129 Some 

proposals included vehicles that 

resembled the soon-to-be-retired 

Space Shuttle, while other designs 

were similar to the capsule spacecraft 

of the Apollo Program. Multiple 

proposals relied on heritage concepts 

and hardware, while others advanced 

new technology such as non-water 

landings on airbags.

Before the PEP conducted a more 

in-depth analysis, the Contracting 

Officer-Agreements Officer was 

responsible for an initial review of 

the proposals. NASA Contract 

Specialist James W. Bailey 

determined whether or not the 

submissions were “consistent with 

Announcement’s instructions” and 

“otherwise acceptable for purposes 

of evaluation.”130

After passing this preliminary 

compliance review, the PEP found 

that 18 submissions met the Step 1 

Initial Screening criteria of feasibility, 

relevancy, and affordability for 

commercial resupply services to 

ISS within the desired timeframe.131

The PEP evaluated these 

proposals on 1) how well the plan, 

if implemented, would meet the 

goals of the Announcement, and 

2) confidence that the plan could be 

implemented. In keeping with the 

goal of providing opportunities 

for both startups and established 

aerospace contractors, the PEP did 

not consider past performance 

under government contracts in the 

decision-making process. Evaluators 

did, however, examine the past 

experience of company leaders, 

as well as its business plans and 

management structures.132

Instead of numerically scoring the 

proposals as in a traditional Source 

Evaluation Board, submissions 

were assigned levels of confidence 

based on how convinced NASA was 

that the company could execute its 

proposed plan, from “very high level 

of confidence” to “very low level 

of confidence.” These levels were 

based on the degree of strengths and 

weaknesses established in each of 

the three committees’ findings. 

The PEP assigned a color to each 

level of confidence (blue for very high, 

green for high, white for moderate, 

yellow for low, and red for very low). 

A matrix provided a visual summary 

of key proposal attributes the PEP 

took into account: capabilities 

covered, the color ratings, potential 

markets, amount requested from 

NASA, and the choice of orbital test 

bed (ISS or other).133

Selection

NASA made the decision to select 

two companies in order to allow for 

competition, while at the same time 

being able to distribute sufficient 

amounts of money to each partner for 

their development programs.134 Only 

3 percent of the COTS budget was 

set aside for operating funds, leaving 

$485 million total for distribution 

between the selected partners. 

Prior to the final decision, the PEP 

sorted the findings into candidate 

portfolios, i.e., combinations of 

finalists that listed a variety of options 

to fit both the needed capabilities for 

ISS resupply and the COTS budget. 

According to Stone, “This was a most 

significant departure from standard 

SEB practices.”135

The PEP then reported its results 

to the ultimate Selection Authority, 

the Associate Administrator for 

ESMD at NASA Headquarters, and 

his executive council composed 

of various internal and external 

stakeholders. Advisors included 

NASA Headquarters representatives 

from the Office of Safety and Mission 

Assurance, General Counsel, 

Procurement, and Engineering, as 

well as the program offices of ISS 

and Constellation. George C. Nield 
CHAPTER 3 – COMPETITION 29

represented the Federal Aviation 

Administration Office of Commercial 

Space Transportation, and Selection 

Authority Horowitz also brought in 

Byron M. Allen as an independent 

business consultant.136

Horowitz took various factors into 

account in his decision, including 

the total cost, capabilities covered, 

the color-coded rating, both 

business and technical risk, and 

potential markets for the capabilities 

developed.137 Based on PEP input, 

Horowitz selected six finalists (listed 

in alphabetical order): Andrews Space 

Corp., Rocketplane Kistler Limited 

Inc. (RpK), SpaceDev, Inc., Space 

Exploration Technologies Corp. 

(SpaceX), SpaceHab Inc., and the 

Transformational Space Corp. 

(t/Space). Significantly, none of the 

selected companies represented 

the major names in the industry with 

decades of government contract 

experience, but rather exemplified the 

emerging NewSpace community.138

These six finalists then underwent 

a series of intensive due diligence 

meetings. PEP members visited 

facilities and spoke to management 

personnel “face to face, eyeball 

to eyeball,” to better understand 

company operations, particularly the 

qualifications of the management team 

and the proposed funding plans.139

Also present were venture capitalist 

Alan Marty and JSC attorney 

Jonathan A. Arena. The due diligence 

sessions included negotiations on 

Space Act Agreements and desired 

funding levels, sometimes requiring 

days of back-and-forth discussions 

between the companies and NASA 

legal and procurement personnel.140

Companies were also invited to 

address any weaknesses evaluators 

may have found, and the PEP 

subsequently adjusted the findings 

and color ratings for each competitor. 

As a result of this process, most 

of the companies were able to 

improve the ratings for their business, 

technical, and financial plans.141

During the final phase of the 

selection process, on August 15 

and 16, each finalist was allowed 

two speakers to explain the 

company’s proposal to the 

Headquarters selection team—an 

added measure not typical of NASA 

procurements.142 Of the six finalists, 

Horowitz and his team found SpaceX 

to be the clear leader for both the 

technical strengths of the company’s 

Falcon rocket and Dragon spacecraft, 

as well as the company’s solid 

finances and plan for capturing a 

share of the launch market.

SpaceX responded to NASA’s COTS Announcement with a proposal that included a 

two-stage Falcon 9 launch vehicle (left) capable of delivering 78,000 pounds of thrust, 

and the capsule-shaped Dragon to carry crew and cargo to and from the ISS. After 

separation from the rocket, the Dragon would travel to the International Space Station 

where an ISS astronaut would use the Canadarm2 to grapple the spacecraft (right).

Credit: SpaceX
30 CHAPTER 3 – COMPETITION

For the second partner, Horowitz 

narrowed the selection down to two 

potential companies. Rocketplane 

Kistler exhibited an impressive 

technical plan for the reusable 

K-1 launch system, but had some 

weaknesses in its financial credentials. 

On the other hand, SpaceDev 

presented a stronger business case, 

but had a less credible technical plan 

for developing its Dream Chaser 

spacecraft. The Dream Chaser was 

based on NASA’s HL-20 lifting body 

concept from the early 1990s, and 

would utilize an Atlas V launch vehicle 

to reach low-Earth orbit.143

Although “the executive council 

was evenly divided between these 

two finalists,” NASA ultimately 

selected RpK as the second COTS 

partner. Horowitz noted in the Final 

Selection Statement that “SpaceDev’s 

technically complex design with its 

associated adverse cost and schedule 

implications was a greater risk than 

RpK’s financial uncertainty.”144

The inclusion of financial milestones 

to mitigate RpK’s known financing 

risk contributed to the Selection 

Authority’s decision.145 As Horowitz 

would explain later, “In order to be 

selected they had to be technically 

viable. That was the tipping point.”146

Furthermore, RpK proposed to 

provide services on an earlier timeline, 

and its requested contribution 

from NASA fit within the available 

COTS funding.147

On August 18, 2006, SpaceX and 

RpK signed the first funded Space 

Act Agreements of the COTS 

competition. The companies were 

awarded a total of $278 million and 

$207 million respectively (based 

on the amounts requested in each 

company’s proposal) to be paid 

in increments upon completion of 

each of the negotiated milestones.148

The milestones were placed at 

intervals of roughly one every 

quarter, allowing NASA to periodically 

track their progress, but without 

undue interference.149

Round 1 Protest

In late 2006, NASA received the first 

legal challenge to the Agency’s use 

of funded Space Act Agreements. 

Exploration Partners LLC—one of 

the unsuccessful proposers from the 

COTS Round 1 competition—argued 

to the Government Accountability 

Office (GAO) that the company 

should have been awarded one of 

the COTS Space Act Agreements, 

on the grounds that it was “the only 

company that offered a fully funded 

end-to-end transportation system.”150

On December 19, 2006, GAO 

denied the Exploration Partners 

protest. First, GAO found that the 

Serving as the Selection Authority, 

Scott “Doc” Horowitz, NASA Associate 

Administrator of Exploration Systems Mission 

Directorate (ESMD), signed the Space Act 

Agreements, August 18, 2006, officially 

starting the NASA Commercial Orbital 

Transportation Services program partnerships 

with SpaceX and RpK. Sue Fenn, ESMD 

Executive Assistant, is also pictured.

Rocketplane Kistler proposed its K-1 

launch vehicle for crew and cargo launch 

services to the ISS. (Top photo) The 

fully reusable system was designed to 

accommodate a wide range of missions 

and launch satellites to a geosynchronous 

orbit. Operating in two stages, the K-1 

Launch Assist Platform (first stage) was 

designed to carry the Orbital Vehicle 

(second stage) to its trajectory in lowEarth orbit. For NASA’s COTS program, 

the Orbital Vehicle could be configured to 

transport per mission about 2,900 pounds 

of cargo or up to five crew members 

(bottom photo).

Credit: C3PO team

Credit: KAS 1989-2002
CHAPTER 3 – COMPETITION 31

protest was not submitted in a 

timely manner. Second, in what was 

described as a “landmark” case 

for the Agency, as a result of the 

protest, GAO determined that it did 

not have jurisdiction over the award 

of funded Space Act Agreements.151

Past precedent had determined 

the GAO’s lack of authority over 

cooperative agreements, and this 

case extended the same principle 

to other non-contract awards, 

including SAAs. GAO only monitors 

whether or not the Agency used the 

appropriate legal instrument; i.e., 

whether NASA was justified in its use 

of an SAA or should have used a 

traditional procurement.

The COTS legal team at JSC and 

NASA Headquarters credited their 

diligence during the formation of 

COTS for the successful defense 

of the Agency’s funded Space Act 

Agreements. Even before the SAAs 

were awarded, the attorneys made 

sure to forge a consensus within 

NASA so that all the involved parties 

understood that these awards were 

not for goods or services being 

purchased for the direct benefit of the 

government, but rather to stimulate a 

public purpose.152

Attorney Karen M. Reilley explained 

how “not only did we need to 

come up with a process, educate 

ourselves and the rest of our own 

internal community, but document 

that. We made sure that we had a 

good record, literally on paper, of the 

decision-making process that we 

had gone through.”153 Arena added, 

“As lawyers, we wanted it to be 

defensible. We knew what we were 

doing was very unique, and so we 

were likely to get criticized.”154

Round 2

In October 2007 NASA elected to 

terminate the SAA with RpK, citing 

the company’s failure to meet its 

financial and subsequent technical 

milestones. Aware that they may need 

a contingency plan of action as RpK 

began to falter, the COTS team began 

brainstorming how to proceed forward 

with the program. Instead of allocating 

the funds to a runner-up from Round 

1, C3PO decided that the best way 

to continue the program’s goals was 

to hold another round of competition 

and selection. This advanced planning 

allowed C3PO to announce a new 

competition within a month of RpK’s 

official termination.

NASA had paid a total of $32.1 million 

to RpK, which after an approximately 

five percent reduction for program 

operations left $170 million of 

unassigned COTS money for a new 

partner. The Round 2 Announcement 

issued on October 22, 2007, gave 

previous competitors the opportunity 

to submit updated or improved 

financial and technical information, 

while also allowing new competitors 

a chance to propose plans for the 

remaining funds.155

Lessons Learned

Due to the success of the COTS 

Round 1 selection, the team was 

able to use an almost “cookie cutter” 

approach for Round 2, retaining 

many of the same elements and 

people who had participated in the 

first selection.156 The basic text and 

structure of the Announcement 

remained almost identical, but some 

modifications reflected lessons 

learned from the first competition. 

For example, each company was 

limited to submitting one proposal. 

Other changes refined the 

structure of the proposal, reduced 

the page count, and updated ISS 

interface requirements.157

The Round 2 Announcement asked for 

additional financial data in the proposal 

which previously was requested 

during due-diligence meetings. This 

enabled the business team to have all 

financial data earlier in the process for 

thorough evaluation.158

Similarly, the COTS team was able 

to further streamline the evaluation 

and due diligence process, while 

maintaining most of the elements 

that had worked well during the 

first round. Retaining most of the 

same PEP members and committee 

chairs contributed significantly to the 

efficiency of the Round 2 selection. 

One change was the consolidation 

of the COTS business and finance 

functions into one business 

committee. According to Xenofos, 

“We got a little bit smarter about 

how we did the evaluation process,” 

though the process was still not 

disclosed to companies in detail.159

Selection

NASA received 13 proposals by 

the November 22, 2007, deadline 

that gave companies one month to 

prepare their Round 2 submissions. 

Some of the Round 2 participants 

had applied during Round 1, such 

as Andrews Space, Boeing, Orbital 

Sciences Corp., and SpaceX, and 

four of the companies had signed 

unfunded Space Act Agreements 

with NASA earlier that year to help 

them develop their technology without 

milestone payments. A few new 

competitors, such as TGV Rockets, 

Inc., also joined the race. 
32 CHAPTER 3 – COMPETITION

Four proposals were eliminated due 

to deficiencies in their business plans. 

The SpaceX proposal was dismissed 

because it “was only to accelerate the 

crew transportation capability under its 

existing funded Space Act Agreement 

and did not provide an executable 

demonstration plan within the available 

NASA funding.”160 The remaining eight 

proposals were evaluated according to 

levels of confidence, using the same 

process as in Round 1. 

Of these eight, five finalists were 

selected to proceed to the step 

of due diligence: Andrews Space, 

The Boeing Company, Orbital 

Sciences Corp., PlanetSpace, Inc., 

and SpaceHab, Inc. In February 

2008, Selection Authority Douglas R. 

Cooke, who succeeded Horowitz as 

Associate Administrator for ESMD, 

ultimately selected Orbital Sciences 

Corp. as the winner of the COTS 

Round 2 competition. Cooke’s 

decision between the two strongest 

contenders, Orbital Sciences Corp. 

and The Boeing Company, hinged on 

two deciding factors.

First, in Cooke’s analysis, the 

most immediate ISS need was for 

cargo delivery and disposal, i.e., 

Capabilities A and B. Although 

cargo return for scientific research 

samples and crew (Capabilities C 

and D) were “desired,” they were 

not as necessary at the time of the 

selection, particularly considering that 

other routes to crew transportation 

were available from the Russian 

Federal Space Agency (Roscosmos) 

and the Orion crew capsule being 

developed under the Constellation 

Program.161 Boeing proposed all four 

For the COTS Round 2 selection, Orbital Sciences Corp. proposed its Taurus II launch system (left). Later renamed Antares, this was 

the first vehicle developed by the company to use a liquid first stage. Antares (top right) would be equipped with Aerojet AJ-26 engines 

and utilize on its second stage a solid rocket motor from ATK. To deliver cargo to the ISS, Thales Alenia Space in Italy would build 

Orbital pressurized and unpressurized cargo modules (bottom right).

Credit: Orbital Sciences Corp.
CHAPTER 3 – COMPETITION 33

capabilities, with crew as an unfunded 

option, but Orbital’s proposal of only 

capabilities A and B fit better within 

the needed portfolio of commercial 

transportation services.

Second, as Cooke stated in his 

Selection Statement, “A key 

discriminator in this decision is the 

business plan for each company.”162

NASA had learned from experience 

that a company’s financial stability 

was just as important, if not more so, 

than its technical approach. Boeing 

and Orbital had the two strongest 

business cases of the finalists, but 

Boeing proposed to buy launch 

services from other companies, 

whereas Orbital was developing its 

own launch vehicle, the Taurus II 

(later renamed Antares). Launch costs 

would therefore be more directly 

under Orbital’s control.

Furthermore, Orbital already had the 

internal funds necessary to complete 

to development; the company had 

no need to seek additional investors 

or income. Antonio L. Elias, Orbital 

Executive Vice President and 

Chief Technical Officer, described 

the moment when he explained 

the company’s finances to COTS 

representatives during due diligence 

meetings: “It was as if this huge 

load had been lifted, a sigh of relief. 

All of a sudden the great black 

cloud on top of the COTS program 

had been released.”163

Cooke also found that in the areas of 

science missions and small satellite 

launches the Taurus II would meet a 

real market need for a medium launch 

vehicle capability, which he said met 

the “objective of COTS to stimulate a 

broad space transportation market for 

multiple customers.”164

NASA signed the funded Space Act 

Agreement with Orbital Sciences 

Corp. on February 19, 2008, 

incorporating the lessons learned 

from RpK’s termination. In the words 

of Project Executive Bruce Manners: 

“NASA does a really good job at 

understanding what technical risks 

are. But since we had gotten our 

hands burnt on what was always 

RpK’s biggest risk on the business 

side, which was outside of our realm,” 

in Round 2 “we picked somebody 

that was a fairly low business risk, 

who already had the money in-house 

and the ability to put this together.”165

Round 2 Protest

In January 2008, GAO decided the 

second protest regarding the COTS 

program. After NASA terminated 

its Space Act Agreement with 

Rocketplane Kistler in October 

2007, the company protested 

the subsequent COTS Round 2 

Announcement to issue RpK’s 

remaining funds to another 

commercial partner. RpK claimed 

“that the principal purpose of the 

announcement [was] to obtain 

research and development services 

for the direct benefit of NASA,” and 

therefore should have been issued 

under a procurement contract instead 

of a Space Act Agreement.166

This protest was also denied, on 

the grounds that “the record 

supports the agency’s arguments 

that the principal purpose of the 

announcement is to encourage, 

support and stimulate the 

development of a commercial market 

for space transportation”—not to 

obtain a good or service for the direct 

benefit of the government, which 

would in fact require a procurement.167

Unfunded 

Space Act 

Agreements

An important element of the COTS 

program was NASA’s decision to 

also work on an unfunded basis 

with some of the non-selected 

companies. On January 31, 

2007, NASA signed Commercial 

Space Transportation Capabilities 

Agreements, or unfunded Space Act 

Agreements, with PlanetSpace and 

t/Space, two of the unsuccessful 

proposers from the Round 1 COTS 

competition. These non-reimbursable 

SAAs were followed a few months 

later with similar agreements signed 

on June 15, 2007, with three of the 

other Round 1 offerors: Constellation 

Services International, SpaceDev, 

and SpaceHab.168

These agreements allowed the 

partners access to NASA technical 

expertise without the payments of 

funded SAAs. The unfunded SAAs 

did include milestones, but C3PO 

observed their completion as opposed 

to conducting a formal evaluation. 

Sometimes the process was as simple 

as receiving a letter from an unfunded 

partner indicating they had achieved 

the required milestone criteria. 

Being able to continue these 

companies’ relationship with NASA 

after the selection decision was 

important to Lindenmoyer. “He was 

insistent,” recalled NASA attorney 

Sumara Thompson-King, because 

the purpose of COTS was “to 

stimulate industry, so having those 

unfunded agreements would keep 

those folks in the game.”169 They 
34 CHAPTER 3 – COMPETITION

would have the chance to continue 

the development of their vehicles 

for future NASA competitions, and 

NASA was able to show the Agency’s 

support for commercial space 

transportation initiatives.170

Having established the legal 

framework for the COTS funded 

SAAs, the team of NASA attorneys 

also made these unfunded 

agreements possible. Through 

“robust” conversations and policy 

study, the lawyers determined that 

NASA would be able to pursue 

unfunded cooperation with these 

industry partners to help provide 

technical advice, but without going 

so far as to use the agreement as a 

NASA endorsement.171

Although no set rule existed for how 

many unfunded agreements were 

possible, the extent of help was 

limited to available NASA personnel 

time. Each of the unfunded partners 

was assigned to one of NASA’s 

two project executives, who were 

available to answer telephone calls 

and arrange for additional technical 

assistance if necessary.172

All of the companies with unfunded 

SAAs, except Constellation Services 

International, submitted proposals 

for the COTS Round 2 competition, 

with PlanetSpace and SpaceHab 

making it to the final round. Both 

PlanetSpace and SpaceHab were 

highly rated for their technical 

approaches for Capabilities A through 

C, but the companies fell short on 

their respective business plans.173

Following the Round 2 COTS 

award, three of the unfunded COTS 

participants elected to unilaterally 

terminate the agreements with 

NASA. On May 29, 2008, SpaceHab 

gave 30-day notice of its termination, 

stating, “We are unable to continue 

to meet our milestones using only 

internal funding.”174 Constellation 

Services International followed 

on July 15, 2008, reporting that its 

ISS commercial cargo resupply 

service project was being put into 

“indefinite hibernation.”175 That 

October, t/Space also unilaterally 

terminated the company’s unfunded 

SAA with NASA.176

SpaceDev was acquired by the Sierra 

Nevada Corp. in October 2008, and 

the company continued development 

of the Dream Chaser vehicle as part 

of NASA’s subsequent Commercial 

Crew Development (CCDev) Program. 

PlanetSpace competed for the ISS 

Commercial Resupply Services 

contract awarded in December 2008, 

but was outdone by funded COTS 

participants SpaceX and Orbital. 

NASA entered into unfunded Space Act 

Agreements with companies not selected 

in the COTS Round 1 selection process, 

allowing these partners access to 

NASA technical expertise to assist 

companies in further development of their 

vehicles. Above are illustrations of the 

concepts proposed by the five partners.

PlanetSpace

SpaceDev

Constellation Services International

t/Space

SpaceHab
CHAPTER 4 – PROGRAM 35 chapter 4 chapter 4

Program

Funding

Organization

Operations
36 CHAPTER 4 – PROGRAM

The COTS program aimed to maximize 

the use of government funds in order 

to stimulate the U.S. commercial 

space transportation sector. Of the 

$500 million originally allocated in 

2006, C3PO designated only 3 percent 

for program management, leaving 97 

percent, or about $485 million, to give 

directly to the commercial partners. 

In its five-year operating plan set forth 

in August 2006, C3PO planned the 

distribution of its budget in such a way 

that the majority of funds would be 

available to the commercial partners 

in the middle of their development 

programs (see table below).177

In the first round of COTS competition 

in 2006, $278 million was awarded 

to the Space Exploration 

Technologies Corp. (SpaceX) 

and $206 million was awarded to 

Rocketplane Kistler (RpK).178

The C3PO budget request for fiscal 

year 2008 (October 2007 through 

September 2008) had been submitted 

to NASA Headquarters in the summer 

of 2006—before C3PO was officially 

incorporated and before the Round 1 

competition had been announced—

and asked for a $236 million 

appropriation. By the time the fiscal 

year 2008 budget was signed into 

law in December 2007, the plan and 

circumstances of C3PO operations 

had changed. Most significantly, the 

SAA with RpK had been terminated 

two months previously. 

Congress appropriated only about 

$160 million to C3PO, a $76 million 

reduction, and the bill specified that 

COTS could not move forward with 

the selection of a second commercial 

partner until the Government 

Accountability Office (GAO) protest 

regarding the COTS Round 2 

Announcement had been decided. 

According to COTS Resource Analyst 

Lisa P. Price, a Congressional staffer 

asked the program if it could accept 

a budget reduction in fiscal year 2008 

in exchange for greater appropriations 

in later years. Price and her colleagues 

were then able to develop a phasing 

plan that allowed for the continuation 

of the SpaceX SAA and the selection 

of a new partner under the program’s 

revised budget profile.179

NASA’s Commercial Crew & Cargo Program Office (C3PO) contributed 

to the development of commercial space transportation services by offering 

a new form of partnership between the space agency and private industry. 

The success of this effort depended on the synthesis of limited government 

funding, an innovative operating philosophy, and the people who put these 

elements together. 

C3PO focused on administering NASA’s obligations under the Commercial 

Orbital Transportation Services (COTS) Space Act Agreements. This included 

verifying that partners met their predefined milestones, processing milestone 

payments, and providing technical expertise and support to the partners 

when needed.

Funding

COTS Project FY06 FY07 FY08 FY09 FY10 Total

Funding ($M) 52 91 193 130 34 500

Originally planned COTS funding.
CHAPTER 4 – PROGRAM 37

In January 2008 the GAO denied 

the Round 2 protest, freeing NASA 

to select Orbital Sciences Corp. as 

its new partner in February 2008. 

Orbital was awarded a funded 

Space Act Agreement (SAA) for the 

remaining $170 million of available 

COTS funding. At this point C3PO 

increased the percentage of the 

budget withheld for program 

management from 3 percent to 

about 5 percent to accommodate 

the additional development time 

needed for NASA’s new partner. 

C3PO Manager Lindenmoyer 

reported that a traditionally run NASA 

Program may dedicate 10 to 15 

percent of its budget to overhead, so 

even at the increased 5 percent level, 

COTS still represented a significant 

cost savings when compared to 

traditional NASA programs with 

markedly higher management costs, 

and budgets in the range of tens of 

billions of dollars.180

In addition to C3PO’s novel use 

of funded Space Act Agreements 

that allowed partners to receive 

payment only after the completion of 

predefined milestones, the program 

also applied innovation to the process 

for partner milestone payments. 

Under procurement contracts, 

payment could take up to 15 or even 

30 days, but in her role as the COTS 

Resource Analyst, Price was able 

to coordinate with her colleagues 

to establish a process that allowed 

payments to be deposited in the 

company’s bank account within 

only 3 days of milestone approval. 

Price described her goal as an effort 

“to get that money to the partners 

as quickly as we could so that they 

could continue to work without 

interrupting their efficiency.”181

Augmentation

C3PO continued to operate with 

the understanding that it would 

have only the original $500 million 

funding allocation to complete the 

development of both partners’ 

commercial space transportation 

systems. However, around 2009 

NASA and Congressional leaders 

began to assess the need to maintain 

ISS operations after the impending 

retirement of the Space Shuttle 

(originally planned for 2010). 

William H. “Bill” Gerstenmaier, NASA 

Associate Administrator for the Space 

Operations Mission Directorate, 

explained how additional funds 

were needed to provide “mission 

assurance” for the commercial 

resupply capabilities that were 

becoming increasingly critical to the 

Agency’s mission.182 Gerstenmaier 

reflected that, “the focus had changed 

a little bit. Development of this new 

industry was going to be critical to 

us in the future. It was time to invest 

a little bit more money to keep that 

moving forward.”183

Meanwhile, advocates of NASA’s 

new way of doing business had 

been working to promote COTS to 

important policy influencers 

in Washington, DC, particularly 

the Review of United States Human 

Spaceflight Plans Committee. 

The White House Office of Science 

and Technology Policy commissioned 

the committee in May 2009 to 

review the nation’s progress and 

plans for space exploration. More 

often referred to as the Augustine 

Commission for the panel’s chair, 

Norman R. Augustine, this group of 

spaceflight experts included former 

NASA astronauts and representatives 

from private aerospace corporations. 

Bretton Alexander, former President 

of the Commercial Spaceflight 

Federation, later reflected that “by 

putting someone like Norm Augustine 

In May 2009 the White House Office of Science and Technology Policy commissioned 

a panel to review the nation’s progress and plans for space exploration. Referred 

to as the Augustine Commission, this group of spaceflight experts recommended 

NASA’s commercial cargo initiative receive more funding to “incentivize” the COTS 

cargo demonstrations. C3PO ultimately received a $300 million augmentation as a 

result of this assessment.
38 CHAPTER 4 – PROGRAM

at the top, I would have thought 

you were guaranteeing it to never 

say anything good about [NASA’s] 

commercial [initiatives], because he 

was not known for that.”184

However, to the surprise of Alexander 

as well as C3PO, the committee 

advised that more funding be added 

to NASA’s commercial cargo initiative. 

Members of the COTS team at 

JSC reported first hearing of this 

recommendation to add funds to the 

C3PO budget while watching CSPAN 

coverage of an Augustine Commission 

hearing in Washington, DC on 

August 12, 2009. Committee member 

Dr. Sally K. Ride, the first American 

woman in space, presented the 

Commission’s “Scenario Affordability 

Analysis,” and announced:

“We elected to add an additional 

$200 million—this is a one-time 

add—to the COTS cargo baseline in 

FY ’11 ... to incentivize the current 

COTS cargo demonstrations. We’ve 

all come to realize how important the 

COTS cargo is to the future of ISS, 

and we want to make sure that there’s 

incentive for them to perform as we all 

hope they will.”185

The eventual Augustine Report 

released to the public on October 22, 

2009, included the statement that, 

“NASA’s planned transition of much of 

the International Space Station (ISS) 

cargo resupply to the commercial 

sector is a positive development. 

Financial incentives should be added 

to those suppliers to meet their 

schedule milestones.”186

The White House accepted 

the Augustine Commission’s 

recommendation for augmented COTS 

funding. NASA’s FY 2011 budget 

request, submitted in February 2010, 

asked Congress for an additional 

$312 million for commercial cargo 

development, a 62 percent increase 

over the $500 million budget that 

C3PO had been allocated in 2006.187

Furthermore, as a result of the 

Augustine Commission’s finding that 

the Constellation Program was too 

far behind schedule and too over 

budget to meet its goals, in February 

2010 President Obama announced 

the program’s cancellation. In 

addition to the retirement of the 

Space Shuttle, Marc G. Timm from 

NASA Headquarters called this 

decision “a big turning point, where 

the partners became the primary 

systems for transporting cargo to 

and from Station.”188

The NASA Authorization Act of 2010, 

passed on October 11 of that year, 

explicitly approved NASA’s plan to 

augment C3PO funding. It stated 

that, “$300,000,000 shall be for 

Commercial Cargo,” and that “the 

Administrator may apply funds towards 

the reduction of risk to the timely start 

of these [commercial] services.”189

This $300 million augmentation 

(slightly less than the $312 million 

NASA requested since $12 million 

was needed to complete the original 

$500 million program) helped ensure 

that commercial cargo resupply 

services to the International Space 

Station would be available after the 

retirement of the Space Shuttle in 

July 2011. For more on how these 

augmentation funds were applied, 

see Chapter 5: Commercial Partners 

and Chapter 6: Collaboration.

Norm Augustine (right) chaired the 2009 Presidential Commission, Review of U.S. Human 

Spaceflight Plans Committee. Serving as one of the panel members was Sally Ride, the 

first American woman in space. Ride (left) presented the Commission’s analysis that 

included the recommendation of a one-time funding addition to the COTS cargo budget.

Credit: NASA/Paul E. Alers
CHAPTER 4 – PROGRAM 39

Organization

C3PO operated with a very small 

full-time staff to implement its 

partnerships with industry. At most, 

14 NASA civil servants were employed 

in C3PO, in comparison to traditional 

programs that employed hundreds 

of government employees to monitor 

technical development.

The small percentage of the C3PO 

budget designated for program 

management was judiciously 

applied to cover the salaries and 

travel of program office personnel; 

support from JSC safety, budget, 

and procurement offices; as well as 

funding for “as needed” expertise. 

As Price stated simply: “The size of 

the workforce drives the cost.”190

The program maintained lean 

operations, relying heavily on its 

project executives and assistants, 

and drew on engineers and technical 

experts from across the Agency to 

create an “on-call” team known as 

the COTS Advisory Team (CAT). 

A designated Safety and Mission 

Assurance Officer was involved 

throughout the program. Marc G. 

Timm, the Program Executive at 

NASA Headquarters, with the aid of 

assistant Andrea M. Riley, served as 

the liaison between the program office 

in Houston and senior NASA officials 

in Washington, DC.191

Project Executives

Not only did C3PO work towards 

the most effective use of limited 

government funds, the program 

emphasized limited NASA oversight 

to allow the commercial partners 

to pursue innovation. The project 

executives and their deputies 

served as the essential conduits for 

communicating NASA information 

to commercial partners and vice 

versa. Both worked to establish a 

true partnership with their respective 

industry partners, lending NASA 

expertise and providing guidance 

on spacecraft development rather 

than relentlessly monitoring the 

implementation of specific, NASAimposed requirements.

The position of the COTS project 

executives was somewhat analogous 

to the job a project manager might 

do in a more traditional Federal 

Acquisition Regulation-based 

contract, but there were important 

differences. According to Bruce A. 

Manners, the COTS Project Executive 

for RpK and Orbital, the project 

executive served more as a facilitator 

without dictating, driving, or owning 

the design or the program. He added 

that with COTS, NASA was trying to 

do something “broader” and not just 

expecting the companies to “answer 

our requirements.” Manners also said 

that at times he had “to reel” himself 

in and not give the companies the 

direction that they sometimes wanted 

in order to allow them to make a 

better business decision.192

Michael J. “Mike” Horkachuck, NASA 

Project Executive for SpaceX, shared, 

“Sometimes I’d just ask questions 

in a framework to make them think. 

Not necessarily looking for an answer 

immediately ... but it’s a seed.”193

Because the project executives and 

their respective assistants closely 

followed the philosophy of guiding 

without forcing solutions, they were 

able to share technical expertise 

and lessons learned in a genuine 

partnership relationship. “It’s much 

more managing through influence 

than it is managing through force of 

position,” said Manners.194

COTS Program Executive

Marc G. Timm

Program Integration Manager

Dennis A. Stone

COTS Project Executive

(SpaceX)

Michael J. Horkachuck

COTS Project Executive

(Orbital)

Bruce A. Manners

Chief Safety and Mission Assurance Officer

Mark D. Erminger/Jeffrey H. Cyphert

Program Manager

Alan J. Lindenmoyer

Deputy Program Manager

Valin B. Thorn

Administrative Assistant

Starr Reynolds/Linda Turnbough

HQ

COTS Advisory Team

(CAT)

Agreements Officer

Assistant Project Executive

Warren P. Ruemmele 

Assistant Project Executive

Kevin M. Meehan 

Resource Analyst

NASA Centers

Instead of the large organization typical of major NASA programs, the space agency 

used a small program office of about 10 civil servants to manage COTS.
40 CHAPTER 4 – PROGRAM

NASA Deputy Administrator Lori 

B. Garver observed that NASA’s 

relationship with the commercial 

partners was akin to “grandfathers 

taking their grandsons fishing,” 

using a “gentle touch” to guide their 

protégés in the right direction.195

Furthermore, due to the nature of 

funded Space Act Agreements, there 

was no haggling over the cost of 

changes that is experienced with a 

typical contract, allowing for a more 

harmonious relationship.

For both of the project executives, this 

new role also meant the acquisition of 

new skills. Manners and Horkachuck 

increased their business and financial 

proficiency through the COTS team’s 

collaboration with venture capitalist 

Alan Marty, knowledge which would 

become increasingly necessary as 

RpK began to slip on its financial 

milestones. Horkachuck also 

undertook additional training in how to 

handle the increased media attention 

resulting from the SpaceX COTS 

demonstration missions.196

Bruce Manners 

After receiving a B.S. degree in 

Electrical Engineering from Ohio 

Northern University in 1988, 

Bruce Manners spent the first 

years of his NASA career at the 

Glenn Research Center (GRC) in 

Cleveland, Ohio, working on the 

ISS electrical power system. 

Manners eventually progressed to 

the position of Supervisory Engineer 

of the Power Systems Analysis 

Branch, where he came to know 

both future C3PO Manager Alan J. 

Lindenmoyer and Deputy Program 

Manager Valin B. Thorn through the 

ISS office. While serving as a liaison 

for GRC at the Johnson Space 

Center (JSC), Thorn invited Manners 

to participate in the Participant 

Evaluation Panel as a member of the 

technical committee. 

Shortly after helping evaluate the 

COTS proposals in early 2006, 

Manners permanently relocated 

to JSC and began work on power 

and propulsion for the Constellation 

Program, where Manners reported he 

was able to draw on his experience 

and professional ties to form a 

partnership between engineers at 

GRC and JSC. In the fall of 2006, he 

was asked to utilize these skills as 

the NASA project executive for RpK. 

After NASA terminated its Space Act 

Agreement with RpK in October 2007, 

Manners participated in the Round 2 

COTS selection as a voting member 

of the Participant Evaluation Panel, 

which awarded the remaining funds 

from RpK to another competitor. He 

began his work as the NASA project 

executive for Orbital Sciences Corp. in 

February 2008.197

Mike Horkachuck 

Mike Horkachuck worked with 

SpaceX as the NASA project 

executive from August 2006 through 

the completion of the company’s 

Space Act Agreement in 2012. 

Horkachuck graduated from the 

University of Southern California in 

1983 with a degree in Mechanical 

Engineering, and began his NASA 

career at the Ames Research 

Center, where his work on the 

1.8-meter centrifuge for ISS research 

involved extensive coordination 

with the Space Shuttle and Station 

programs. In 1996 Horkachuck 

moved to JSC, eventually being 

promoted to Manager of ISS Payload 

Hardware Engineering Integration, 

managing the team that integrated 

hundreds of science payloads with 

ISS and the Shuttle.

As part of his ISS integration work, 

Horkachuck had previously 

studied options for how to return 

experiment samples more frequently 

to Earth than was possible with 

the Space Shuttle, and helped 

include this important need into 

the high-level ISS goals being 

developed for the nascent COTS 

program at the end of 2005. 

After some months as Chief of 

Development Testing and Verification 

Strategies for the Constellation 

Program, in September 2006 

Horkachuck joined the COTS 

team full-time as the NASA Project 

Executive for SpaceX.198

In addition to his intimate knowledge 

of ISS integration, Horkachuck’s 

previous positions also involved 

partnership-type collaborations 

with the European Space Agency, 

experience that could be applied to 

his new role. After years of working 

within the confines of traditional 

NASA procedures, Horkachuck was 

ready to a support a more efficient 

way of doing business. He found 

SpaceX an appealing choice for a 

partner. “I liked their innovative style, 

and it just seemed like they were a 

more natural fit with my management 

style,” he said.199

Assistant Project 

Executives

Throughout the COTS program, 

Horkachuck and Manners relied 

on the support of their assistant 

project executives. Assistant Project 

Executive for SpaceX Warren P. 

Ruemmele brought his experience 

in mechanical engineering and as 

a Contracting Officer Technical 

Representative and Technical 

Management Representative to the 

collaboration. Horkachuck described 
CHAPTER 4 – PROGRAM 41

multiple occasions when he relied 

on Ruemmele’s aid, for example in 

assembling the COTS Advisory Team 

and searching for NASA resources 

that could help SpaceX meet its 

milestones.200 Assistant Project 

Executive Kevin M. Meehan similarly 

supported Bruce Manners in NASA’s 

engagement with RpK and Orbital.

The COTS project executives and their 

respective assistants were the key 

links in the public-private partnership 

between NASA and commercial 

space transportation companies. 

By respecting the commercial 

partners’ unique business models 

and providing insight rather than 

oversight, the NASA project 

executives were able to forge 

bonds that ultimately resulted in 

the successful development of 

U.S.-based commercial space 

transportation capabilities.

Chief Safety and 

Mission Assurance 

Officer

Throughout the program, C3PO 

included the position of a designated 

Chief Safety and Mission Assurance 

Officer. As a demonstration of the 

priority given to safety and mission 

assurance, the safety officer was 

given a voting role as member of the 

Participant Evaluation Panel in both 

COTS competitions. 

The safety officer collaborated with 

the COTS team and the commercial 

partners to assess various areas 

of risk, and periodically conducted 

essential established safety reviews. 

He participated in major technical 

investigations as well as every major 

partner quarterly and milestone review.  

Additionally, the safety officer played 

an active role in C3PO program-level 

boards and meetings.

The NASA safety officer’s job included 

developing mishap preparedness 

and contingency plans for each 

major integrated vehicle launch 

pad test and flight, detailing what 

steps would be taken in the event 

of a mishap or incident, and who 

would be responsible for leading 

an accident investigation. Prior to 

each demonstration mission, a 

mishap simulation was conducted 

that included all responsible parties 

in the event of an incident. These 

included representatives from C3PO, 

the Federal Aviation Administration, 

and the National Transportation 

Safety Board, as well as the NASA 

Headquarters Chief of Safety and 

Mission Assurance and the Associate 

Administrator for the Exploration 

Systems Mission Directorate.

Mark D. Erminger served as the safety 

officer from September 2006 until his 

SpaceX displayed a Dragon spacecraft during the 2011 Innovation Day event at the Johnson Space Center. Standing by the exhibit are 

C3PO team members: (front, left to right) Bruce Manners, Stan Whalen, Mark Erminger, Joyce Repa, Starr Reynolds, Alan Lindenmoyer; 

(back) Elijah Williams, Warren Ruemmele, Mike Horkachuck, Tom Clemandot, Derek Jones, Valin Thorn, John Bretschneider.

Credit: C3PO team
42 CHAPTER 4 – PROGRAM

retirement in September 2012, when 

Jeffrey H. Cyphert took over the role.

Throughout the program, the C3PO 

Chief of Safety and Mission Assurance 

maintained communication with the 

JSC Safety and Mission Assurance 

Manager and the Office of Safety 

and Mission Assurance at NASA 

Headquarters. Due to the hands-off 

structure of COTS, however, the JSC 

safety officer was not always able 

to share as much in-depth technical 

information as Headquarters officials 

were accustomed to having. Cyphert 

reported this was part of the learning 

curve in working with commercial 

providers as opposed to traditional 

NASA contractors.201

Mark Erminger 

Mark Erminger received a Bachelor 

of Science degree from the U.S. Air 

Force Academy in 1978, and an 

M.B.A. from the University of Missouri 

in 1980. In 1981 Erminger began his 

NASA career at the Johnson Space 

Center, where he worked in the Crew 

Training Division. In this position he 

trained astronauts and flight controllers 

on Space Shuttle operations and 

systems. In 1987, Erminger became a 

flight controller himself.

With more than 10 years in Shuttle 

operations, Erminger was acutely 

aware of the critical importance of 

safety issues in low-Earth orbit. In 

1992 Erminger moved to the office of 

Space Shuttle Safety, Reliability, and 

Quality Assurance as its Manager. 

Among his other duties, in this 

position Erminger coordinated the 

safety reviews of flight readiness for 

Space Shuttle and Space Station 

missions between three field centers 

and NASA Headquarters.

From 2003 to 2005, Erminger used 

this experience as Executive Director 

of the Aerospace Safety Advisory 

Panel (ASAP) at NASA Headquarters, 

after which he returned to JSC as the 

Chief Safety and Mission Assurance 

Officer for the COTS program.202

COTS Advisory Team 

Under COTS, the commercial 

partners, not NASA, established 

their own requirements and 

were responsible for the design, 

development, and testing of 

their spacecraft. However, C3PO 

recognized at the beginning of COTS 

that subject matter experts would 

be needed to advise the partners in 

particular areas of technical expertise. 

Maintaining a full-time contingent of 

engineers was inconsistent with the 

COTS approach of lean operations. 

Instead, the COTS team used 

periodic targeted support when 

specific needs arose, especially for 

the major technical reviews. This 

group became known as the COTS 

Advisory Team, or CAT. Members 

were often referred to as CATs. 

The CAT served two main functions: 

providing partners with NASA’s 

technical expertise and advising 

C3PO on whether partner milestones 

were completed satisfactorily. The 

teams were similar to the support 

teams that Horkachuck had set up 

for the Constellation Program, as 

well as Boeing vehicle team support 

hours that were used by the ISS 

Payloads Office to work technical 

issues. A group of technical experts 

were identified for each discipline and 

an approximate budget of hours was 

allocated to allow for that support 

when needed. 

This NASA engineering expertise 

was vital to COTS. Employing “as 

needed” experts helped create a more 

efficient process for the development 

of the commercial partners’ vehicles 

by lowering NASA overhead and 

reducing costs for dedicated COTS 

personnel. Indirectly, this arrangement 

also saved the commercial partners 

money, since development delays did 

not result in an idle team of engineers 

waiting for work. When challenges 

arose, they were able to utilize CAT 

expertise without hiring their own fulltime support staff. 

To identify CAT members, C3PO 

staff reached out to engineers they 

had worked with previously, many 

of whom saw the COTS philosophy 

as “interesting and challenging.”203

Availability posed something of an 

issue at the beginning of the COTS 

program, as many engineers were 

occupied with work on the Shuttle, 

ISS, and Constellation Programs. 

Project executives sometimes 

encountered difficulty finding 

consistent support for reviews. 

To remedy this, a dedicated point 

of contact was later established 

at each NASA center to help access 

personnel.204 All NASA centers 

provided CAT support, including 

As part of COTS development and 

demonstration programs, partners met 

technical milestones that included major 

engineering reviews and engine tests. NASA 

team members traveled to the SpaceX 

facility in McGregor, Texas, which has a 

number of testing stands, including the 

tripod shown below that is used to test the 

nine Merlin engines on the Falcon rocket. 

Credit: C3PO team
CHAPTER 4 – PROGRAM 43

engineers from the Marshall 

Space Flight Center in Huntsville, 

Alabama, with its rich history of 

rocketry and propulsion.

CAT expertise grew to cover more 

than 30 subsystem disciplines, and 

numbered 100-plus individuals. 

Main CATs disciplines in addition to 

propulsion included avionics; electrical 

power; structures; parachutes; 

thermal control; thermal protection; 

communication and tracking; 

guidance, navigation, and control; and 

pyrotechnics. David W. Thompson, 

CEO and President of Orbital, 

remarked that, “We had roughly half 

of the field center network within 

the Agency at one time or another, 

providing know-how or surplus 

equipment to our work, which made a 

big difference.”205

When working through crack and 

corrosion issues with its AJ-26 

rocket engines, Orbital Sciences 

Corp. engineer Kurt Eberly stated 

that “it was essential to bring all 

that history that [Marshall engineers] 

have working with cracked metals.” 

He described how “they’re able to 

really step in and quickly analyze 

the materials” in order to “help us 

through the process of developing 

the weld repair process and the 

inspection process that assures us 

that the engines are going to be 

flightworthy.”206 Said SpaceX Mission 

Manager Peter Capozzoli, “NASA 

was very willing and very open to lend 

their expertise wherever we asked, 

and often offered up places where 

they thought they could help.”207

CAT members were assigned to 

support both commercial partners 

equally; no CAT members supported 

one partner exclusively, allowing NASA 

to be somewhat consistent in the 

advice provided. Because the majority 

of company data was considered 

proprietary, each CAT member 

signed a non-disclosure agreement 

(or inherently protect proprietary data 

as a civil servant), acknowledging 

the importance of handling partner 

data appropriately and keeping data 

separate from the other partners.

Although most CAT members were 

NASA civil servants, some contractors 

also contributed, many of whom 

were former NASA civil servant “grey 

beards” who could draw on their 

wealth of experience from the Shuttle 

and even Apollo programs. This 

expertise allowed these engineers 

to transmit key lessons learned to 

the commercial partners, relaying 

what had and had not worked well 

historically at NASA. 

The project executives reported 

having to “coach” the CAT members 

early in the program, reminding 

them that COTS worked differently 

than previous NASA programs they 

had supported.208 Horkachuck and 

Manners specifically explained that 

under the Space Act Agreements, 

CATs would be asked to offer their 

best technical advice, rather than 

certifying that a design adhered 

verbatim to NASA requirements and 

standards. They reviewed commercial 

partner data and documented potential 

concerns, sometimes working with 

the commercial partners to provide 

guidance and help with specific design 

challenges. However, they would not 

solve the commercial partners’ issues 

or dictate design solutions.209

Commercial partners took the time 

to explain their design approach 

and company philosophy to CAT 

members, and the project executives 

clarified that due to this partnershiptype relationship, the commercial 

partners had the option of not 

following CAT inputs, except those 

related to safety. In practice, very 

rarely were CAT recommendations not 

followed, and then only with a viable 

alternative approach. 

A few early CAT members had 

difficulty accepting the COTS 

approach and were not invited to 

future technical reviews. However, 

the many who provided support 

throughout the program provided 

an element of continuity, as the 

commercial partners became 

comfortable with and trusted the 

advice of individual CAT members.

NASA Stennis Space Center in Mississippi conducted test firings on the liquid-fueled 

Aerojet AJ-26 engines used to power the first stage of the Orbital Sciences Corp. launch 

vehicle. The first in a series of three firings, this test (pictured above) on November 11, 

2010, was held to verify start and shutdown sequences on the engines, along with test 

stand operations and ground-test engine controls. 

Credit: NASA/Stennis Space Center
44 CHAPTER 4 – PROGRAM

After the successful test flight of the 

Antares rocket, Orbital Senior Vice 

President of Antares Michael R. “Mike” 

Pinkston noted, “I heard nothing 

but rave reviews of the independent 

verification that was done on our 

guidance and control system that 

NASA had provided. It really bolstered 

our confidence going in, and I think 

the results bore out just how critical 

that help was to us, in terms of getting 

it right the first time.”210

Program Integration 

Manager

While the project executives and their 

deputies focused on working with 

the partners, the C3PO Program 

Integration Manager, Dennis A. Stone, 

supported program operations that 

transcended individual partnerships. 

The program integration function 

covered a spectrum of activities 

including quality system compliance, 

external relations, website 

management, unfunded partner SAA 

negotiations, planning, and support 

contractor oversight. 

Contractor Support

C3PO identified the need for a 

small amount of technical support, 

especially with the surge of activity 

predicted during the major milestone 

reviews. For the majority of the 

program, two to three full-time Booz 

Allen Hamilton support contractor 

engineers worked with the COTS 

team through the Advanced Planning 

Assessment Contract.

They designed processes that enabled 

C3PO to have insight into the progress 

of the commercial partners’ space 

transportation systems. Main efforts 

focused on evaluating partner products 

and events associated with the SAA 

milestones. For example, the support 

contractor recommended using 

NASA Support Plans to provide the 

necessary timeline and documentation 

for each design review. These 

documents outlined the purpose of 

the review and detailed the roles and 

responsibilities for those involved. 

As an example of its other 

contributions, Booz Allen 

recommended inputs to the SpaceX 

DragonEye Detailed Test Objective 

(DTO) I & II Project Requirements and 

Verification Document. The DTOs 

tested the relative navigation solution 

for maneuvering a cargo vehicle into 

position to be grappled by the ISS 

robotic arm and berthed to the Station. 

Since ISS integration constituted 

a major component of the COTS 

program, Booz Allen also evaluated 

ISS change requests for impacts to 

C3PO and the commercial partners.

Additionally, Booz Allen supported 

C3PO efforts to communicate 

activities to NASA Headquarters 

and the public, provided content 

recommendations to baseline 

performance review charts, budget 

reports, facility usage charts, etc., 

which went to the Center or NASA 

Headquarters. Also recommended 

were updates to ensure the C3PO 

website content was current.

ARES Corp. provided detailed 

schedule analysis and predictions of 

most likely launch dates. This was 

important to help NASA plan realistic 

support for the program, and proved 

useful in independent reviews of the 

program and for answering questions 

from officials at NASA Headquarters. 

ARES support was most notable 

when the first significant slips in 

milestones needed to be evaluated 

and recommendations made to NASA 

Headquarters on whether or not to 

continue the program.

A proximity sensor named DragonEye, developed by SpaceX, underwent flight system 

trials on the Space Shuttle Endeavour during the STS-127 mission in July 2009. This Laser 

Imaging Detection and Ranging (LIDAR) sensor system provides three-dimensional images 

based on the amount of time it takes for a single laser pulse from the sensor to reach 

a target and bounce back. The successful demonstration provided range and bearing 

information needed to guide the Dragon spacecraft during future ISS resupply deliveries.
CHAPTER 4 – PROGRAM 45

Operations

Over its eight-year history, the 

Commercial Crew & Cargo Program 

Office instituted a new way of doing 

business with the private sector. In 

addition to the use of milestonebased funded Space Act Agreements 

and a focus on commercial viability, 

the COTS program pursued a 

unique approach in other aspects 

of its operations. The use of a small, 

“skunk works”-type team facilitated 

communications. The process of 

milestone assessment allowed 

NASA to verify completion of partner 

progress (necessary for the companies 

to receive payment) without undue 

oversight and interference.

Communications 

C3PO aimed to maintain open 

lines of communication with COTS 

team members at JSC and NASA 

Headquarters (including legal and 

procurement), the general NASA 

community, NASA’s current and 

potential industry partners, and the 

public. C3PO made a concerted effort, 

especially in the early days of COTS, 

to share the program’s approach 

with the aerospace community. The 

team understood that the COTS 

philosophy was different from how 

industry had previously worked with 

the government, and would require a 

proactive effort to achieve widespread 

understanding of how NASA planned 

to foster the commercial space 

transportation industry. 

The C3PO Program Integration 

Manager worked on developing the 

COTS ecosystem, those sectors on 

which COTS partners depended, 

such as investors, regulators, insurers, 

and non-government markets. This 

typically involved communicating 

with these sectors about COTS and 

NASA’s plan to buy cargo services 

to ISS. Dennis Stone gave special 

attention to developing the market 

for microgravity services, which could 

open new demand for COTS partner 

vehicles as free fliers.

COTS team members also spoke at 

various aerospace forums, including 

the annual American Institute of 

Aeronautics and Astronautics 

(AIAA) Space Conference, as well 

as commercial space events such 

as the Space Frontier Foundation’s 

annual NewSpace conference, 

and the annual Federal Aviation 

Administration (FAA) Commercial 

Space Transportation conference.

Although C3PO was small, it 

had reporting obligations to 

both the NASA Johnson Space 

Center and NASA Headquarters. 

Scheduled quarterly meetings 

allowed Lindenmoyer, the project 

executives, NASA Headquarters, 

and ISS representatives to meet 

with commercial partner executives 

and gain insight into the companies’ 

progress. The results were 

summarized in quarterly reviews by 

C3PO with ESMD management. 

COTS Program Executive Marc G. 

Timm at NASA Headquarters served 

as the program’s conduit to other 

federal entities. These included 

Congressional offices, the Office 

of Management and Budget, and 

the White House. Said Timm, “The 

program wasn’t set up to have a 

large contingent of folks to do that 

interfacing, so we purposely put 

together the processes that would 

allow us to accomplish this with a 

very small number of people.”211

He added he talked often with 

Lindenmoyer and worked closely with 

public affairs, legal, and legislative and 

intergovernmental affairs offices at 

NASA Headquarters.

NASA’s Johnson Space Center in Houston hosted a media briefing in April 2012 to 

preview the SpaceX demonstration mission to the International Space Station. Pictured 

are (left to right), briefing moderator Josh Byerly; William Gerstenmaier, NASA Associate 

Administrator for Human Exploration and Operations; Mike Suffredini, Manager, 

International Space Station Program; Alan Lindenmoyer, Manager, Commercial Crew & 

Cargo Program; and Elon Musk, SpaceX Chief Executive Officer and Chief Designer.

Credit: NASA/Bill Stafford
46 CHAPTER 4 – PROGRAM

Proprietary Data 

A critical component of the COTS 

team’s communication plan was 

to ensure they did not share the 

proprietary technical information that 

belonged to the commercial partners.

Although a traditional NASA contract 

may have some company data which 

the space agency must protect, 

in COTS nearly all the commercial 

partners’ data was considered 

proprietary. The SAAs strictly 

precluded NASA from sharing partner 

data, even with NASA personnel, 

unless they were directly involved in 

reviewing partner milestones. C3PO’s 

rigorous approach to protecting the 

companies’ data included requiring 

all personnel who worked on the 

project, from NASA civil servants to 

contractors, to sign a non-disclosure 

agreement and maintain proprietary 

data in restricted online libraries.

Under traditional NASA contracts, the 

government typically owns the data 

and can use it for other programs. 

Everyone working on the COTS 

program understood they were 

allowed to use the partner data only 

for COTS support. In one case, CAT 

members at the Marshall Space Flight 

Center supporting Orbital’s Antares 

rocket engines were evaluating use 

of the same Aerojet engines on 

another project. Bruce Manners, the 

NASA Project Executive for Orbital, 

described how C3PO had to be “rigid 

and specific” to ensure that the data 

and knowledge acquired under COTS 

was not applied to other efforts.212

Milestone Assessment 

The COTS Space Act Agreements 

outlined a series of technical and 

financial milestones to be completed 

as part of the commercial partners’ 

development and demonstration 

programs. Technical milestones 

typically consisted of major 

engineering reviews, engine tests, 

hardware delivery, and demonstration 

launches. After the COTS budget 

was augmented in fiscal year 2011, 

some extra technical milestones for 

SpaceX and Orbital were added to the 

SAAs, mainly for additional hardware 

and engine tests to reduce risk and 

enhance safety.

The language of the SAAs was 

intentionally written in broad 

terms with respect to milestone 

reviews. C3PO anticipated that the 

commercial partners’ development 

programs would evolve, and with 

the aggressive COTS development 

schedules, the details of milestone 

verification were settled closer to the 

actual event. Some criteria, such 

as engine firings, were fairly easy 

to monitor and verify. Other criteria 

required a degree of discussion and 

negotiation between the COTS team 

and their industry partners.

The major technical reviews—System 

Requirements, Preliminary Design, 

Critical Design, and Demonstration 

Readiness—required the most NASA 

and COTS Advisory Team support, 

being the most complex of the 

various SAA milestones. The criteria 

for these reviews were tailored after 

the NASA Procedural Requirements 

document NPR-7123, NASA’s 

standard for Systems Engineering 

Processes. The partners and the 

project executives agreed on the 

details and logistics of the engineering 

reviews, and the overall process 

evolved as COTS progressed. 

While no two engineering reviews 

followed exactly the same steps from 

start to finish, all utilized a similar 

process. After C3PO determined 

the amount of support needed for 

a particular review, COTS Advisory 

Team members were recruited. 

Early in the COTS program, ISS 

support was fairly limited, but 

became more intense as commercial 

partners approached the engineering 

milestones to prepare for their ISS 

demonstration missions. The ISS 

Transportation Integration Office 

coordinated the ISS support from 

its office and worked with C3PO 

throughout those reviews. 

The partners organized documents 

into relevant subsystems and created 

suggested reading lists for the 

CAT subsystem teams due to the 

large amounts of documents and 

overlapping subsystems. An easy-touse Review Item Discrepancy (RID) 

As one of its COTS milestones, SpaceX 

conducted a series of high-altitude drop 

tests in August 2010 to validate parachute 

deployment systems and recovery 

operations. An Erikson S-64F Air-Crane 

helicopter dropped a test article of the 

Dragon spacecraft from a height of 

14,000 feet, roughly 9 miles off the coast 

of Morro Bay, California.

Credit: SpaceX/Roger Gilbertson
CHAPTER 4 – PROGRAM 47

form, once completed by the teams, 

was merged into one spreadsheet for 

efficient sort, review, and prioritization. 

Typically reviewers had two to 

three weeks to submit RIDs. Then 

the support contractor facilitated 

a RID screening session, filtering 

on occasion up to 600 items. The 

screening sessions, sometimes two 

days or longer, would filter out RIDs 

that were out of scope for the COTS 

program, clarify the intent of poorly 

worded RIDs, and combine multiple 

RIDs to try to minimize the workload 

on the commercial partner. Only 

after the NASA project executive 

had approved the RIDS were they 

submitted to the commercial partner. 

This process ensured consistency, 

and prevented the partners from 

being overwhelmed by NASA inputs.

Partners addressed the approved 

RIDs by providing additional 

information or analysis and 

worked with RID submitters to 

ensure concerns were adequately 

addressed. C3PO monitored this 

process and became involved with 

closing out RIDs as necessary. This 

RID process became such a reliable 

staple that both the ISS Commercial 

Resupply Services contract team 

and Commercial Crew Program at 

the Kennedy Space Center requested 

to use the form.213

Milestone Review Boards

The Milestone Review Boards 

occurred at the partners’ respective 

headquarters, attended by C3PO, ISS 

representatives, NASA Headquarters 

officials, and a representative from 

the Federal Aviation Administration. 

The commercial partner chaired the 

board. During the meeting, in addition 

to demonstrating completion of the 

milestone, the company presented 

information on the mission, a status of 

all the subsystems, and key forward 

work. Open RIDs were discussed, 

along with plans for closure. The most 

significant technical RIDs identified 

through the screening process were 

also presented, even if they were 

closed satisfactorily. This provided 

NASA and partner management 

with insight into the most significant 

findings of the review. 

Unlike some reviews of previous largescale NASA programs that routinely 

spanned several months, the COTS 

milestone reviews spanned anywhere 

from a few weeks to a maximum of 

just over two months. These thorough 

yet efficient reviews reflected the 

overall COTS operating style.

Demonstration Flights 

The Demonstration Readiness Review 

was originally derived from the 

established NASA procedure for a Test 

Readiness Review, but also needed 

to encompass much of what is 

known as an Acceptance Review and 

Certification Review for hardware that 

NASA would have taken ownership of 

in a traditional contract. C3PO found 

aspects of these reviews were still 

high-value added when preparing to 

launch a rocket into space. 

Reviewing qualification reports and 

acceptance test reports for lingering 

anomalies in hardware performance 

allowed for a clear understanding of 

the design baseline and the as-built 

vehicle configuration. CAT members 

were assigned test reports and 

analyses to review, and the RID form 

was modified to inform the project 

executives that the data had been 

reviewed and was satisfactory for 

flight. This helped the partner confirm 

that all the hardware was ready for the 

intended mission, and was also a key 

point communicated to Headquarters 

officials at the prelaunch briefing and 

mission overview.

After the Demonstration Readiness 

Review (the final technical review) 

and before the demonstration flight, 

additional work was needed in several 

areas. Multiple mission simulations 

occurred between the partners 

and NASA Missions Operations, 

emphasizing key elements of the 

NASA utilized a number of its assets used during the Space Shuttle Program to help in 

performance assessment of the SpaceX C2+ mission in May 2012. The two Solid Rocket 

Booster Retrieval Ships, Freedom Star and Liberty Star, both carried an X-band diagnostic 

radar system that detects and quantifies in-flight launch vehicle behavior and any generated 

debris. Also on board the Freedom Star was the MARS high-powered, sea-stabilized 

tracking camera system that monitored the separation of the Dragon spacecraft from the 

Falcon 9 launch vehicle. These ships and diagnostic radar systems also helped to observe 

the Falcon 9 maiden flight in June 2010 and the SpaceX C1 mission in December 2010.
48 CHAPTER 4 – PROGRAM

rendezvous and berthing to ISS. 

The project executives took 

preparatory steps necessary to 

monitor mission success.

In the case of the first flight of the 

SpaceX Falcon 9 rocket, Project 

Executive Mike Horkachuck described 

how he and Assistant Project 

Executive Warren Ruemmele “scoured 

the Agency” to locate assets that 

could contribute additional insight 

into the vehicle’s launch and reentry 

performance.214 The launch team 

was able to use radar originally 

deployed to look for falling foam 

during the Shuttle launches following 

the Columbia accident. In addition, 

the Shuttle solid rocket booster 

retrieval ships helped monitor the 

SpaceX mission from sea. These 

additional resources allowed NASA 

to independently understand the 

launch staging events and solar array 

deployment, areas that historically are 

high risks to new vehicles. 

Similarly, prior to the Orbital Antares 

rocket test flight, C3PO “scrounged 

unique devices” from around NASA to 

help make the mission a success.215

These included instruments to 

measure the rocket’s acoustic 

environment, as well as high-speed 

tracking cameras that would provide 

insight into any potential accidents.

Prior to the demonstration missions, 

all the key stakeholders, including 

C3PO, the ISS Program Office, 

and the FAA met at the respective 

partner’s launch facility for a Mission 

Readiness Review to ensure all parties 

were ready for launch and that no 

open issues remained.

Shortly after the mission was 

completed, the partners provided 

C3PO with a “quick look” report, 

showing how the mission performed 

based on the data available. 

Several weeks later, after a more 

detailed report was produced, 

C3PO called on CAT experts to 

review the flight data and determine 

if any additional analysis was 

recommended. Only after all the data 

had been thoroughly reviewed could 

the partner receive payment for a 

successfully completed milestone.

Although the same method was 

applied throughout the COTS 

program, the circumstances of each 

of the commercial partners’ respective 

development program varied 

according to the company’s unique 

history, technology, and approach. 

Each of the three companies that 

C3PO partnered with is profiled in 

the following chapter.

(Left) During both Orbital Sciences Corp. missions, NASA used its ground KTM (kineto tracking mount) cameras previously used for 

the Space Shuttle Program. These were deployed from the Kennedy Space Center in Florida to Wallops Island, Virginia, to monitor the 

launch and early ascent phase of the Antares vehicle in April and December 2013. These camera systems also helped to observe the 

SpaceX missions—Falcon 9 maiden flight in June 2010, C1 mission in December 2010, and C2+ mission in May 2012. (Right) NASA 

utilized the U.S. Navy vessel NAWC-38 to carry an X-band diagnostic radar system that detects and quantifies in-flight launch vehicle 

behavior and any generated debris during both launches of the Antares rocket, built by Orbital Sciences Corp.

Credit: C3PO team
CHAPTER 5 – COMMERCIAL PARTNERS 49 chapter 5

Commercial Partners

Space Exploration Technologies Corp.

Rocketplane Kistler

Orbital Sciences Corp.
50 CHAPTER 5 – COMMERCIAL PARTNERS

SpaceX may be the most wellknown of the three companies that 

were awarded funded Space Act 

Agreements under the Commercial 

Orbital Transportation Services (COTS) 

program. The technical triumphs 

of the Dragon cargo spacecraft 

and Falcon 9 rocket received 

extensive media coverage, as the 

company’s demonstration flight to the 

International Space Station (ISS) in 

May 2012 captured national attention, 

encouraged by the company’s active 

social media presence. 

SpaceX had already been working 

on the Falcon rocket and concept 

for the Dragon spacecraft at the time 

of the first COTS Announcement in 

January 2006, but NASA’s call to 

partner with commercial companies 

provided additional incentive to 

formulate vehicle specifics and turn 

the concept into reality.216

Company Philosophy

SpaceX submitted a strong business 

plan in its proposal, and this was 

among the reasons NASA selected the 

company as the first choice partner in 

the COTS Round 1 competition.217

Both SpaceX’s business and 

technological strengths stemmed 

from its Silicon Valley-style operating 

philosophy, gleaned from founder, 

CEO, and Chief Designer Elon Musk 

and his entrepreneurial experience 

in the area of California known for 

development of innovative, highrisk technology ventures. Musk 

founded SpaceX in 2002 using 

his know-how and capital from a 

previous venture, PayPal, the secure 

online payment website.218

SpaceX’s explicit aim is “to 

revolutionize space technology, 

with the ultimate goal of enabling 

people to live on other planets.”219

The company’s innovative approach 

to rocketry has allowed SpaceX to 

achieve its near-term goals, as 

the company becomes increasingly 

competitive with major industry 

players such as The Boeing Company 

and Lockheed Martin Corp.220

NASA Partnership

Throughout the six years of its COTS 

partnership with NASA, SpaceX 

relied on the indispensable expertise 

of C3PO and the COTS Advisory 

Team (CAT), NASA Project Executive 

Michael J. “Mike” Horkachuck and 

Assistant Project Executive Warren 

P. Ruemmele in particular. With 

experience in Shuttle and ISS payload 

integration, Horkachuck was wellpoised to assist the SpaceX team 

on their quest to develop a vehicle 

capable of berthing with the ISS and 

providing critical resupply services.

SpaceX personnel eventually came 

to view the project executive not 

as a NASA overseer, but as a vital 

member of their team. Horkachuck 

The Commercial Crew & Cargo Program Office (C3PO) worked with three 

different commercial partners from 2006 through the COTS program’s 

completion in 2013: Space Exploration Technology Corp. (SpaceX) (from 2006 

to 2012), Rocketplane Kistler (from 2006 to 2007), and Orbital Sciences Corp. 

(from 2008 to 2013).

Space Exploration 

Technologies Corp. 
CHAPTER 5 – COMMERCIAL PARTNERS 51

described how SpaceX came to trust 

his judgment, saying, “I had a lot more 

history than most of the employees 

at SpaceX on what was going on 

and how things worked. When they 

first came in, they had the ‘I know it 

all’ kind of attitude. It took a while for 

them to learn that maybe they could 

use some help in some areas.”221

Hans Koenigsmann, SpaceX Vice 

President of Mission Assurance, said, 

“We realized we were going through 

this with NASA, and they go through 

this with us. It’s a partnership, and 

we’re both in this. If we fail, they fail. 

If they fail, we fail.”222 Tim Buzza, 

SpaceX Vice President of Launch 

and Test, echoed Koenigsmann’s 

sentiment: “The ‘us and them’ 

mentality disappeared once we got 

‘into the trenches,’ getting the work 

done that both sides proposed to do. 

Then it was just an ‘us.’”223

Vehicles

SpaceX worked to develop the 

capabilities proposed in the 

company’s COTS proposal, beginning 

with A, B, and C, i.e., pressurized 

and unpressurized cargo delivery 

and return services to and from the 

ISS. Using the Falcon 9 rocket to 

launch the capsule-shaped Dragon 

spacecraft into low-Earth orbit, the 

SpaceX COTS proposal indicated it 

would be able to deliver 6,835 pounds 

of cargo to the ISS per flight, at a 

rate of eight flights per year.224

At the time of the COTS award, 

SpaceX was still developing its Falcon 

1 rocket, named for the Millennium 

Falcon spacecraft commanded by Han 

Solo in the popular Star Wars film. The 

numeral one designated the vehicle’s 

single Merlin engine. The two-stage, 

liquid oxygen- and kerosene-fueled 

rocket was 70 feet long, weighed 

61,000 pounds, and was capable of 

delivering 78,000 pounds of thrust. 

After three failed attempts to reach 

orbit, the Falcon 1’s first successful 

launch occurred on September 28, 

2008, from the remote island of 

Kwajalein in the Marshall Islands.225

Hans Koenigsmann, who had 

previously worked as the SpaceX 

Vice President of Guidance and 

Control, described the first launch 

failure as “heartbreaking.” “A lot of 

people worked a long time,” he said, 

but “at the end, it didn’t fly very far.” 

However, Koenigsmann added, “We 

learned a lot of things we did wrong, 

and learning sometimes hurts.”226

Using the experience gained from 

the Falcon 1 development process, 

SpaceX was ready to progress to 

bigger and heavier rockets that relied 

on multiple Merlin engines. 

On June 4, 2010, less than two 

years after the Falcon 1 launch, 

SpaceX successfully launched the 

227 foot Falcon 9 rocket (with 9 

Merlin engines), capable of generating 

1,125,000 pounds of thrust at sea 

level, and 1,250,000 pounds of thrust 

in the vacuum of space.227 Due to the 

expense and logistics of transporting 

people and materials to the Pacific, 

by this launch SpaceX had moved 

its operations from Kwajalein to Cape 

Canaveral in Florida. Koenigsmann 

explained that this way SpaceX 

would also be close to the company’s 

NASA customer.228

Liftoff of the inaugural SpaceX Falcon 9 launch vehicle occurred June 4, 2010, from the 

Space Launch Complex 40 at Cape Canaveral Air Force Station, Florida. The 227-foot 

rocket with 9 SpaceX Merlin engines carried a boilerplate of the Dragon spacecraft in 

preparation for the upcoming NASA COTS demonstration mission. 

Credit: SpaceX
52 CHAPTER 5 – COMMERCIAL PARTNERS

On its second flight on December 8, 

2010, the C1 demonstration mission of 

the company’s Space Act Agreement, 

the Falcon 9 carried the first SpaceX 

Dragon spacecraft to orbit, after which 

it successfully reentered, splashed 

down, and was recovered. 

Dragon features a recoverable 

capsule and disposable “trunk” for 

unpressurized cargo. In total, the 

vehicle is capable of ferrying 13,228 

pounds of upmass and 6,614 pounds 

of downmass to and from low-Earth 

orbit. The spacecraft propels itself in 

space with the use of 12 to 18 Draco 

thruster engines, and relies on a 

PICA (Phenolic Impregnated Carbon 

Ablator) thermal protection system to 

protect the capsule during reentry to 

Earth’s atmosphere.229

Musk reputedly named the spacecraft 

after the 1963 song “Puff, the Magic 

Dragon,” in response to critics’ 

skepticism that the startup company 

would be able to achieve its goals. 

The company also displayed a sense 

of humor with the C1 mission’s “top 

secret” payload of a wheel of cheese, 

in reference to a Monty Python 

comedy skit.230

Off-the-Shelf

SpaceX developed its technologies 

using a business model that fits 

many of the observations on 

disruptive technology found in The 

Innovator’s Dilemma, the book 

that venture capitalist Alan Marty 

recommended to the C3PO team 

to help them understand how large 

organizations can nurture internal 

innovation. For example, the 

statement that “generally disruptive 

innovations were technologically 

straightforward, consisting of offthe-shelf components put together 

in a product architecture that was 

often simpler than prior approaches,” 

describes the company well, despite 

the fact that the book was published 

years before SpaceX was founded.231

SpaceX made widespread use of 

off-the-shelf hardware in developing 

its first launch vehicle, the Falcon 

1 rocket. Engineers found these 

readily-available components to be 

significantly cheaper and equally 

reliable as space-specific hardware. 

As reported by Fast Company

in 2005, the SpaceX Falcon 1 

would use an Ethernet bus for 

communication between the rocket’s 

different computers. “I didn’t want 

to invent anything new,” explained 

Hans Koenigsmann.232

Other examples included components 

of avionics equipment such as 

satellite navigation and a readilyavailable airbag from Musk’s electric 

car venture, Tesla Motors, Inc. For 

the crewed variant of the Dragon 

spacecraft, SpaceX utilized a modified 

bathroom stall latch for securing 

cargo lockers and NASCAR fivepoint harness restraint seatbelts for 

astronauts—both off-the-shelf items 

that cost significantly less to purchase 

and were more comfortable for crew 

use than their much more expensive 

space-rated counterparts.233

Small Organization

SpaceX was also able to pursue 

innovation by virtue of its small 

organization. With less than 100 

employees at the time of the COTS 

award in 2006, communication 

flowed easily between team 

The second flight of the Falcon 9 on December 8, 2010, met the objectives for the C1 

demonstration milestone of the company’s COTS Space Act Agreement, and established 

SpaceX as the first commercial company in U.S. history to return a spacecraft from 

Earth’s orbit. The mission tested the Dragon’s ability to be launched, maneuver in orbit, 

reenter, and be recovered.

Credit: SpaceX/Chris Thompson
CHAPTER 5 – COMMERCIAL PARTNERS 53

members.234 John Couluris, Senior 

Director of Launch and Mission 

Operations at SpaceX, described how 

employees were trusted to execute 

their jobs without disproportionate 

oversight, thus streamlining the 

development of new designs and 

hardware.235 Issues were easily 

resolved with a simple face-to-face 

conversation, and design changes 

could be quickly communicated to 

colleagues in manufacturing. 

This was even more true in 2008, 

when SpaceX moved from a group of 

separate buildings and facilities in El 

Segundo, California, to a large factory 

in the neighboring south Los Angeles 

suburb of Hawthorne on Rocket 

Road, where development and 

manufacturing could be completed 

under one roof—a roof that used to 

cover Boeing operations, and before 

that served as the original home of 

The Northrop Corp. formed in 1939.

This sense of close camaraderie 

sometimes extended beyond work 

hours. While on Kwajalein, employees 

also benefited from days and weeks 

spent together in the Marshall Islands. 

In addition to their work, teams spent 

much of their limited off-time in close 

proximity as they commuted between 

islands and, for lack of many other 

activities or distractions, fishing and 

diving together.236

Design and 

Manufacturing

Project Executive Mike Horkachuck 

observed that in contrast to traditional 

NASA methods of development in 

which a vehicle is designed to optimal 

levels of performance before assembly 

and testing, SpaceX built some 

additional margin and “robustness” 

into its design from the beginning. 

Then, vehicles could be more easily 

altered and optimized after tests 

provided demonstrable measures of 

their performance.237

SpaceX also stuck closely to its 

philosophy of pursuing a thorough test 

program. The company conducted 

a test of every Merlin engine at its 

rural McGregor, Texas, facility (an 

existing test pad purchased from 

defunct Beal Aerospace) as close to 

flight conditions as possible. Using 

reimbursable Space Act Agreements, 

in which SpaceX paid NASA for its 

services, the company also relied on 

NASA facilities such as the Marshall 

Space Flight Center in Huntsville, 

Alabama, for services like wind tunnel 

testing of the Falcon 9 first stage.238

As SpaceX matured as a company 

over the course of its partnership 

with NASA, it also increasingly 

shifted to manufacturing more of its 

own components in-house at the 

Hawthorne facility. In many cases 

this strategy helped the company 

deliver the same or better quality 

while saving money, particularly 

when vendors charged prices 

the company deemed too high. 

SpaceX also made a point of using 

American companies as suppliers 

whenever possible—in contrast to its 

competitor Orbital, which preferred 

an international collaboration.

One of the most prominent examples 

of the company’s manufacturing 

capability is PICA-X, SpaceX’s 

version of the heat shield material 

developed in cooperation with 

NASA Ames Research Center. 

(Ames developed and patented the 

original PICA material in the 1990s.) 

By developing its own material 

for Dragon’s thermal protection 

system, SpaceX also avoided the 

risk of potential price manipulation 

that can result from reliance on a 

single-source supplier.239 In fact, 

during the COTS competition, NASA 

identified the company’s in-house 

capabilities as a major strength of the 

company’s proposal, as they allowed 

for “improved project control and 

simplified interfaces/integration.”240

SpaceX worked closely with NASA’s Ames 

Research Center to develop PICA-X, 

a SpaceX variant of NASA’s Phenolic 

Impregnated Carbon Ablator (PICA) heat 

shield. Under a reimbursable Space Act 

Agreement, NASA made its expertise and 

specialized facilities available to SpaceX 

as the company designed, developed, and 

qualified the heat shield. Dragon’s PICA-X 

protected the spacecraft during reentry.

Technicians inside a processing hangar 

at Cape Canaveral Air Force Station, 

Florida, guide the SpaceX Dragon as it is 

lifted atop its cargo ring. The spacecraft 

is designed to carry both pressurized and 

unpressurized cargo to the ISS and safely 

return cargo to the Earth.

Credit: NASA/Kim Shiflett 

Credit: SpaceX/Roger Gilbertson
54 CHAPTER 5 – COMMERCIAL PARTNERS

Milestones

In August of 2006 NASA awarded 

SpaceX its COTS Space Act 

Agreement worth $278 million, to 

be paid in increments upon successful 

milestone completion, to develop 

the capability to deliver and return 

cargo to and from low-Earth orbit.241

Musk had always envisioned a system 

capable of transporting humans—

not only cargo—across the solar 

system, but the first step was ferrying 

supplies to the ISS (though the 

vehicles were designed for robustness 

from the beginning, with an eventual 

human rating in mind). Human 

transportation to low-Earth orbit, 

COTS Capability D, was included as 

an option in the SpaceX SAA (one that 

NASA never exercised).

SpaceX executed the 40 total 

milestones of its Space Act Agreement 

between August 18, 2006 (the date 

NASA signed the agreement) to 

May 2012, when SpaceX successfully 

completed the objectives of the 

company’s final COTS mission 

to berth with the International 

Space Station. That August, NASA 

completed its verification that this 

milestone’s objectives had been met. 

Financial Milestones

By March 2009, SpaceX had 

completed the three financial 

milestones that proved the company 

could contribute its promised share 

of the funding needed to finish 

development of the Falcon 9 and 

Dragon vehicles. NASA placed 

these financial markers early in 

the program to allow the space 

agency to exit the agreement 

early, should it become necessary, 

before expending excessive monies 

on an unsuccessful development 

program. In addition to his own 

resources, Musk was able to turn 

to his network of colleagues in 

Silicon Valley to lead the subsequent 

rounds of financing that made it 

possible to forge ahead with the 

COTS agreement.242

However, SpaceX did experience 

financial struggles. Looking back, 

President Gwynne E. Shotwell 

described her biggest challenge as 

seeking investors and convincing 

potential customers to purchase 

launch services before SpaceX was 

able to demonstrate the capabilities 

of the Falcon vehicles. “I was focused 

on keeping the company alive, 

keeping people paid while we were 

struggling and getting through it,” 

Shotwell said.243

Technical Milestones

Paper-based milestones (System 

Requirements Reviews, Preliminary 

Design Reviews, Critical Design 

Reviews, and Demonstrated 

Readiness Reviews) and other 

technical milestones (for example 

engine tests and a cargo integration 

demonstration) took place as 

intermediate steps to the three primary 

COTS demonstration missions. 

The C1 mission on December 8, 

2010, tested the Dragon’s ability to be 

launched, maneuver in orbit, reenter, 

and be recovered. Moments after the 

SpaceX C1 demonstration mission 

lifted off the pad, members of C3PO 

monitoring from the partner launch 

control center in Florida leapt from 

their seats to run outside and watch 

the rocket clear the tree line, lifting into 

orbit. After two orbits and a successful 

splashdown, the engineers gave each 

other thunderous high fives—with a 

few receiving a champagne shower.244

NASA also deployed its Shuttlelaunch debris radar and Shuttle solid 

rocket booster retrieval ship assets 

to observe the reentry of the SpaceX 

C1 capsule, the first U.S. commercial 

vehicle to reenter from space. This 

and the parachute deployment were 

some of the most critical aspects 

of the SpaceX C1 mission. These 

assets also would have provided 

invaluable information in the case of 

an in-flight anomaly.245

The next milestone mission, C2, would 

comprise a Dragon launch and flyby of 

the ISS, while C3, the final milestone, 

would complete the berthing and 

cargo delivery demonstration.

Schedule Slips

SpaceX’s original schedule proposed 

to complete all milestones by 

September 2009. As the milestones 

SpaceX conducts rigorous tests on its 

engines at its McGregor, Texas, rocketdevelopment and test facility that originally 

had been developed by Beal Aerospace. 

SpaceX refitted the largest test stand for 

the full Falcon 9 engine firing (pictured 

above). Also at this location are new test 

stands, a vacuum chamber to test the 

Draco thrusters, and buildings where 

employees de-fuel and clean up the 

flown Dragon spacecraft and potentially 

refurbish it for reuse.

Credit: SpaceX 
CHAPTER 5 – COMMERCIAL PARTNERS 55

transitioned from more paper-based 

benchmarks—i.e., financing rounds 

and design reviews—to the building 

of physical hardware, milestone 

completion began to slip behind the 

original, very aggressive schedule. 

Eventually schedule slips resulted in 

a cumulative delay of approximately 

two and a half years, and the final 

demonstration mission originally 

planned for September 2009 did not 

occur until May 2012. 

According to Horkachuck, as these 

milestones began to slip, SpaceX 

became fearful that NASA would 

terminate the company’s Space Act 

Agreement. Article 17B of the SAA 

did allow for “Termination for Failure 

to Perform,” but did not specify 

the consequences in the case of 

schedule delays.246 However, C3PO 

determined that as long as SpaceX 

was making technical progress and 

had a sound plan to continue in the 

face of delays, there was no need to 

end the partnership. 

Both SpaceX and NASA knew at the 

time the Space Act Agreements were 

signed that the company’s schedule 

was aggressive and pushed the time 

limits of what it was possible to achieve 

in rocket science. According to C3PO 

Manager Alan J. Lindenmoyer, “The 

average time to field a new launch 

vehicle is at least 27 months longer 

than initially projected.” Lindenmoyer 

observed “that’s almost exactly the 

delay that SpaceX experienced from 

the predicted original launch date of 

the first demonstration flight to the 

actual.”247 Therefore, NASA expected 

these slips from the beginning.

Augmentation Milestones

Partially as a result of these delays, 

and to increase mission safety 

and assurance, in fiscal year 2011 

Congress appropriated an additional 

$300 million to the Commercial Crew 

& Cargo Program Office, allowing 

$118 million in supplementary 

funds to be given to each of the 

commercial partners. 

Eighteen milestones were added to the 

SpaceX Space Act Agreement, which 

concentrated on seven main tasks 

specifically targeted to risk reduction: 

a pressurized cargo environment 

modal test; Light Detection and 

Ranging (LIDAR) sensors testing; solar 

array deployment tests; a spacecraft 

thermal vacuum system test; 

infrastructure enhancements (launch, 

test and production sites); acoustic 

and electromagnetic interference 

(EMI) tests; and enhanced powered 

cargo accommodations.248

According to Shotwell, several of 

these, such as the thermal vacuum 

and EMI testing, were tests that 

SpaceX had proposed as part of the 

original agreement but were removed 

after negotiations because cost 

exceeded the available NASA funds 

under the original COTS $500 million 

budget allocation.249

Flexibility

As with any rocket development 

program, unforeseen issues and 

deviations from original projections 

were bound to occur. Some of 

these changes were suggested by 

NASA, based on its experience and 

lessons learned from past programs, 

while others SpaceX proposed in 

order to achieve greater efficiency 

and accelerate development. 

Regardless of which party proposed 

the changes, both partners were 

willing to work towards for the best 

possible solution. 

For example, after the development 

of Falcon 1, SpaceX originally planned 

the Falcon 5 as an intermediate step to 

a launch vehicle with more capability. 

However, as a result of NASA’s ISS 

cargo needs, SpaceX decided to 

pursue the Falcon 9, with nine Merlin 

engines.250 In addition to hardware, 

NASA also influenced some of the 

company’s processes and procedures. 

Horkachuck influenced SpaceX team 

members to place greater emphasis 

on building integrated schedules as 

Prior to its inaugural launch, the Falcon 9 rocket undergoes its final integration in the 

hangar at SpaceX’s Cape Canaveral launch site in Florida. Components include: Dragon 

spacecraft qualification unit (left), second stage with Merlin vacuum engine (center), 

first stage with nine Merlin 1C engines (right). 

Credit: SpaceX 
56 CHAPTER 5 – COMMERCIAL PARTNERS

a critical project management tool.251

Similarly, through its partnership 

with NASA, SpaceX began to put 

into place a more rigid and thorough 

documentation and configuration 

management process.

Horkachuck strongly encouraged 

SpaceX to develop its own 

communications system with ISS, 

instead of relying on the existing 

Japan Aerospace Exploration Agency 

system. Horkachuck observed that 

the SpaceX operating style was not 

compatible with the methodical way 

of business that he noted was typical 

of Japanese companies. The resulting 

COTS UHF Communications Unit 

(CUCU) system gave SpaceX 

control of its own development and 

schedule, and allowed it to learn 

more about how to build and verify 

hardware to the standards and 

requirements of ISS. This included 

an introduction to the Safety Review 

Panel process before the first full 

demonstration mission.252

Based on his experiences with past 

programs, Horkachuck was also able 

to intercede when SpaceX moved 

to its new facility in Hawthorne. He 

noticed issues during the production 

of the first few rockets and spacecraft 

and “kind of forced some of [the 

NASA] money to be spent on fixing 

problems” in some of those areas.253

NASA also helped with an additional 

friction stir welder, and some other 

production capabilities that would 

make a significant difference in 

manufacturing processes.

Another specific area of influence 

was additional parachute drop 

tests, in this particular case applying 

some lessons learned from delays 

in NASA’s Orion Crew Exploration 

Vehicle Program. Resources and 

lessons learned from the Space 

Shuttle Program were also applied, 

as SpaceX utilized the NASA Shuttle 

launch debris radar systems to study 

the ascent phase of the Falcon 9.254

SpaceX was also able to take 

advantage of two Space Shuttle flights 

to test its rendezvous and proximity 

operations systems. In July 2009, 

STS-127 launched with a DragonEye 

Detailed Test Objective (DTO) box on 

Endeavour’s Space Station docking 

system. As the Shuttle approached the 

ISS, the DTO tested the company’s 

flash LIDAR sensor. As opposed to 

a traditional scanning LIDAR, the 

system works by sending a single 

laser pulse to a target (as opposed to 

thousands of multiple pulses required 

by a scanning LIDAR system), and 

measuring the time it takes for the 

signal to bounce back. A similar test of 

the Dragon LIDAR system took place 

two years later on STS-133, the final 

flight of Space Shuttle Discovery.

255

According to Warren P. Ruemmele, 

NASA Assistant Project Executive 

for SpaceX, these tests “allowed 

SpaceX to perform the best possible 

in-space test of the ... LIDAR they 

would eventually use” on the final 

demonstration mission to Station.256

NASA influences did not mean 

SpaceX did not push back with its 

own ideas of how to facilitate vehicle 

development. Even in the matter of 

documentation, which employees 

acknowledged as important, SpaceX 

more often relied on electronic and 

interactive procedures rather than 

hard copies.257

One of the major changes made as 

time progressed was the combination 

of the C2 and C3 milestone missions. 

As C3 was essentially a continuation 

of the C2 mission, in 2010 SpaceX 

proposed to NASA that instead of 

conducting the demonstrations as 

two separate missions and building 

two separate spacecraft, that after the 

C2 objectives were completed NASA 

would allow SpaceX to complete the 

C3 objectives (of ISS grapple and 

berthing) on the same mission. 

NASA initially hesitated, viewing the 

proposal as an attempt to eliminate 

cost while taking on an unacceptable 

amount of risk, but eventually 

acquiesced—with the provision 

that Dragon remain in space a few 

additional days and perform some 

system checkouts to allow for some 

of the planned C2 mission time and 

objectives. Negotiations lasted several 

months, but in the summer of 2011 

the Associate Administrator for the 

Human Exploration and Operations 

Directorate, William H. “Bill” 

Gerstenmaier, approved the change to 

NASA C3PO team members toured the 

company’s launch site before the first 

SpaceX demonstration mission to the ISS 

in May 2012. Attending were (left to right): 

Andrea Riley, NASA Headquarters Assistant 

Program Executive; Todd Hegemier, C3PO 

Financial Team; Lisa Price, C3PO Financial 

Team; Mark Timm, NASA Headquarters 

Program Executive; Alan Lindenmoyer, 

C3PO Manager; Alan Marty, C3PO Business 

Advisor; Phil McAlister, NASA’s Director 

of Commercial Spaceflight Development; 

Dennis Stone, C3PO Integration Manager; 

and Allison Zuniga, NASA Headquarters 

Strategic Planning.

Credit: C3PO team
CHAPTER 5 – COMMERCIAL PARTNERS 57

the company’s Space Act Agreement. 

A single C2+ mission allowed SpaceX 

to complete both the C2 and C3 

milestone objectives on a single flight 

(but with the understanding that the 

C3 mission could still be flown as a 

separate mission if SpaceX failed to 

achieve all the C2 objectives during 

the first attempt).258

This amendment to the SAA 

milestones demonstrated NASA’s 

commitment to work with partners 

and negotiate, as opposed to 

imposing its will, traditions, and 

procedures on the companies, and 

proving that the COTS team was truly 

open to suggestions on how to make 

this new way of doing business work. 

Partners were not only welcomed 

but encouraged to push back on any 

requirements for requirements’ sake, 

resulting in what all parties agreed 

was a more successful and costeffective mission overall.259

Not Always a Winner

It should be mentioned that, despite 

SpaceX’s inarguable success, there 

were some NASA awards SpaceX 

did not win. After the SAA with RpK 

was terminated in October 2007, 

SpaceX was one of 13 companies to 

submit a proposal for the remaining 

$170 million of available COTS funds. 

However, SpaceX was eliminated in 

the first round of selection.260

SpaceX had a following opportunity 

to receive additional funding from 

the Commercial Crew & Cargo 

Program when the Commercial Crew 

Development (CCDev) competition 

was announced in August 2009 to 

begin work on the capabilities that 

would be necessary for industry to 

ferry people to and from low-Earth 

orbit. The 2009 American Recovery 

and Reinvestment Act allocated 

$400 million for space explorationrelated activities, of which $50 million 

was allocated to the CCDev project 

administered by C3PO. 

SpaceX made it through the first 

round of eliminations, but when the 

Participant Evaluation Panel made 

its final decision in December 2009 

it deemed that the company 

asked too high a contribution from 

NASA, and the proposal was not 

a good use of designated stimulus 

funds for technology that would be 

developed in return.261

C2+ Demonstration 

Mission 

In the end, NASA’s partnership with 

SpaceX succeeded in producing U.S. 

cargo capability to low-Earth orbit. 

After months of training with ISS 

astronauts and a few launch delays to 

ensure issues such as flight software 

testing had been resolved, SpaceX 

launched the Dragon C2+ spacecraft 

from Cape Canaveral, Florida in the 

early hours of the morning on 22 May 

2012.262 The first three days of the 

mission were spent demonstrating 

the objectives of the original C2 

mission, establishing communications 

with the ISS using the COTS UHF 

Communications Unit (CUCU) and 

conducting an ISS flyby.

Then, on May 25, 2012, the NASA 

Mission Control team in Houston 

granted Dragon permission to begin 

its approach toward the ISS. In 

a tense moment just prior to the 

final approach for grapple, Dragon 

experienced an issue with its thermal 

imagers caused by a reflection from 

the Japanese Experiment Module, 

resulting in a discrepancy between 

the LIDAR and thermal imagers. 

Forging ahead without consistent 

readings would have triggered a 

During the early morning hours of May 

22, 2012, the SpaceX Falcon 9 launched 

from Cape Canaveral Air Force Station, 

Florida (top photo), to begin the C2+ 

demonstration mission, the final phase of 

its COTS Space Act Agreement. On board 

was the Dragon spacecraft with more than 

a thousand pounds of cargo to deliver to 

the ISS. Following a series of tests of its 

maneuverability and abort systems, the 

Dragon was grappled (bottom photo) and 

berthed to the International Space Station 

by the crew members of ISS Expedition 31. 

After 5 days, 16 hours, and 5 minutes, the 

Dragon was released.

Credit: NASA/Alan Ault
58 CHAPTER 5 – COMMERCIAL PARTNERS

NASA abort, so SpaceX mission 

control in Hawthorne ordered a retreat 

and quickly engineered a solution. 

Software programmers narrowed the 

LIDAR’s field of view to eliminate the 

reflection, then uploaded the software 

change to Dragon, allowing the 

spacecraft to continue its approach 

and NASA to give the final “go” 

command for capture. 

ISS Expedition 31 astronaut Donald 

R. Pettit grappled the spacecraft at 

13:56 GMT, followed by a successful 

ISS berthing. Shotwell, who called the 

event “amazing” and “extraordinary,” 

celebrated with the close to 1,500 

employees who had waited outside 

the company’s mission control room 

at SpaceX headquarters during the 

early morning hours.263 After delivering 

1,014 pounds of cargo, Dragon 

unberthed from the ISS and splashed 

down in the Pacific Ocean on May 31, 

2012, signaling the completion of its 

Space Act Agreement with NASA. All 

that remained were formal reviews to 

verify that all the mission objectives 

had been achieved.264

After the successful mission, SpaceX 

began the transition from development 

of the Dragon spacecraft and Falcon 

9 launch vehicle to manufacturing 

and operations for contracted 

flights. Development continued on 

projects such as a manned Dragon 

spacecraft for the NASA Commercial 

Crew Program, and bigger and more 

powerful rockets. These launch 

vehicles—including the Falcon 9 

version 1.1, Falcon Heavy, and 

Grasshopper vertical landing vehicle—

stemmed from the lineage of the 

original Falcon 1 launched on a remote 

island in the middle of the Pacific. 

That same heritage allowed SpaceX 

to provide needed cargo to the ISS, 

eventually graduating from less-critical 

supplies to scientific experiments 

carrying live animal specimens.265

Over the six-year course of the 

company’s Space Act Agreement, 

NASA contributed both financial 

and technical assistance to the 

development of the SpaceX Falcon 

launch vehicle and Dragon 

spacecraft. However, as both 

C3PO Manager Alan Lindenmoyer 

and SpaceX President Gwynne 

Shotwell emphasized, the company’s 

financial contribution exceeded 

the government’s for the work 

performed under the COTS 

program. While the COTS office 

distributed a total of $396 million 

to the company (the original $278 

million agreement plus $118 million 

in augmentation funds), SpaceX 

financed approximately $454 million, 

over half of the total amount, to make 

the program a success.266

NASA’s technical advice is less 

quantifiable, but the following 

statement by Tim Buzza gives 

an indication of how closely the 

government and private partner 

worked together: “There’s no doubt 

Employees outside the mission control room at SpaceX headquarters in Hawthorne, 

California, waited while the Dragon spacecraft successfully berthed with the 

International Space Station on May 25, 2012. Over its six-year COTS partnership with 

NASA, the company that was founded in 2002 transitioned from a small startup to 

the first private company to deliver cargo to the ISS.

On May 31, 2012, the capsule-shaped 

Dragon splashed down in the Pacific 

Ocean west of Baja California, Mexico, 

less than one mile from the center of the 

targeted landing zone. SpaceX recovery 

teams retrieved the vehicle carrying cargo 

returned from the ISS.

Credit: SpaceX

Credit: SpaceX/Michael Altenhofen
CHAPTER 5 – COMMERCIAL PARTNERS 59

that through years of working 

together, fingerprints of meetings 

and discussions with NASA have 

ended up on the rocket.”267

SpaceX has transitioned from a small 

startup company to an increasingly 

major contender in the aerospace 

world in large part thanks to NASA’s 

partnership. After the C2+ mission, 

Elon Musk acknowledged what a 

“tremendous honor” it had been to 

work with NASA, saying, “We could 

not have started SpaceX, nor could 

we have reached this point without 

the help of NASA.”268

With the final demonstration mission, 

SpaceX sealed its place in history 

as the first ever private company 

to deliver cargo to the International 

Space Station. 

Rocketplane 

Kistler

Rocketplane Kistler (RpK), the second 

commercial partner selected in the 

Round 1 COTS competition, found 

itself unable to execute the terms 

of its Space Act Agreement due to 

the formidable challenge of securing 

the financing to fund a successful 

aerospace venture.

K-1 Vehicle

The Kistler Aerospace Corp. was 

founded in 1993, one of several 

aerospace startup companies 

established after the end of the Cold 

War to lower the cost of launching 

small-sized satellites into low-Earth 

orbit.269 In 1995, Dr. George E. 

Mueller, Director of NASA’s Apollo 

Program and an early champion 

of the Space Shuttle, joined Kistler 

as the company’s CEO, and the 

company began development of the 

Kistler K-1 vehicle. 

The design for the K-1 had its roots in 

the early concepts for a fully-reusable 

space transportation system Mueller 

had envisioned in the late 1960s. 

However, due to budget cuts and 

political maneuvering in the 1970s, the 

Space Shuttle that NASA eventually 

developed was only partially reusable; 

the orbiter and solid rocket boosters 

were recovered and refurbished for 

reuse, but the external tank was 

discarded after every mission. 

The K-1 promised to convert the 

dream of a fully reusable vehicle to 

reality, as both stages of the vehicle 

would glide back to Earth using a 

system of parachutes and air bags. 

Operating in two stages, the K-1’s first 

stage Launch Assisted Platform (LAP) 

would carry the second stage 

Orbital Vehicle (OV) to its trajectory 

in low-Earth orbit. The liquid 

oxygen/kerosene-fueled LAP would 

be powered by three Aerojet AJ-26 

engines (refurbished Russian 

NK-33s)—the same engines used by 

Orbital in its Antares rocket.270

Kistler planned to launch the 113-foot 

tall K-1 vehicle from the Woomera Test 

Range in a sparsely populated area of 

South Australia.271 After delivering its 

cargo to orbit, the LAP would return 

to Earth for rapid turnaround at the 

company’s horizontal processing 

facilities. The company’s 2006 COTS 

proposal outlined how the OV could be 

configured to transport about 50,050 

pounds of cargo per year or up to five 

crew members for Capability D.272

In addition to Mueller, Kistler boasted 

an impressive executive team, 

with decades of combined NASA 

Rocketplane Kistler planned to use the K-1 

launch vehicle, in development since 1995, 

in its partnership with NASA. The fully 

reusable vehicle had two stages with the 

second stage, the Orbital Vehicle (above), 

designed to transport cargo or crew. The 

company was unable to meet its financial 

agreements, resulting in a termination of 

their COTS Space Act Agreement.

Credit: KAS

On June 13, 2012, NASA Administrator 

Charlie Bolden (left) and SpaceX CEO 

and Chief Designer Elon Musk inspected 

the Dragon spacecraft that returned to 

Earth and had been moved to the SpaceX 

facility in Texas. After its 9-day test flight, 

the vehicle returned with nearly 1,400 

pounds of equipment and experiments 

from the ISS.

Credit: NASA/Bill Ingalls
60 CHAPTER 5 – COMMERCIAL PARTNERS

experience in the Apollo, Shuttle, and 

Space Station programs. Randolph H. 

“Randy” Brinkley, Kistler’s President, 

served as the NASA Program Manager 

of the International Space Station from 

1994 to 1999. Brinkley explained that 

one of his primary reasons for joining 

the Kistler venture was to sustain the 

ISS as a laboratory: “I had such strong 

feelings about being able to make 

the Space Station—the science 

platform that we spent $100 billion 

on—to enable it. I saw that the K-1 

had that capability.”273

Joseph W. “Joe” Cuzzupoli served as 

Kistler’s Vice President and K-1 launch 

vehicle Deputy Program Manager, 

bringing to the table his years of 

experience as Rockwell’s Assistant 

Manager of the Apollo Program and 

Vice President and Program Manager 

of the Space Shuttle Orbiter.274 COTS 

Project Executive Bruce Manners later 

reflected that Cuzzupoli “had so much 

experience, so many guidelines,” that 

“it was just a real career highlight to 

have the opportunity to meet and 

work with somebody of his caliber 

and his background.”275 Rounding out 

the team, Richard H. “Dick” Kohrs, 

another former NASA manager with 

decades of experience in the Apollo, 

Space Shuttle, and Space Station 

programs, was Kistler’s Chief Engineer. 

The Kistler Aerospace Corp. 

originally aimed to develop the K-1 

independently of any government 

funding. In 1997, Kistler won a $100 

million-plus contract to deliver 10 

satellite launches for Space Systems/

Loral, “but the deal hinge[d] on 

Kistler’s ability to finance and build its 

planned K-1 rocket.”276 Years later, 

the company’s ability to attract and 

retain funding would linger as an issue 

for what was otherwise an advanced 

technical concept.

Space Launch Initiative

At the turn of the 21st century, 

Kistler Aerospace increased its 

involvement in government programs. 

In May 2001, NASA awarded Kistler 

Aerospace one of 22 Space Launch 

Initiative contracts, designated 

for small businesses, to study the 

feasibility of commercial cargo 

transportation to the International 

Space Station. Kistler would only 

receive $10 million of its $135 million 

award until the K-1 vehicle flew 

a successful mission.277

Only two years later, on 15 July 2003 

Kistler filed for Chapter 11 bankruptcy 

protection, unable to pay over 

$600 million in debt to the company’s 

creditors. Kistler turned to the New 

York hedge fund company Bay 

Harbour Management LLC 

to help the company out of debt. 

Bay Harbour became the majority 

owner of Kistler Aerospace, and was 

tasked with the job of raising the 

$450 million Kistler estimated it would 

need to complete the K-1 vehicle. 

At the time, Kistler predicted it could 

complete development of the K-1 

within 13 to 18 months of receiving 

sufficient financing.278

Although NASA had cancelled the 

Space Launch Initiative program 

in 2002, in February 2004, NASA 

announced its intent to reactivate 

the previous award and offer Kistler 

a sole-source contract for pre- and 

post-flight data from the K-1 vehicle. 

NASA justified the award of Kistler’s 

no-bid award on the grounds that no 

other company had a vehicle as near 

completion as the K-1. 

By 2004, Kistler had completed 

75 percent of the vehicle’s hardware, 

85 percent of the design, and 100 

percent of the software for guidance, 

navigation, and control. Presaging 

NASA’s future use of funded Space 

Act Agreements, NASA would 

provide payments to Kistler only 

after data was delivered, and any 

potential contracted ISS missions 

would be subject to a separate 

follow-on procurement.279

However, a recent startup founded in 

2002, SpaceX, protested the award at 

the Government Accountability Office, 

claiming that the contract should have 

been subject to open competition 

as per standard Federal Acquisition 

Walter Kistler, left, cofounder of Kistler Aerospace and K-1 inventor, joined with members 

of the COTS Participant Evaluation Panel for a presentation during the NASA due 

diligence visit with Rocketplane Kistler as part of the 2006 COTS competition. 

Credit: C3PO team
CHAPTER 5 – COMMERCIAL PARTNERS 61

Regulation procedures.280 SpaceX 

won the protest, and after losing their 

award Kistler again failed to raise the 

money it needed to complete the 

K-1 vehicle. The company was “put 

on the shelf” by Bay Harbour, still the 

majority owner.281

COTS

In 2005, as interest in NASA’s new 

way of doing business began to 

circulate among commercial space 

transportation companies, George 

D. French, the owner of Pioneer 

Rocketplane, a suborbital space 

tourism venture based in Oklahoma, 

attended the COTS Industry Day in 

Houston. French reported that he met 

investment banker Petter Kleppan 

at the bar of a local hotel, who 

suggested that French buy the failing 

Kistler Aerospace Corp.282

In February 2006, French announced 

the purchase of Kistler Aerospace, 

giving the new Rocketplane Kistler 

Inc. about six weeks to pull together a 

team and prepare a COTS proposal for 

the March 3, 2006 deadline.283 As one 

of the company’s two speakers during 

the final selection briefings at NASA 

Headquarters, Mueller presented 

a strong case for the advanced 

state of the K-1’s technological 

development, and on August 18, 

2006, NASA selected RpK as one 

of two commercial partners in the 

first round of the COTS competition, 

though noting the weak point of the 

company’s financial plan.284

Milestones

Despite the company’s impressive 

technical credentials, Rocketplane 

Kistler struggled to achieve the 

financial objectives defined in the 

company’s Space Act Agreement 

with NASA. 

Technical Milestones 

Rocketplane Kistler easily achieved 

its first two technical milestones, the 

Program Implementation Plan and 

System Requirements Review.285

Both were completed on schedule, 

in September 2006 and February 

2007 respectively. The RpK team 

was technically proficient, well on the 

way to achieving their next technical 

milestone, the Pressurized Cargo 

Module Critical Design Review, 

except for the issue of financing. 

Financial Milestones

The financial milestones presented 

more of a struggle for RpK. The 

company required 30 additional days 

to complete its first round of financing, 

$40 million originally due by the end 

of September 2006. Rocketplane 

Kistler hired investment bank Jeffries 

Quarterdeck LLC to help it raise 

the capital needed to complete 

development of the K-1 vehicle. 

Jeffries Quarterdeck convinced RpK 

that all its funds should be secured 

in one large lump sum, and in late 

February 2007, NASA amended 

the RpK Space Act Agreement to 

accommodate this new plan. The 

original Milestone 4 ($120 million in 

financing due February 2007) and 

Milestone 9 ($256 million in financing 

due February 2008) were combined. 

The consolidated Milestone 4 called 

for $500 million of financing to be 

secured by May 2007.286

Jeffries helped RpK prepare a 

Confidential Information Memorandum 

about the company and its business 

plan to show to interested lenders. 

RpK went to New York City in April 

2007 to find potential investors, 

particularly a lead investor that could 

provide over $100 million of funds 

and help monitor RpK’s progress for 

the other possible financiers. One of 

RpK’s investors from the first round 

of financing, MacDonald, Dettwiler, 

and Associates (MDA), brought in the 

Ontario Teachers’ Pension Plan (OTPP) 

as a lead investor willing to contribute 

over $200 million of financing. Having 

reached the significant landmark of 

$300 million raised (the sum of the 

existing $100 million plus $200 million 

from OTPP), RpK continued its search 

to reach the full $500 million.287

Throughout the process, the COTS 

team supported RpK’s endeavors. 

Venture Capitalist Alan Marty and 

Dennis A. Stone met with the RpK 

board at the company’s facilities 

in Wisconsin and attended RpK 

meetings on Wall Street.288 Project 

Executive Bruce A. Manners 

and Program Manager Alan J. 

Lindenmoyer also helped review RpK 

presentations and accompanied 

RpK during their July 2007 “Investor 

Day” in New York. The NASA 

representatives helped demonstrate 

NASA’s commitment to the COTS 

program, explaining to investors the 

Agency’s new way of doing business. 

C3PO Manager Alan Lindenmoyer 

approved payments to Rocketplane Kistler 

upon completion of technical milestones. 

Although technically proficient, the 

company failed to meet its financial 

commitments under the COTS Space Act 

Agreement with NASA. 

Credit: C3PO team
62 CHAPTER 5 – COMMERCIAL PARTNERS

Marty helped explain the investment 

process and advise C3PO on which 

investors might be more willing to 

commit to a financial contribution. 

Attorney Jonathan A. Arena was 

also present to ensure NASA did not 

cross any legal or policy boundaries 

by issuing a particular endorsement 

of the company, and clarifying that 

participation in the COTS program 

was not a guarantee of a follow-on 

service contract.289

Both Marty and Arena used their 

expertise to serve as liaisons between 

financial, legal, and engineering groups 

in the NASA, commercial, and private 

investment communities. Arena later 

described how “one of my informal 

roles throughout that COTS process 

was being a translator, explaining 

some of the legal aspects to the 

engineers, some of the business 

aspects to the engineers, and trying to 

be a go-between between folks who 

have vastly different backgrounds.”290

Termination

Despite these efforts, by May 2007 

Rocketplane Kistler still had not 

managed to attract all $500 million 

needed to complete the revised 

Milestone 4 of the company’s Space 

Act Agreement. NASA agreed to 

an extension until July 2007, noting 

that the company had identified a 

lead investor. However, by July RpK 

had raised only $300 million, $200 

million short of the amount needed 

for completion of the milestone that 

had originally been due two months 

prior. Without the financing needed to 

continue development, RpK began to 

slip on its technical progress. 

In August 2007, Manners 

recommended that NASA issue notice 

of termination, giving Rocketplane 

Kistler 30 more days to secure 

financing to allow the company one 

final chance to meet its second 

financial milestone.291 NASA decided 

to end RpK’s association with the 

space agency only after a series of 

intense discussions with RpK and 

the COTS team’s legal and financial 

advisors, ultimately determining that 

RpK did not have a viable chance of 

raising the required funding.292

Associate Administrator for the 

Exploration Systems Mission 

Directorate Scott J. “Doc” Horowitz 

explained, “I basically used a threestrike policy. They didn’t meet their 

milestones. We tried, now we’ll go 

on.”293 Horowitz issued NASA’s 30-

day notice of termination to RpK on 

September 7, 2007, and on October 

18, 2007, the company’s Space Act 

Agreement was formally terminated. 

Only four days after the official 

termination, NASA issued the COTS 

Round 2 Announcement to select a 

new commercial partner.

Throughout the termination 

process, NASA remained in close 

communication with Rocketplane 

Kistler. Correspondence between 

Lindenmoyer and Brinkley reveals 

how RpK tried to argue the 

company’s case. From the company’s 

perspective, NASA’s failure to 

guarantee the follow-on Commercial 

Resupply Services contract during 

RpK’s search for funding was the 

primary reason for the company’s 

inability to find investors willing to 

commit money to the project. 

Without a defined NASA commitment 

to buy the company’s low-Earth 

orbit transportation services, 

financiers had no guarantee of a 

return on their investment. Investors’ 

hesitance could also be explained 

by the long development time and 

high risk inherent in space ventures; 

with the dozens of proposals 

investors regularly sift through, as 

exciting as the prospect of space 

travel was, investors’ focus was 

ultimately on the bottom line.294

According to Brinkley, Rocketplane 

Kistler was also unfortunate in the 

timing of its appeals to investors. 

To begin with, in April 2007 NASA 

announced a $719 million extension 

of the space agency’s contract 

with the Russian Federal Space 

Agency (Roscosmos) to provide 

crew and cargo services through 

2011, signaling to investors that 

NASA would not be relying on U.S. 

commercial resupply services in 

the foreseeable future. Then, when 

the Space Operations Mission 

Directorate at NASA Headquarters in 

Washington, DC, issued a Request 

for Information in the summer of 

2007 to gather information to help 

plan for an eventual services contract, 

the ISS Program Office indicated 

it planned to commit to only three 

servicing missions—resulting in 

a significantly smaller figure than 

the billion-dollar-plus Commercial 

Resupply Services (CRS) contracts 

that were actually awarded in 

December 2008, and not one large 

enough to convince investors.295

Next, after the July 4 Independence 

Day holiday, RpK encountered 

difficulty contacting venture capitalists 

on Wall Street, many of whom took 

summer vacations and were not fully 

available until September.296 RpK’s 

search for investors also coincided 

with the U.S. subprime mortgage 

crisis that began its deleterious effect 

on U.S. stock markets in the summer 

of 2007. Said French, “Never in my 

risk assessments did I put on my 

plate that the hedge funds...that 

were demanding a 15 percent return 

from us were investing in packaged 

home mortgage loans to the tune of 

billions of dollars.”297 After the markets 

collapsed, the company was unable 

to resume talks with investors.
CHAPTER 5 – COMMERCIAL PARTNERS 63

Finally, also at issue was the fact 

that two of Rocketplane Kistler’s 

primary investors, MDA and OTPP, 

were foreign-owned entities. Brinkley 

explained in his correspondence 

with Horowitz that “[OTPP’s] 

participation was limited, in part, by 

the fact that it is a Canadian fund 

and NASA’s view that a Canadian 

fund could not have a controlling 

position in RpK without violating the 

Commercial Space Act [of 1998].”298

In his letter, Brinkley went on to point 

out the irony of NASA’s position in 

this case, since the Agency was 

dependent on foreign vehicles for ISS 

resupply and crew transport. 

Epilogue

After the company’s termination, 

Brinkley attempted to convince 

officials at NASA Headquarters to 

retain some of the valuable hardware 

and intellectual property from the 

K-1 vehicle, as the company was no 

longer able to afford storage at the 

NASA Michoud Assembly Facility 

in New Orleans, Louisiana. Brinkley 

reported how he argued that there 

was “real value in keeping that work 

that had been done, and that it was 

a shame to just have that become 

scrap,” especially after NASA had 

invested so much government money 

in the K-1 development.299

Company owner George French was 

able to transport some hardware 

pieces to storage facilities in California 

and Green Bay, Wisconsin, though 

the majority were eventually scrapped. 

Regarding the intellectual property 

of the K-1 design, NASA still retains 

the right under the terms specified in 

the Space Act Agreement to use any 

information RpK submitted as part 

of any of the three milestone reviews 

the company completed. However, 

there have been no attempts at the 

space agency to exercise this right.300

Rocketplane Kistler did attempt a 

GAO protest of the Round 2 COTS 

competition, but was unsuccessful. 

Rocketplane Global, the parent 

company of Rocketplane Kistler, filed 

for Chapter 7 bankruptcy on June 

15, 2010 (along with its owner).301

In December 2011, the company’s 

assets were put up for auction, 

and purchased for $25,000 by the 

Wisconsin-based Space Assets LLC. 

The company, still steered by French, 

has managed to salvage what is left 

of the hardware—some tanks and 

rings—and intellectual property to 

develop a new business plan.302

Despite their termination, the 

engineers at Rocketplane Kistler 

still believed in the COTS approach 

to partnering with industry. Said 

Cuzzupoli, “I would say that the COTS 

program has been a very successful 

program, and that the whole concept 

of how this thing was going to be 

put together and housed and 

played out is a great idea. Cuzzupoli 

continued, “I think the NASA folks that 

are located at Johnson Space Center 

have done a tremendous job.”303

His colleague Brinkley added, “I’m 

really happy and pleased to see the 

success of SpaceX and the recent 

success of Orbital. At the end of the 

day, although I’m disappointed about 

Rocketplane Kistler and the K-1, 

that’s secondary to the fact that COTS 

has been successful.”304

NASA and Rocketplane Kistler (RpK) representatives discussed progress of the company’s milestones during a meeting held at the 

Michoud Assembly Facility, New Orleans, Louisiana. RpK used the facility to assemble and check out its K-1 Space Transportation 

System after entering into a reimbursable Space Act Agreement with the NASA Marshall Space Flight Center in Alabama. 

Credit: C3PO team
64 CHAPTER 5 – COMMERCIAL PARTNERS

Orbital 

Sciences 

Corp.

Based on the carefully established 

COTS strategy, in February 2008 the 

Commercial Crew & Cargo Program 

Office was able to resume plans for 

commercial low-Earth orbit delivery 

services with a new partner, Orbital 

Sciences Corp.

Company Founding 

and Early Years

David W. Thompson, Bruce W. 

Ferguson, and Scott L. Webster 

founded the Orbital Sciences Corp. 

in 1982, one of several aerospace 

companies established in the preChallenger accident atmosphere 

of optimism regarding the future of 

private space ventures. In the late 

1970s, Thompson, a former engineer 

at the NASA Marshall Space Flight 

Center, had decided to pursue a 

business degree based on his belief 

that a private company could develop 

new systems more efficiently and cost 

effectively than the government.

While a student at Harvard Business 

School, Thompson met Ferguson and 

Webster, two like-minded colleagues 

who also shared an interest in 

aerospace. In April 1981—the same 

month as the first Space Shuttle 

launch—the three participated on a 

team that studied materials research 

and manufacturing in low-Earth orbit 

for the school’s Creative Marketing 

Strategy course. The work was 

funded by the Program Development 

Group at Marshall, interested 

in potential commercial uses of 

Shuttle. After graduation, the former 

classmates stayed in contact, and on 

April 2, 1982, formally incorporated 

the Orbital Sciences Corp.305

Thompson described how there 

were almost “no precedents” in the 

commercial space transportation 

arena to look to for guidance, but two 

European initiatives founded in the 

late 1970s and early 1980s—Orbital 

Transport and Rockets, Inc. (OTRAG) 

and Arianespace—offered some 

proof it could be done.306 In the era 

when the Shuttle was expected to 

provide exclusive, frequent, lowcost access to space, Orbital’s initial 

business plan proposed to support 

NASA’s capabilities by developing 

the Centaur Orbital Transfer 

Vehicle (OTV) that could be used 

to ferry payloads from the Shuttle’s 

low-Earth orbit to the higher 

geosynchronous orbit required by 

many communications satellites.307

The company secured approximately 

$2 million from seed capital investors 

and venture capital sources in late 

1982 and early 1983. Orbital planned 

to raise “most of the capital to develop 

and build the OTV, permitting NASA 

to leverage its budget with private 

investment and freeing space agency 

funds for other programs.”308 Although 

in this instance Congress deemed the 

program important enough to allocate 

sufficient budget for NASA to run the 

initiative, the statement foreshadowed 

the work Orbital would complete 

under the COTS program a quarter of 

a century later. 

By mid-1983, Orbital began 

development of the Transfer Orbit 

Stage (TOS), a similar OTV concept 

designed to be a lower-cost 

alternative to the U.S. Air Force Inertial 

Upper Stage. However, the Challenger

disaster of January 1986 forced the 

company to dramatically rethink its 

business plan to complement Shuttle 

activities with privately-developed 

systems, especially after the policy 

reversal of launching commercial 

and military satellites on Shuttle. 

Several of Orbital’s TOS production 

contracts, close to completion, 

were delayed or cancelled. By 1988 

the company had shifted focus to 

a second product line of small and 

relatively inexpensive satellites, and 

the expendable rockets needed 

to launch them.309 As one industry 

observer phrased it, “the tragedy 

freed space enterprise from the need 

to move in lockstep” with NASA.310

Orbital based its new business plan 

on the company’s analysis that a 

vehicle built expressly for the launch 

of small satellites could capture 

Orbital Sciences Corp. began working 

with NASA and the U.S. government in 

the early 1980s and continued in the next 

decades to develop small satellites as well 

as the rockets to launch them. Included in 

NASA projects was the unpiloted X-34, a 

proposed low-cost reusable launch vehicle 

for space access. (Above) The first X-34 

captive carry flight occurred June 29, 1999, 

using Orbital’s Lockheed L-101 as the 

mothership, from the NASA Dryden Flight 

Research Center, Edwards., California. 

In March 2001, NASA announced it was 

discontinuing the X-34 program, but it 

served as a basis for further collaboration 

between NASA and the private entity.

Credit: NASA/Tom Tschida
CHAPTER 5 – COMMERCIAL PARTNERS 65

this “lightsat” market by providing 

an alternative for small satellite 

customers flying their payloads as 

secondary cargo on the Shuttle or 

large-class rockets.311 The resulting 

air-launched Pegasus rocket 

completed its first mission in 1990. 

Pegasus was launched from a 

B-52 aircraft, a plane featured in 

the famous Cold War movie Dr. 

Strangelove: Or, How I Learned to 

Stop Worrying and Love the Bomb. 

Pegasus’ primary architect, Antonio 

L. Elias, Orbital Vice President and 

Chief Technical Officer, later reflected 

on how Dr. Strangelove became 

the official film of the development 

team. Elias even posed for a photo 

on Pegasus imitating Major Kong’s 

rodeo-style descent on the H-bomb 

in the film. Since then Pegasus has 

become a mainstay of the company’s 

business, having conducted 45 

missions as of November 2013, while 

also spawning numerous derivative 

products for space launch and missile 

defense applications.312

Throughout the 1990s, Orbital 

continued to expand its product 

line to include a variety of small 

satellites and launch vehicles for 

communications, scientific, and 

defense payloads. These included 

the Taurus and Minotaur rockets, 

as well as the ORBCOMM satellite 

communications network. Over the 

first two decades of operations, 

Orbital established a reputation as 

a dependable company offering 

NASA, military, and private industry 

customers reliable and cost-effective 

access to space.

NASA Initiatives

NASA has been listed among Orbital’s 

customers from the very beginning. 

According to Thompson, throughout 

the company’s history NASA business 

has accounted for anywhere from 

20 to 80 percent of Orbital’s total 

revenue. As of 2013, Thompson 

reported the figure was about 40 

percent, including COTS and CRS. 

The space agency also continues to 

purchase Orbital’s launch services for 

its small scientific payloads. 

Always looking for new potential 

business, Vice President of Human 

Spaceflight Systems Richard T. 

“Bob” Richards described how, 

in the early 2000s, the company 

anticipated a need for contingency 

cargo capability to ISS and 

developed the Orb Express concept 

to address potential emergency 

deliveries on an as-needed basis. 

However, NASA elected not to pursue 

the concept because at the time 

Station’s needs could be fulfilled by 

Shuttle operations.313

Orbital also participated in NASA’s 

Space Launch Initiative and Alternate 

Access to Station studies, and the 

company developed a Demonstration 

of Autonomous Rendezvous 

Technology (DART) to prove on-orbit 

capabilities.314 Although none of these 

early initiatives reached fruition, they 

showed Orbital had already developed 

a number of ideas for cargo resupply 

by the time the COTS program was 

announced in late 2005. 

Lori Garver, NASA Deputy Administrator, and (left) David Thompson, CEO and President 

of Orbital Sciences Corporation, shared a conversation while in the Range Control 

Center at the NASA Wallops Flight Facility in Virginia prior to the first test flight of the 

Antares rocket. Also pictured are (middle) Antonio Elias, Orbital Sciences Corp. Executive 

Vice President and Chief Technical Officer, and Dale Nash, Executive Director, Virginia 

Commercial Space Flight Authority. 

Credit: NASA/Bill Ingalls
66 CHAPTER 5 – COMMERCIAL PARTNERS

COTS

Orbital was among the 21 companies 

that submitted proposals in response 

to the Round 1 COTS Announcement 

issued January 18, 2006. The 

company proposed Capabilities 

A and B, unpressurized and 

pressurized cargo delivery, but was 

not selected into the group of six 

finalists, most of which had proposed 

all four capabilities. (SpaceDev, Inc. 

was the one exception, proposing 

only Capabilities C and D, 

pressurized cargo return and the 

possible crew option.)

Thompson, company President 

and CEO, explained the decision 

to pursue only the first two COTS 

capabilities: “We concluded that 

returning intact cargo was not likely 

to be a large part of the overall traffic 

model, and the incremental cost of 

implementing that was high enough 

that we probably wouldn’t see a 

good return on that incremental 

investment.”315 With limited potential 

returns on the return cargo capability, 

crew posed an even bigger financial 

risk, though an option Thompson 

indicated the company would be 

open to pursuing in the future.

Many of the engineers who worked 

at Orbital believed their proposal 

was not selected because it was 

overly reliant on foreign components, 

particularly the use of a modified 

Soyuz spacecraft for ISS cargo 

delivery.316 After Rocketplane 

Kistler’s Space Act Agreement was 

terminated in October 2007, and 

NASA issued the Round 2 COTS 

Announcement on October 22, 

2007, Orbital saw another chance 

to be awarded a funded Space Act 

Agreement for the development of 

low-Earth orbit capabilities. 

Recognizing that COTS aimed to 

develop U.S.-based capabilities, the 

company changed its approach for 

the Round 2 competition. Orbital 

deleted the Soyuz-derived spacecraft 

from its proposal, but included other 

international elements. The company 

was selected, largely due to its stable 

finances, and signed its funded 

Space Act Agreement with NASA on 

February 19, 2008. 

Vehicles

Prior to the Round 1 COTS 

competition in 2006, Orbital had 

conducted some internal studies 

regarding the development of a new 

medium-class launch vehicle. The 

U.S. Air Force indicated it would no 

longer be purchasing services on 

the Delta II rocket built by Boeing 

Integrated Defense Systems, so 

Orbital conceived the Taurus II, 

based on the company’s existing 

Taurus small launch vehicle, as a 

possible replacement.317

Taurus II was kept in the study 

phase until the spring of 2007, 

when Orbital felt more confident 

about potential markets and began 

development work using internal 

funds. A ground-launched variant 

of the Pegasus rocket, the smallclass 104-foot Taurus XL weighed 

170,000 pounds and was capable 

of launching satellites weighing up 

to 3,500 pounds.318 By contrast, 

the Taurus II (by then renamed 

Antares) that Orbital successfully 

launched on April 21, 2013, was 

131 feet tall, weighed 530,000 

pounds, and was capable of lifting 

over 11,000 pounds to low-Earth 

orbit.319 By the time development 

was complete, the vehicle had been 

modified enough that the company 

felt it needed a new name to signify 

the substantially different vehicle that 

had been produced.

Not only was this medium-class 

vehicle appreciably larger than 

Orbital’s previous programs, it also 

entailed significant design changes. 

Orbital Sciences Corp. developed the Antares launch vehicle as part of its COTS 

Space Act Agreement. Originally named the Taurus II, the 131-foot rocket is capable of 

lifting over 11,000 pounds to low-Earth orbit. This medium-class vehicle reflected the 

company’s philosophy of relying on proven hardware components. 

Credit: NASA/Brea Reeves
CHAPTER 5 – COMMERCIAL PARTNERS 67

Whereas the company’s other rockets 

utilized all solid propulsion stages, 

Antares was the first Orbital vehicle to 

use a liquid first stage. Orbital utilized 

a liquid first stage developed by the 

Ukrainian design company Yuzhnoye, 

manufactured by its sister company 

Yuzhmash. Other examples further 

demonstrate how Orbital’s design 

approach leveraged proven hardware 

to the greatest extent possible. 

Orbital purchased Aerojet AJ-26 

engines to power the first stage of 

Antares. These units were in fact 

refurbished NK-33s that Aerojet had 

in turn purchased from Kuznetsov, the 

Russian company that manufactured 

them in the 1960s and 1970s for the 

failed N-1 Soviet moon rocket. (These 

were the same engines Rocketplane 

Kistler had planned to use for its K-1 

system.) The second stage of Antares 

utilized a solid rocket motor from 

Alliant Techsystems, Inc. (ATK) with 

Orbital avionics and integration.320

For the cargo delivery vehicle that 

Taurus II/Antares would launch into 

low-Earth orbit, Elias proposed a 

flexible concept capable of supporting 

multiple COTS capabilities. The 

Service Module “hockey puck” unit 

contained all the necessary propulsion, 

power, avionics, communications, 

and other operational systems.321 This 

could then be attached to either an 

Unpressurized Cargo Module (UPCM) 

or Pressurized Cargo Module (PCM), 

depending on NASA’s cargo needs. 

Orbital turned to an Italian company, 

Thales Alenia Space, to build the 

PCMs that would berth to Station 

with the aid of the robotic Canadarm. 

Thales Alenia was able to rely on its 

experience building ISS Multi-Purpose 

Logistics Modules, as well as the 

European nodes of the Station, to 

build this very similar module for 

Orbital. Another European supplier, 

Dutch Space B.V., was brought in to 

construct, test, and integrate the solar 

arrays for the PCM.322

Orbital’s Round 2 COTS proposal 

asserted that the PCM would 

be capable of ferrying 2.3 metric 

tons (roughly 5,070 pounds) of 

pressurized cargo, or 2 metric tons 

(4,409 pounds) of unpressurized 

cargo to ISS. The Orbital capsule 

was designed to dispose of return 

cargo as the vehicle disintegrated 

upon a controlled reentry to Earth’s 

atmosphere.323 In keeping with the 

company tradition of naming vehicles 

based on classical Greek mythology 

and astronomy, Orbital named the 

ISS visiting vehicle Cygnus, a swan 

that would fly to low-Earth orbit.

Company Philosophy

The vehicles’ technical capabilities 

reflected Orbital’s philosophy of relying 

on an international collaboration to 

utilize proven hardware components. 

Frank DeMauro, Orbital’s COTS/CRS 

Program Director, explained: “It’s a 

commercial venture, we’re on a fixed 

price, so we need to be able to do 

it in a cost-efficient way. We need to 

have very low risk, obviously from a 

safety point of view, but also from a 

raw ability standpoint.”324

Thales Alenia Space in Turin, Italy, built the Cygnus cargo modules for Orbital Sciences 

Corp., relying on its experience from building the Multi-Purpose Logistics Modules for 

the ISS, as well as the European nodes of the International Space Station, to build this 

similar module for Orbital. The Italian company shipped the completed modules to the 

flight facility in Virginia. 

Credit: Thales Alenia Space
68 CHAPTER 5 – COMMERCIAL PARTNERS

Orbital also built on the company’s 

experience using tried and tested 

subcontractor components on other 

vehicles. Said Antares Deputy Project 

Director Kurt Eberly, “We tend to 

be in a systems integrator role,” 

continuing, “We buy the parts, we 

know what the parts need to do. 

We do the interfaces, we do the 

analytical work, the simulations.”325

All of the company’s rockets rely 

on the same basic hardware and 

software for functions such as 

guidance, navigation, and control, 

which the company is then able to 

adapt to new configurations based 

on customer need. According 

to Michael R. “Mike” Pinkston, 

Senior Vice President for Antares, 

“I don’t think there’s any substitute 

for building that kind of historical, 

heritage-based understanding of what 

you’re applying,” adding, “It’s simply 

adapting, and that’s really how we’ve 

done business for years.”326

Orbital engineers and officials 

described how they always 

endeavored to pursue a policy of 

openness regarding the COTS 

development process, with both 

NASA and the public. This included 

a candid explanation of mission 

successes as well as failures. 

Frank L. Culbertson, former Space 

Shuttle astronaut and Executive 

Vice President and General Manager 

of Orbital’s Advanced Programs 

Group, described how after a press 

conference, members of the media 

approached him and expressed 

their gratitude for the company’s 

“quiet competence.”327 An already 

Team members from Orbital Sciences Corp. autographed a section of the Cygnus mass simulator which later flew atop the Antares on 

its inaugural flight. Many of them are pictured above with this unique “flight article” along with several NASA officials who were at the 

company’s headquarters in Dulles, Virginia, for a milestone review. Those pictured include (center) C3PO manager Alan Lindenmoyer; 

and (to his left) Frank DeMauro, Orbital’s COTS/CRS Program Director; Jeff Siders, Director, Houston Operations; and Frank Culbertson, 

Executive Vice President and General Manager of Orbital’s Advanced Programs Group.

Credit: Orbital Sciences Corp.
CHAPTER 5 – COMMERCIAL PARTNERS 69

established company with over 

three decades of experience, the 

company hosts press conferences 

for its major launch events. 

NASA Partnership

Although the company used 

a different approach to develop 

its vehicles than SpaceX and 

Rocketplane Kistler, NASA’s 

Commercial Crew & Cargo Program 

Office still worked with Orbital 

as a partner, not a supervisor. 

Culbertson echoed Project Executive 

Bruce A. Manners’ statement that 

NASA had to allow the company 

to develop the vehicles based on 

what would be best for their future 

customers, not just for the space 

agency. A former NASA Program 

Manager, Culbertson said he 

appreciated the suggestions, but, 

“it’s our design, and we’ll make 

our own decisions ... [to] decide 

what’s the safest, most efficient, and 

cost-effective approach.”328

Orbital did value NASA’s advice 

and expertise from both the Project 

Executive and the COTS Advisory 

Teams. As Jeffrey A. Siders, Orbital 

Director of Houston Operations 

explained at the 4th SpaceUp 

Houston conference on February 8, 

2013, “NASA brings in the lessons 

learned, they ensure we’re doing 

things safely, they help us in design 

decisions—although the final decision 

is left to us.”329

Milestones

As with the other two commercial 

partners, Orbital’s Space Act 

Agreement with NASA outlined a 

series of predefined milestones 

to track the development of 

the company’s low-Earth orbit 

transportation system.

Financial Milestones

Because of Orbital’s ability to use 

existing internal funds to pay for COTS 

development, the company’s SAA did 

not include any financial milestones. 

However, all the COTS partners 

struggled to raise the financial 

capital necessary to develop their 

products at some point, and Orbital 

was no exception—especially in 

the early years of the company. 

According to Thompson, “That 

was probably the biggest single 

problem that we had to solve,” as 

Orbital “used just about every form 

of financing that was available during 

the ’80s and ’90s”—from private 

investment, to venture capital, to 

debt financing, to research and 

development limited partnerships—

to get the new startup off the 

ground.330 After maximizing the 

Orbital Sciences Corp. integration and test engineers performed final test and checkout activities for the first two Cygnus Service Modules at the company’s Satellite 

Manufacturing Facility in Dulles, Virginia. Multiple service modules can and are being 

assembled and tested in parallel to support COTS and the follow-on Commercial 

Resupply Services missions. A full-scale poster of a fully assembled Cygnus on the wall 

illustrates the overall size of the spacecraft once on orbit.

Credit: Orbital Sciences Corp.
70 CHAPTER 5 – COMMERCIAL PARTNERS

amount of funding available from 

private sources, in 1990 Orbital went 

public with an IPO, “the equivalent of 

high school graduation for a rapidly 

growing enterprise.”331 This initial 

offering was followed by a series of 

further public stock offerings and 

debt financings in the 1990s. 

By the early 2000s—roughly 20 years 

after the company was founded—

Orbital finally reached a position of 

stability where the company no longer 

needed to raise additional capital; 

profits from its existing rocket and 

satellites programs were sufficient to 

maintain the company’s operations. 

Orbital put a significant amount of 

its own internal funds at risk, about 

$590 million over the five-year course 

of the COTS agreement, in order to 

develop the company’s low-Earth orbit 

transportation capabilities. Orbital 

operated the program at a financial 

loss prior to the COTS demonstration 

flight, hoping its initial investment 

would be recuperated once the 

system became operational.332

Technical Milestones

As with SpaceX, some negotiations 

took place regarding the originally 

planned technical milestones, 

again showcasing the space 

agency’s flexibility in adapting to the 

commercial partners’ needs—not 

the other way around. When Orbital 

signed its Space Act Agreement 

with NASA in February 2008, the 

company proposed to complete 

its demonstration flight using an 

Unpressurized Cargo Module. 

However, in December 2008 the ISS 

Program Office awarded Orbital a 

$1.9 billion Commercial Resupply 

Services contract for eight flights of 

pressurized cargo only. 

Seeing that it would not need to 

supply any unpressurized cargo to 

the ISS in the foreseeable future, 

Orbital requested that its UPCM 

demonstration mission in the Space 

Act Agreement be replaced by a 

demonstration mission utilizing the 

Pressurized Cargo Module instead. 

NASA agreed to the change, and 

amended the Orbital SAA milestones 

to reflect the new plan.333

Another prominent example of 

flexibility and negotiation occurred 

regarding the “Launch Vehicle Stage 

1 Assembly Complete” milestone. 

Although the definition would seem 

fairly straightforward, the milestone 

became the topic of significant 

discussions between C3PO and 

its commercial partner. As Orbital’s 

manufacturing process evolved over 

the course of development, the order 

of the rocket build changed from the 

original plan established at the time 

the SAA was signed. Parts of the 

second stage were now attached 

before the first stage was fully 

assembled. Project Executive Bruce 

Manners explained the quandary: 

“Well, do I pay them early? ... Does 

it make sense for me to have them 

take that second stage off, put the first 

stage pieces on there, and take it back 

off so they can attach the first?”334

Interface inspections between the Antares rocket and the Antares launch mount were 

conducted by Orbital Sciences Corp. after the rocket had been transferred to the launch 

pad using the Transporter, Erector, Launcher (TEL).

By using an overhead crane, Orbital’s 

integration and test engineers lifted one 

of the three main propellant tanks into the 

structure of the Cygnus Service Module. 

This Service Module was flown on the 

COTS Demonstration Mission that was 

successfully completed in October 2013.

Credit: Orbital Sciences Corp.

Credit: Orbital Sciences Corp.
CHAPTER 5 – COMMERCIAL PARTNERS 71

In the end, the partners agreed 

to a “physical configuration audit” 

in which NASA representatives 

conducted an in-person examination 

of the partially assembled first and 

second stages, and approved 

Orbital’s documentation showing 

the remaining first-stage parts were 

accounted for and ready to be 

added to the existing architecture.335

In addition to these matters of 

negotiation, Orbital faced two primary 

technical hurdles in the course of its 

Space Act Agreement with NASA, 

discussed below.

AJ-26 Engines

The AJ-26 engines used to power 

the Antares first stage—part of 

Orbital’s strategy to use already 

available, proven hardware—proved 

more cantankerous than the 

company had originally anticipated. 

Early development tests at NASA 

Stennis Space Center revealed 

that after sitting in storage for 

35-plus years, some of the engine 

components had succumbed to 

stress corrosion that resulted in a 

split fuel manifold line. (This testing 

was conducted under the terms 

of a separate, reimbursable Space 

Act Agreement with Stennis Space 

Center, in which Orbital paid NASA 

for the use of its specialized testing 

facilities which were not available from 

a commercial provider.)336

In order to address the problem, 

Orbital relied on the COTS Advisory 

Team, materials and corrosion experts 

brought in by the Commercial Crew 

& Cargo Program Office to help 

with specific problems. Together, 

Aerojet and Orbital developed a 

“nondestructive evaluation program” 

of X-rays and eddy current inspections 

to detect cracks and repair them by 

welding if necessary.337 In addition 

to the stress corrosion issue, a CAT 

member at NASA White Sands Test 

Facility also provided data that helped 

prevent particle contamination of 

the liquid oxygen that could result in 

accidental ignition.338

Mid-Atlantic Regional 

Spaceport

The second major obstacle for Orbital 

in the development of its commercial 

orbital transportation system was 

the development of the Mid-Atlantic 

Regional Spaceport (MARS) launch 

site adjacent to the NASA Wallops 

Flight Facility on the eastern coast of 

Virginia. In 1995 the Commonwealth 

of Virginia created the Virginia 

Commercial Spaceflight Authority 

(VCSFA). After leasing a tract of 

land from NASA and acquiring the 

necessary license from the Federal 

Aviation Administration Office of 

Commercial Space Transportation, 

MARS was established in 1997 for 

the launch of small launch vehicles 

from Pad 0B, including Orbital’s 

Minotaur rocket.339

Orbital elected to conduct its Antares 

launches at MARS after reviewing 

proposals from both MARS and 

Space Florida, which proposed to 

host the company’s launches from 

Cape Canaveral. Factors in favor 

of MARS included its proximity to 

Orbital’s headquarters in Dulles, 

Virginia; Orbital’s familiarity with 

the Wallops site and organizational 

culture; and the political support of 

Maryland Senator Barbara A. Mikulski. 

Furthermore, the VCSFA promised to 

fund MARS directly through the use 

of tax-free bonds, whereas Space 

Florida would need to seek financing 

through investors and loans.340

Orbital determined these positives 

outweighed some of the advantages 

offered by Space Florida, in particular 

Cape Canaveral’s well-developed 

existing launch infrastructure for 

medium- and large-class rockets.341

In September 2008, the old Pad 

0A was razed in order to begin 

construction on the infrastructure 

required for Antares. The process 

of developing MARS Pad 0A for a 

medium-class rocket, starting “from 

a green field,” was more expensive 

and more time consuming than either 

MARS or Orbital had foreseen.342

The liquid fuel farm that supplies 

Maryland Senator Barbara Mikulski 

(center) cut the ribbon March 22, 2011, 

to open the Horizontal Integration Facility 

at NASA’s Wallops Flight Facility. Built to 

support medium-class launch vehicles, 

Orbital Sciences Corp. was the first 

customer to use the facility for its Antares 

vehicle. On hand for the event were 

(left to right), Bill Gerstenmaier, 

NASA Associate Administrator, NASA 

Administrator Charlie Bolden; and 

David Thompson, CEO and President 

of Orbital Sciences Corporation.

Credit: NASA/Wallops
72 CHAPTER 5 – COMMERCIAL PARTNERS

propellant to the rocket presented 

an especially troublesome area, 

as operations required a complex 

and precise configuration of 

components to ensure correct 

cleanliness levels, temperatures, 

pressures, and flow rates. Specific 

issues included “bad welds, 

valves that didn’t work, [and] 

resonances in the fueling system that 

caused it not to operate.”343

Thompson reported that the cost 

was about three times higher and 

the site took two years longer to 

complete than originally estimated. 

Complicating matters was the 

complex nature of relationships 

between federal and state agencies 

and the private corporation, as NASA, 

VCSFA, and Orbital coordinated to 

prepare the facility for launch. To help 

relieve the issue, NASA contributed 

the horizontal vehicle assembly 

building, and Orbital advanced about 

$45 million to the state of Virginia 

in order to complete development. 

The accumulation of small issues 

resulted in what turned out to be 

lengthy delays, but work was finally 

completed in October 2012.344

Augmentation Milestones

Orbital received an additional 

$118 million as a result of the fiscal 

year 2011 augmentation of the 

COTS budget, and NASA and the 

company agreed to 10 additional 

milestones to accelerate development 

and mitigate risks. 

These additional SAA milestones 

were divided into three main tasks: 

the addition of a Taurus II (Antares) 

maiden flight, installation of an 

additional processor-in-the-loop 

simulator, and a Proximity Flight 

Equivalent Unit (PROX FEU) test 

The Mid-Atlantic Regional Spaceport, a commercial space launch facility, is located on Virginia’s Eastern Shore. Orbital Sciences Corp., 

NASA, state, and local officials coordinated efforts to transform Pad-0A into a facility that could support the medium-class Antares rocket.

Credit: NASA/Bill Ingalls
CHAPTER 5 – COMMERCIAL PARTNERS 73

unit for ISS integration testing.345

The latter two items provided 

additional software to improve the 

accuracy of modeling and operations, 

but for both NASA and Orbital the 

most important milestone was the 

additional test of the launch vehicle.

The addition of a test of the rocket 

prior to attempting a launch of the 

entire system allowed Orbital to 

verify that this crucial element could 

complete its role in the mission 

before attempting the full journey to 

ISS. According to Orbital officials, 

this test was one the company had 

wanted to complete at the beginning 

of the program, but the available 

NASA and internal funding did not 

allow for its inclusion in the original 

Space Act Agreement.346

The Antares test flight launched a 

Cygnus mass simulator, designed 

with the same weight, volume, and 

center of gravity as the PCM that 

would later be launched to ISS. Eberly 

explained, “The rocket launch is the 

most astringent environment that a 

spacecraft will see in its lifetime,” so 

adding thermometers, microphones, 

and other instrumentation to 

measure factors such as vibration, 

acoustic, and thermal loads helped 

collect information to ensure 

Cygnus would be able to handle 

the launch environment in order 

to successfully complete the ISS 

demonstration mission.347

Antares Test Flight 

On February 22, 2013, Orbital 

completed a successful hot fire test of 

the Antares rocket on MARS Pad 0A, 

and two months later the company’s 

perseverance and commitment to 

resolving issues culminated in what 

was described as a “flawless” and 

“perfect” test flight of the rocket. 

After two scrubs, the first due to a 

disconnected data cable and the 

second due to high winds, Antares 

successfully launched from Pad 0A at 

5:00 p.m. local time on April 21, 2013. 

The separation of the first and second 

stages of the rocket occurred exactly 

as planned, and 10 minutes after 

launch the Cygnus mass simulator 

was deployed and reached close to 

its targeted orbit of approximately 

150 to 160 miles. The inclination of 

51.6 degrees matched that of ISS 

and the company’s upcoming final 

demonstration mission.348

Describing the tension in the control 

room at Wallops, DeMauro said, 

“I don’t recall ever being as nervous 

as I was—not because I didn’t think 

it would work, just because all of us 

knew how important it was.”349 Eberly, 

who had worked on the rocket since 

its inception as Taurus II in April 2007, 

added, “We’d done our homework, 

but you can never be sure that 

everything’s going to work properly 

together.”350 When the moment of 

first-stage separation arrived, the 

control room erupted in spontaneous 

applause, the managers and engineers 

relieved and elated to see all their 

hard work culminate in a successful 

mission, “all feeling like little kids again, 

feeling completely renewed.”351

In addition to the Cygnus mass 

simulator, Antares also deployed three 

experimental PhoneSats—called 

Alexander, Graham, and Bell—that 

used smartphones to photograph the 

Earth from space. Other picosatellites, 

including the Dove-1 satellite 

dedicated to amateur radio, provided 

additional data for those interested 

in “open[ing] space to a whole new 

generation of commercial, academic, 

and citizen-space users.”352

The Antares rocket launched from 

Pad-0A of the Mid-Atlantic Regional 

Spaceport on the NASA Wallops Flight 

Facility in Virginia on April 21, 2013. 

The test launch marked the inaugural 

flight of the Orbital Sciences Corp. 

rocket and the biggest rocket ever 

launched from this facility. The Antares 

deployed a Cygnus mass simulator 

and three experimental PhoneSats—

Alexander, Graham, and Bell—that used 

smartphones to photograph the Earth 

from space.

Credit: Orbital Sciences Corp. 
74 CHAPTER 5 – COMMERCIAL PARTNERS

Cygnus Demo Mission

On September 18, 2013, Orbital 

conducted its second launch of the 

Antares rocket, this time aiming for 

the International Space Station with a 

fully-operational Cygnus as its payload. 

The company named the spacecraft 

for G. David Low in honor of the 

three-time Space Shuttle astronaut 

and former Orbital executive who had 

passed away in March 2008.353

Ten minutes after launch, at 

11:08 Eastern time, the Cygnus 

capsule separated from the second 

stage of Antares and began its 

journey to low-Earth orbit.354

Cygnus successfully performed 

its first on-orbit tasks, for example 

deployment of its solar arrays and 

an abort demonstration. However, 

approximately six hours before it was 

due to berth with ISS on the morning 

of September 22, Orbital and NASA 

engineers discovered a discrepancy 

in the navigation software used by 

Cygnus and ISS. 

The team decided the most prudent 

course of action would be to delay 

the berthing by one week. This 

would allow sufficient time for the 

team to upload a software fix, and 

for three new Expedition 38 crew 

members to arrive via the Russian 

Soyuz on September 25.

Eleven days after the Antares launch, 

in the early hours of the morning on 

Sunday, September 29, 2013, Cygnus 

began its approach toward the Earthfacing, or nadir, side of the International 

Space Station. After demonstrating 

its remaining on-orbit tasks, including 

About 10 meters away, the ISS crew members used the Canadarm2 to grapple the 

Orbital Sciences Corp. cargo module. The Cygnus remained at the ISS for three 

weeks before it was released with disposables from the International Space Station. 

As planned the Cygnus spacecraft destructively reentered the Earth’s atmosphere over 

the Pacific Ocean.

NASA astronaut Karen Nyberg (left) 

and European Space Agency astronaut 

Luca Parmitano, both ISS Expedition 

37 flight engineers, monitored the 

approaching Cygnus spacecraft as it 

neared the ISS, on September 29, 2013.

NASA Administrator Charles Bolden (right) congratulated the Orbital Sciences Corp. 

launch team and management in the Range Control Center at the NASA Wallops Flight 

Facility after the successful maiden launch of the company’s Antares rocket. 

Credit: NASA/Bill Ingalls
CHAPTER 5 – COMMERCIAL PARTNERS 75

retreat and hold capabilities, at 

5:00 a.m. local time NASA Mission 

Control in Houston granted the 

capsule permission to enter the 

Station’s 660-foot Keep Out Sphere. 

The grapple that was planned for 

11:15 a.m. GMT occurred slightly 

ahead of schedule, as American 

astronaut Karen Nyberg and Italian 

astronaut Luca Parmitano operated 

the Station’s robotic Canadarm for a 

successful grapple of the “beautiful 

baby swan” at 11:02 a.m. GMT, 

as ISS passed over the Indian 

Ocean.355 Afterward, C3PO Manager 

Lindenmoyer described the mission 

as “just beautiful,” as he praised 

Orbital for its “professional, skilled” 

approach to addressing development 

and mission challenges “with such 

expertise over the years.”356

The next day, the astronauts and 

cosmonauts onboard the ISS began 

unloading the vehicle’s 1,543 pounds 

of cargo. On October 23, 2013, 

Cygnus completed its three-week 

stay by deorbiting from ISS, this 

time loaded with disposables from 

the Station, and destructively 

reentering Earth’s atmosphere over 

the Pacific Ocean.

Ready for the Future

In the course of Orbital’s Antares 

and Cygnus development programs, 

the company’s demonstration 

flight to ISS occurred after a 

cumulative delay of almost three 

years, as the terms of the original 

Space Act Agreement planned 

for the ISS demonstration mission 

to occur in December 2010. 

Many of these delays were the 

result of launch pad development 

issues outside of Orbital’s control, 

and members of C3PO expected 

at least some degree of schedule 

slips based on the partners’ original, 

aggressive schedules. In the words 

of Orbital Project Executive Bruce 

Manners, “They make jokes about 

rocket science for a reason.”357

However, having cleared the hurdle 

of the demonstration mission, 

Orbital was now ready to commence 

regular resupply missions under its 

$1.9 billion Commercial Resupply 

Services contract.

358 Culbertson 

discussed how future missions would 

be capable of carrying more cargo, 

over two and a half tons (5,000 

pounds) by the fourth CRS mission, 

and focus more on scientific payloads 

for ISS research. Because future 

missions would not have to complete 

on-orbit demonstration tasks, these 

payloads could arrive at ISS within 

two to three days after launch.

Frank Culbertson, (center), Executive Vice President and General Manager of Orbital’s 

Advanced Programs Group, provided details about the Cygnus demonstration mission at 

a press conference held at JSC. Seated next to him was C3PO Manager Alan Lindenmoyer, 

and ISS Flight Director Courtenay McMillan (right), who during the mission gave the 

go-ahead for the Cygnus to rendezvous and berth with the International Space Station.

NASA’s commitment to work with 

commercial partners extends into the future. 

Among those from the space agency who 

continue to support this effort are (left to 

right) Marc Timm, COTS Program Executive, 

NASA Headquarters; Phil McAlister, 

NASA Director of Commercial Spaceflight 

Development; Dennis Stone, C3PO Program 

Integration Manager; and Sam Scimemi, 

Director for International Space Station at 

NASA Headquarters.

Credit: C3PO team

Credit: NASA/James Blair
76 CHAPTER 5 – COMMERCIAL PARTNERS

Culbertson explained, “We’re happy 

to take food and clothing...but 

we want to make sure that we’re 

also able to provide the science 

and the research that can be 

accomplished on the Station,” 

adding, “We know and understand 

and accept the responsibility that 

this is critical to the continuation of 

the Station and the continuation 

of U.S. leadership in space.”359

Several observers have pointed out 

how a relatively small government 

investment has resulted in the 

development of a new low-Earth 

orbit delivery system—comprised 

of a medium-class launch vehicle, 

the Cygnus capsule, as well as the 

ground-support technologies and 

infrastructure that allow those vehicles 

to function—for both government 

and private-sector customers. From 

the time Orbital and NASA signed the 

Space Act Agreement in February 

2008 through June 2013, NASA 

contributed approximately $288 million 

in milestone funding for the COTS 

development work, while Orbital spent 

a total of approximately $590 million, 

contributing more than twice the NASA 

commitment to complete the program.

Orbital has more than three decades 

of experience with small launch 

vehicles and satellites, although it 

started off focusing on a single NASA 

program. Over time (especially after 

the Challenger accident in 1986) the 

company continued to grow and 

diversify, moving from small temporary 

facilities to a larger campus on Warp 

Drive in Dulles, Virginia in 1993.360

If Rocketplane Kistler provides 

the example of an unsuccessful 

aerospace startup, and SpaceX a 

fledgling company in rapid growth, 

Orbital shows one possibility for what 

a mature aerospace company can 

look like after 30 years of operation. 

Now both COTS commercial partners 

had the opportunity to finish a project 

conceived decades ago—private 

cargo resupply services to support 

NASA’s mission in low-Earth orbit.

This timeline illustrates the eight-year history of the COTS program, beginning with the first competition in 2006 and culminating with 

the final partner demonstration missions in 2013.

NASA Administrator Charlie Bolden recognized the Commercial Orbital Transportation 

Services program and its commercial partners for innovative accomplishments and 

outstanding contributions to the space agency. (Pictured left to right) Bolden presented 

the NASA Group Achievement Award to Frank Culbertson, Executive Vice President and 

General Manager, Orbital Sciences Corp. Advanced Programs Group; Gwynne Shotwell, 

President, SpaceX; and Alan Lindenmoyer, Manager of NASA’s Commercial Crew & 

Cargo Program. Bolden stated how “America’s best days in space exploration are ahead 

of us” during the awards ceremony held at NASA Headquarters in Washington, DC, 

November 13, 2013.

Credit: NASA/Jay Westcott
CHAPTER 6 – COLLABORATION 77 chapter 6

Collaboration

International Space Station

Federal Aviation Administration
78 CHAPTER 6 – COLLABORATION

As a multi-billion dollar asset, the 

International Space Station maintains 

a strict set of requirements for 

vehicles approaching within 660 feet 

of its football field-sized structure, the 

so-called Keep Out Sphere (KOS), 

to protect the Station’s structure, 

equipment, scientific experiments, 

and human crew. Potential issues for 

commercial cargo missions included 

vehicle collisions, micrometeoroid 

strikes, and plume impingement, 

i.e., visiting vehicle exhaust streams 

that could leave harmful deposits of 

contaminants and/or damage delicate 

structural elements of the Station 

such as solar arrays.361

Under the COTS program, the Space 

Exploration Technologies Corp. 

(SpaceX), Orbital Sciences Corp., and 

Rocketplane Kistler (RpK) all proposed 

to perform the demonstration of 

their low-Earth orbit capabilities 

by visiting the ISS, and therefore 

were required to meet the Station’s 

visiting vehicle requirements. COTS 

offered the possibility of a U.S.-based 

option for not only carrying additional 

cargo, including powered payloads 

for science experiments, but also 

returning research samples back to 

Earth for study.

The ISS Transportation Integration 

Office (TIO) already had experience 

collaborating with external organizations 

through its work integrating 

International Partner resupply vehicles 

to the Station’s modules. 

Before the development of U.S. 

commercial cargo capabilities, 

the ISS relied on four international 

vehicles (in addition to the Space 

Shuttle) to provide regular resupply 

services: the Russian Federal Space 

Agency’s Soyuz and Progress 

spacecraft, the European Space 

Agency’s Automated Transfer Vehicle 

(ATV), and the Japan Aerospace 

Exploration Agency’s H-II Transfer 

Vehicle (HTV).362 The Soyuz transports 

up to three people to and from the 

ISS, but the Progress, ATV, and HTV 

can carry cargo only. Upon reentry 

into Earth’s atmosphere, these cargo 

vehicles disintegrate and incinerate 

waste materials returned from ISS.

The International Partner experience 

laid the groundwork for the COTS 

visiting vehicles, as NASA personnel 

learned from working with their 

Russian, European, and Japanese 

counterparts the need to minimize 

and clearly communicate even 

seemingly basic aspects of the 

launch, rendezvous, and docking 

process (including standard 

NASA procedures such as the 

Certification of Flight Readiness). 

Unique in its operations, the Commercial Crew & Cargo Program Office (C3PO) 

worked with organizations within NASA, as well as other federal agencies, to 

stimulate the commercial space industry. Interactions with the International 

Space Station (ISS) Program Office and the Federal Aviation Administration 

(FAA) Office of Commercial Space Transportation proved that while COTS 

forged new relationships between NASA and industry, the program’s innovative 

methods could mesh with established tradition. Although not everyone 

accepted this new approach at the outset, the achievements of the Commercial 

Orbital Transportation Services (COTS) initiative remain evident, and lessons 

learned from the program continue to be utilized.

International Space Station
CHAPTER 6 – COLLABORATION 79

This helped ensure all the 

International Partners were, as it 

were, speaking the same language.363

TIO Manager Kathryn L. Lueders 

was assigned the role of COTS-ISS 

integration in October 2006, roughly 

two months after the Round 1 Space 

Act Agreements were signed. She 

became responsible for tailoring 

the visiting vehicle requirements for 

commercial vehicles. To meet the 

early December deadline for the first 

SpaceX System Requirements Review, 

Lueders relied on the draft COTS ISS 

Interface Requirements Document 

that had been developed as a guide 

by C3PO Deputy Program Manager 

Valin B. Thorn, using it as a starting off 

point to negotiate in tandem with the 

selected COTS companies.364

Lueders emphasized that she 

“viewed the companies as a partner,” 

working with them collaboratively to 

determine how both parties could 

meet their respective needs.365 For 

the COTS industry partners, this 

meant developing their vehicles as 

expeditiously as possible, without 

being hampered by superfluous 

requirements that did not reduce the 

risk of operations. For the ISS Program 

Office, this meant ensuring the safety 

of the Station and its inhabitants. 

ISS TIO met with representatives 

from each of the COTS partners 

to negotiate their visiting vehicle 

requirements (including RpK before 

its Space Act Agreement with 

NASA was terminated in October 

2007). The companies were allowed 

the opportunity to question the 

rationale behind each of the many 

requirements for ISS docking and 

berthing. These questions forced the 

ISS Program Office to consider the 

justification for each of the technical 

obligations imposed, ensuring the 

requirements truly contributed to 

mission safety, instead of maintaining 

a set list out of tradition. Frank 

DeMauro, Orbital’s COTS/CRS 

Program Director, referred to the 

discussions as collaborations: “It’s 

important to point out that it wasn’t 

stake-in-the-ground, no flexibility.”366

These negotiations also allowed 

Station engineers to impart some of 

their wisdom and lessons learned to 

the partners. For example, Orbital was 

able to simplify its avionics system as a 

result of working with the ISS Program 

Office.367 In fact, for both Orbital and 

While the commercial partners developed their launch vehicles and cargo delivery systems, the ISS Transportation Integration Office 

worked closely with the companies to ensure a safe transport to and from the orbiting laboratory. NASA’s ability to conduct new 

scientific investigations for the ISS Program, led by Manager Mike Suffredini (above), significantly increased because of the rockets and 

spacecraft built by SpaceX and Orbital Sciences Corp. The ISS Program was extended until at least 2024 by President Barack Obama. 

In the near-term, all current and planned U.S. experiments aboard the International Space Station will be facilitated in some way by a 

SpaceX or Orbital Sciences Corp. resupply mission.

Credit: NASA/Bill Ingalls
80 CHAPTER 6 – COLLABORATION

SpaceX, software compatibility 

proved to be a formidable issue. 

SpaceX also experienced issues 

because it utilized a more recently 

developed programming language, 

rather than those used by NASA’s 

heritage systems.368

In some cases the NASA project 

executives served as brokers between 

the partners and their counterparts 

in the ISS Program Office. Michael J. 

“Mike” Horkachuck, Project Executive 

for SpaceX, described how he was 

able to apply his knowledge of ISS 

development history to “influence 

how hard the ISS team was pulling 

on a particular requirement, and try 

to add a little bit of sanity to meeting 

the letter of the law versus the overall 

intent.”369 Horkachuck explained 

that he was able to “talk to the 

NASA side, whoever was raising the 

concern, and understand, mediate 

our way through.”370

In addition to the requirements, NASA 

and its commercial partners also 

negotiated how to verify that those 

requirements had been met. That 

is, to use an example from SpaceX, 

what kind of data was required to 

show that the Dragon spacecraft’s 

software was compatible with ISS 

avionics. According to SpaceX 

President Gwynne E. Shotwell, the 

verification process was a huge 

challenge that was sometimes 

“painful for both NASA and SpaceX,” 

because “there are hundreds, if not 

a thousand or so, requirements.” 

She added that there were years of 

discussion on, “how do you prove 

that you’ve met them?”371

However, in the end, SpaceX 

employees reflected that they had 

“an opportunity to grow together 

with the ISS office” during COTS 

and developed a harmonious 

working relationship with NASA.372

Orbital Vice President Antonio L. Elias 

described the interaction as one 

“of two organizations: one that 

knew a lot about commercial lowcost space, the other that knew a 

lot about traditional government 

procurement and tests, and both 

trying to find a way to do things in a 

satisfactory way.”373

The ISS Program Office also adapted 

to allow commercial partners to retain 

their intellectual property rights as 

specified under the terms of their 

COTS Space Act Agreements. TIO 

learned how to work with companies’ 

proprietary data from both the 

COTS program and the NASA 

Launch Services Program (LSP) at 

the Kennedy Space Center, another 

group that was accustomed to buying 

services and having limited rights to 

this type of information. Conversely, 

the commercial partners learned 

how to better compartmentalize their 

documentation, separating company 

technical design data from documents 

needed for ISS integration. This was 

especially important because some 

COTS partner integration data was 

not only shared with NASA, but also 

NASA’s International Partners.374

SSP 50808

In the summer of 2007, the ISS 

Program Office produced Space 

Station Program (SSP) 50808, the 

ISS to COTS Interface Requirements 

Document. ISS Program Manager 

Michael T. Suffredini determined that 

SSP 50808 would be the only volume 

private entities would need in order 

to visit ISS, as opposed to producing 

individually-tailored books for each 

partner. One integrated volume 

“really makes the Station Program 

have to justify why that requirement is 

there, and why it’s worded a certain 

way,” explained Lueders.375

Under the COTS program, the government and private sector invested funds, shared 

risks, and moved through technical challenges to successfully restore U.S. cargo 

transport capabilities for the ISS. Alan Lindenmoyer, Manager of NASA’s Commercial 

Crew & Cargo Program, described COTS as “a new era in spaceflight.” He is pictured 

above with Gwynne Shotwell, President of SpaceX, the first commercial partner to 

complete its COTS milestones.

Credit: NASA/Kim Shiflett
CHAPTER 6 – COLLABORATION 81

Like COTS, SSP 50808 reflected 

NASA’s new way of doing business. 

The document continued to evolve 

as NASA added to the number of 

private enterprises aiming to visit the 

International Space Station, including 

the companies that participated in 

NASA’s follow-on commercial 

crew programs. For example, Revision 

D, the updated version of SSP 

50808 released in early 2012, added 

specifications for docking directly to 

the Station, whereas previous versions 

had only addressed berthing to ISS 

with the aid of the robotic Canadarm. 

A continued effort was made to make 

the volume easier for new commercial 

providers to use and understand.

Commercial Resupply 

Services Contracts

The original plan for NASA’s 

commercial initiative called for 

its execution to occur in two 

consecutive phases. In Phase 1, 

COTS, the commercial partners 

would develop and demonstrate 

their low-Earth orbit transportation 

systems. Understanding that COTS 

would create viable competitors for 

a follow-on procurement, Phase 2 

would then entail the purchase of 

these fully-developed services through 

a traditional Federal Acquisition 

Regulation-based services contract. 

This Commercial Resupply Services 

(CRS) contract was issued by the ISS 

Program Office, the customer of those 

services, independently of C3PO.

NASA originally planned to compete 

and award CRS after the participating 

COTS companies had successfully 

completed all the milestones of their 

Space Act Agreements and proven 

their ability to deliver cargo to a 

destination in low-Earth orbit. But, 

in the spring of 2007 a NASA team 

composed of Lindenmoyer, Lueders, 

and Ramon Lugo, Deputy LSP 

Manager, concluded that awarding 

CRS after the COTS missions could 

adversely impact Station. 

Based on the original schedule 

for the commercial partners’ 

demonstration missions, and with 

the anticipated retirement of the 

Shuttle looming, if NASA waited until 

those demonstration missions were 

complete, the Station would face a 

27- to 30-month servicing gap due to 

the lead time required to start a new 

contract. This could mean a cargo 

shortfall of 48.8 metric tons (107,585 

pounds) or more. Plus, if development 

delays occurred within the COTS 

program, the gap could increase 

even more. Therefore, the team 

recommended that the procurement 

for CRS take place much sooner than 

originally planned.376

According to the team’s analysis, 

the contract needed to be awarded 

by December 2008 at the latest. On 

August 7, 2007, the Space Operations 

Mission Directorate (SOMD) at NASA 

Headquarters issued a Request for 

Information, soliciting input from 

commercial companies on their 

potential to provide commercial cargo 

services to ISS.377 After three days 

of meetings with industry, NASA 

determined that sufficient interest 

existed in order to release a Request 

for Proposals for a commercial 

In December 2008 NASA awarded Commercial Resupply Services (CRS) contracts to 

both COTS partners. SpaceX was contracted for 12 missions and launched its first CRS 

flight on October 7, 2012. Shown below is the Falcon 9 rocket with the Dragon spacecraft 

on board prior to the second delivery, SpaceX CRS-2, that lifted off March 1, 2013.

Credit: NASA/Tony Gray and Robert Murray
82 CHAPTER 6 – COLLABORATION

resupply contract. The CRS Request 

for Proposals was issued on April 

14, 2008, and ISS awarded the CRS 

contract on December 23, 2008—

only a few months after the first 

successful flight of the SpaceX Falcon 

1 rocket, and less than a year after 

Orbital signed its SAA with NASA.378

William H. “Bill” Gerstenmaier, head 

of the Space Operations Mission 

Directorate (SOMD) in 2008 at NASA 

Headquarters, later explained that 

“if we didn’t move out with some kind 

of services contract there was going 

to be no ability to resupply the Space 

Station. This is where it became 

serious. We absolutely needed this 

service; we were destined to retire 

the Shuttle.” He added, “We had no 

choice. If we were going to deliver, 

we needed to go do the services 

contract, move out, and move 

forward.” Gerstenmaier reemphasized 

that “I didn’t want to do this 

procurement [before the capabilities 

were demonstrated], but I had to 

because of the time criticality.”379

Unlike the COTS Space Act 

Agreements, CRS was a 

procurement; NASA was buying 

a definite service, with a contract 

subject to the Federal Acquisition 

Regulations. A different set of 

personnel participated in the Source 

Evaluation Board and procurement 

process than were involved in the 

contemporaneous COTS work. NASA 

Deputy General Counsel Sumara 

Thompson-King explained, “People, 

language, resources—we put up a 

firewall of sorts to make sure that, as 

much as we could within the Agency 

and external to the Agency, they were 

viewed as different processes.”380

Gerstenmaier served as the CRS 

selection official, making the ultimate 

decision regarding which of the three 

companies that submitted proposals 

would receive the award. In the end 

Gerstenmaier decided to select two 

companies, in order to allow for 

redundancy to ensure the Station 

received all 40 metric tons (88,185 

pounds) of supplies needed by the 

end of the contract.381 As with the 

first round of the COTS competition, 

SpaceX submitted the most highly 

ranked proposal, receiving the highest 

score for both the evaluation criteria 

of 1) mission suitability, and 2) lowest 

price (with the former prioritized as 

more important than the latter).382

Although the Source Evaluation 

Board scored PlanetSpace marginally 

higher than Orbital Sciences Corp. 

for both criteria, Gerstenmaier found 

that several weaknesses in the 

PlanetSpace proposal outweighed 

its potential strengths. First, although 

PlanetSpace’s subcontractors 

Lockheed Martin Corp., The Boeing 

Company, and Alliant Techsystems, 

Inc. (ATK) had substantial past 

experience working on government 

programs, the same could not be 

said of PlanetSpace itself. Second, 

NASA found multiple issues with 

the company’s cost assumptions. 

For example, PlanetSpace would 

be awarded a fixed-price contract 

from NASA, but planned to pay 

its subcontractors on a cost-plus 

basis—resulting in a potentially 

significant financing gap which the 

company had no reasonable plan to 

address. NASA also found several of 

the company’s technical, schedule, 

and costs assumptions to be 

“unrealistically optimistic.”383

NASA’s Source Evaluation Board 

noted Orbital’s use of Aerojet AJ-26 

engines—refurbished decades-old 

Russian NK-33s originally developed 

for the Soviet Moon program—as a 

weakness. This weakness was not 

ranked as significant because it was 

somewhat mitigated by subcontractor 

William H. “Bill” Gerstenmaier, as NASA Associate Administrator for the Human Exploration 

and Operations Directorate, provided updates to Congress on both the COTS and CRS 

programs. He included details of the progress as well as explanations of what he called the 

“challenges associated with a technologically ambitious endeavor.” Gerstenmaier began 

his career with NASA in 1977 and through the years led major efforts for the space agency 

including the Space Shuttle and International Space Station programs prior to 2005 when 

NASA named him to lead the agency’s Space Operations Mission Directorate. In 2012 

Gerstenmaier’s duties expanded with his current role.

Credit: NASA/Paul E. Alers
CHAPTER 6 – COLLABORATION 83

Aerojet’s experience and the fact that 

the engines were stored in a humiditycontrolled environment. On the whole, 

NASA found that this weakness was 

balanced by the strengths of Orbital’s 

existing processes and in-house 

expertise. Orbital also proposed to 

deliver ISS resupply services by 2012, 

a year earlier than PlanetSpace.384

The fixed price Commercial 

Resupply Services contracts were 

thus awarded to the two COTS 

partners, SpaceX and Orbital. Each 

of the respective contracts began on 

January 1, 2009, and ran through 

the end of 2016, requiring delivery of 

20 metric tons (about 44,100 pounds) 

to the International Space Station, 

distributed over multiple flights. 

SpaceX was contracted to deliver 

the specified quantity of upmass 

(cargo to ISS) over 12 missions for a 

total price of $1.6 billion. Orbital was 

contracted for eight missions for a 

total of $1.9 billion.385

Government 

Accountability Office 

Protest 

After losing to SpaceX and Orbital, 

PlanetSpace protested NASA’s 

decision at the Government 

Accountability Office (GAO), where, 

as with the two protests of the 

COTS awards, the NASA legal teams 

at JSC and NASA Headquarters 

again successfully defended 

the space agency’s selection. 

The GAO issued its decision on April 

22, 2009, explaining that despite 

PlanetSpace’s claims of biased 

treatment, the selection process had 

been fair and transparent.386

For many on the legal team, the 

protest itself was less significant 

than NASA’s decision to override 

the “automatic stay” provision that 

requires the Agency to put the 

program on hold for 100 days while 

the GAO makes its decision. Because 

ISS resupply services were seen as 

increasingly critical to the Agency’s 

mission to maintain the International 

Space Station, Gerstenmaier made 

the risky decision to override so 

that the CRS contract could be 

implemented as quickly as possible. 

Gerstenmaier spent hours on the 

stand justifying his decision, and 

as another credit to the legal team, 

NASA’s decision to override the 

automatic stay was one of the rare 

cases upheld at the Department of 

Justice Court of Federal Claims.387

Collaborative Efforts

The award of the CRS contracts to 

the COTS competitors facilitated 

efforts within the ISS Program Office 

to ensure the companies’ vehicles 

would be prepared for their future ISS 

resupply flights. The transportation 

integration teams that verified that 

the COTS partners met integration 

requirements were able to transition 

their technical knowledge of the 

NASA contracted with Orbital Sciences Corp. to complete eight missions to the ISS as part the Commercial Resupply Services (CRS) 

contract. The Antares rocket (shown above) with the Cygnus cargo capsule filled with crew provisions, spare parts, science experiments, 

and other hardware launched on January 9, 2014, for its CRS-1 mission.

Credit: NASA/Bill Ingalls
84 CHAPTER 6 – COLLABORATION

Dragon and Cygnus spacecraft 

to the management of the CRS 

contract. Lueders explained how, 

by “leverag[ing] off of that work that 

had already been done ... we were 

able to optimize our resources and 

the contractors’ resources, and then 

optimize how we were relating with 

Alan’s [COTS] folks too.”388

After the CRS award, Lueders and 

TIO worked “hand-in-glove” with 

Lindenmoyer and the COTS team in 

encouraging the commercial partners 

to meet their technical milestones. 

The two offices held joint quarterly 

review meetings to present a united 

NASA front, sometimes playing “bad 

cop, good cop,” with the commercial 

partners in order to encourage 

their development.389 Antonio L. 

Elias, Executive Vice President and 

Chief Technical Officer of Orbital, 

observed that C3PO functioned as 

a “lubricant” for the ISS Program 

Office and commercial partners 

“to mesh together.”390 While C3PO 

maintained the role of investor, aiding 

development but offering payment 

only upon milestone completion, 

Lueders’ office was able to enforce 

stricter requirements in accordance 

with the terms of the CRS contracts. 

Lueders reported that, “Honestly, 

it was a great, great collaboration 

between us.”391

As with the definitions of 

requirements, the ISS Program Office 

worked flexibly with the commercial 

partners to schedule their resupply 

missions under the CRS contract. 

Even after the ISS office verified 

that vehicles conformed to SSP 

50808, vehicles could not fly to the 

International Space Station at will. 

The ISS office maintained a complex 

schedule for all visiting vehicles slated 

to resupply the orbiting laboratory: 

Soyuz, Progress, ATV, HTV, and 

now Dragon and Cygnus. Further 

complicating matters was the fact 

that ISS had contracted missions 

for vehicles that did not yet exist in 

flight-ready form. As the commercial 

partners’ technical milestones 

continued to slip, resulting in an 

almost three-year development delay 

from original projections, the ISS 

office adjusted its schedules and 

cargo manifests to accommodate the 

necessary resupply.

TIO approached the problem from 

a position of trying to aid and 

encourage what they recognized was 

a very demanding and challenging 

task for private industry. Lueders 

used the term “balance” to describe 

NASA’s approach to securing the 

contracted delivery services without 

being so overbearing as to prevent 

the companies from being “healthy” 

enough to carry out their missions. 

Instead of “driving them into the 

ground with launch slip costs,” the 

ISS team viewed the commercial 

partners as such, and arranged at 

the beginning of the contract to be 

able to negotiate launch schedules 

and missions profiles to better suit 

the development needs of both the 

companies and ISS.392 In one case, 

for example, a schedule slip benefited 

both SpaceX and the ISS office: 

ISS also needed additional time to 

determine how best to robotically 

extract external cargo from the 

Dragon spacecraft.

Augmented Funding

In fiscal year 2011, Congress took 

the rare and noteworthy step of 

approving the addition of $300 million 

to the C3PO budget. (More details 

of the augmentation can be found 

in Chapter 4: Program.) The COTS 

team reviewed multiple potential 

uses of these unanticipated funds. 

Actions under consideration included 

modifying the ISS Commercial 

Resupply Services contracts (for 

example funding early cargo delivery, 

and/or building additional capsule 

mockups for training) and giving 

money to other NASA organizations 

that supported the infrastructure for 

commercial cargo delivery.393

As part of the original COTS 

agreements, NASA’s contributions to 

the commercial partners were fixed 

at the beginning of the program, and 

any cost increases incurred while 

pursuing the milestones were solely 

the responsibility of the commercial 

International partners provided supplies to the ISS after America’s Space Shuttle Program 

ended in July 2011. The European Space Agency built five Automated Transfer Vehicles 

(ATV), pressurized modules with a cargo capacity of almost 17,000 pounds. Shown 

above is the Jules Verne, the first ATV that launched March 9, 2008, and docked with the 

ISS on April 3. On September 29, 2008, as it reentered the Earth’s atmosphere, the ATV 

incinerated as planned.
CHAPTER 6 – COLLABORATION 85

partners. Therefore, when additional 

funding became available, C3PO 

determined that the best application 

of these funds was to add milestones 

to the commercial partners’ COTS 

Space Act Agreements specifically to 

reduce technical risk and accelerate 

development of their respective 

systems to deliver the needed cargo 

to low-Earth orbit.394

At the time of the augmentation, 

COTS was still “owed” $12 million in 

funding from the original $500 million 

allocation. Therefore, the program 

expected to receive $312 million in 

fiscal year 2011 ($300 million plus 

$12 million) for augmentation and 

original program milestones. Instead, 

C3PO received only a $300 million 

allocation. This meant the program 

had to use $12 million of the $300 

million augmentation for original 

milestones, leaving $288 million in 

available additional funds.395

C3PO transferred $17.5 million to the 

ISS Program Office in order to allow 

ISS to purchase cargo on the COTS 

demonstration missions, a service 

not permitted under the terms of the 

COTS Space Act Agreements.396

This left about $118 million worth of 

additional milestones to be added to 

each partner’s Space Act Agreement. 

From December 2010 to May 

2011, these additional milestones, 

including a thermal vacuum test 

for SpaceX and an additional test 

flight for Orbital, were negotiated 

with the partners and added to their 

respective Space Act Agreements.397

Engineers in C3PO saw the 

advantage of this mid-stage injection 

of funds, noting that at that point 

the strengths and weaknesses in 

project development were becoming 

more apparent, and “you can start 

plugging holes in where there are 

big weaknesses.”398

Federal 

Aviation 

Administration

While NASA’s safety community 

largely accepted how operations 

pertaining to the ISS were conducted, 

some noted the Agency’s lack of 

jurisdiction in the case of an accident 

on Earth.399 Because the industry 

partners’ launches and reentries 

were commercial, not government 

activities, these fell under the 

authority of a different federal agency, 

the Federal Aviation Administration 

(FAA) Office of Commercial Space 

Transportation (AST).

The space policy that President 

Ronald Reagan established in the early 

1980s (before the Challenger accident) 

strongly supported commercial space 

enterprises. The 1984 Commercial 

Space Launch Act allowed and 

encouraged the development of 

private launch and reentry services, 

and created the AST under the 

Department of Transportation “to form 

a single one-stop shop that would 

facilitate the process of a commercial 

entity conducting a launch.”400 The 

Office was charged with the dual tasks 

to 1) regulate the U.S. commercial 

space transportation industry, and 

2) “encourage, facilitate, and promote 

commercial space launches and 

reentries by the private sector.”401

In 1995, AST was transferred to the 

FAA, where the office continues to 

both promote commercial space and 

ensure compliance with regulations 

for all launch and reentry operations 

conducted on U.S. soil and abroad 

by U.S. companies. 

Working with the U.S. Air Force, AST 

codified the military’s best practices 

into common safety standards for 

commercial companies. The resulting 

“big, fat book of regulations” was 

added to the list of requirements the 

COTS commercial partners needed 

to comply with in order to launch 

their ISS demonstration missions.402

Although these regulations might 

be seen as an additional burden, 

according to Dr. George C. Nield, 

FAA Associate Administrator for 

AST, the FAA also helped new 

companies by providing a known 

regulatory environment that could 

be accounted and planned for in 

companies’ business plans.403 For 

more established companies such 

as Orbital, employees were already 

accustomed to the licensing process, 

as it had become part of their regular 

launch routine.404

Regulations

Any private entity launching from 

the U.S., or any U.S. company 

conducting launches abroad, is 

required to demonstrate that the 

operation will not “jeopardize public 

health and safety, or safety of 

property” in order to receive either 

a launch or reentry license, an 

experimental permit, or an operator’s 

license.405 These regulations apply 

only to launch and reentry safety. 

That is, they are intended to protect 

the general public and property on 

the ground only, not any human 

participants of any potential suborbital 

or orbital flights.

The requirement for COTS partners to 

obtain launch licenses from the FAA 

was understood from the beginning of 

the initiative, and was reflected in both 

COTS announcements. During the 

competition, an engineer from the FAA 

reviewed potential partners’ licensing 

plans, and “let NASA know whether 

the company had already started 

discussions with the FAA.”406
86 CHAPTER 6 – COLLABORATION

Limiting the number of regulations for 

the private sector was a deliberate 

strategy designed to encourage the 

incipient commercial spaceflight 

sector. The 2004 Commercial Space 

Launch Amendments Act updated the 

legislation signed 20 years prior and 

included a “learning period” from 2004 

to December 2012 that limited the 

FAA’s ability to impose regulations for 

crew and spaceflight participants.407

In February 2012, Congress extended 

this moratorium until October 2015.408

Since 1988, the U.S. government 

has also provided indemnification 

to commercial providers of launch 

services. In the case of an accident, 

the company will be only financially 

liable for what has been determined 

through the licensing process as 

“maximum probable loss.” Any further 

amount will be the responsibility 

of the U.S. government.409 Both 

government indemnification and 

the moratorium on regulations are 

intended to encourage the industry 

and make U.S. companies more 

competitive internationally, and 

in theory will be phased out as 

commercial launch companies gain 

more experience in space operations. 

Promoting 

Commercial Space

In addition to regulating launch 

and reentry operations, the 

second half of the FAA Office of 

Commercial Spaceflight’s mandate 

is to encourage and promote the 

commercial spaceflight sector. 

Nield has continued AST’s mission 

by, among his other duties, attending 

numerous commercial spaceflight 

and NewSpace conferences to 

meet with industry. Other activities 

that AST conducts to promote 

the commercial spaceflight sector 

include: hosting meetings of the 

Commercial Space Transportation 

Advisory Committee (COMSTAC), 

holding an annual Commercial 

Space Transportation Conference, 

publishing economic impact studies 

and launch forecast reports, and 

reaching out to potential launch 

license applicants.410

Nield explained, “We don’t ever 

compromise safety, but if you look at 

the encourage/facilitate/promote role, 

we’re trying to listen and understand 

what kinds of policies or activities the 

government is doing that are turning 

out to be obstacles to the industry.”411

By maintaining and encouraging 

open lines of communication with 

industry representatives, Nield was 

able to earn the trust of commercial 

companies and overcome any initial 

suspicions they may have had about 

working with a government agency. 

As with its work with the ISS 

Program, C3PO’s collaboration 

with the FAA proved pivotal to the 

success of COTS. The cooperative, 

partnership philosophy of both the 

ISS Transportation Integration Office 

and the FAA Office of Commercial 

Spaceflight mirrored the COTS 

approach to working with the 

commercial sector—enforcing safety 

where necessary, but also remaining 

cognizant of the need to critically 

examine rules and regulations.

NASA and the Federal Aviation Administration (FAA) have partnered to enable American 

industry to provide the government and private-sector customers with safe, reliable, and 

cost-effective transportation to low-Earth orbit. (Left) Dr. George Nield, FAA Associate 

Administrator for Commercial Space Transportation, and Charlie Bolden, NASA 

Administrator, both participated in the 2012 Commercial Space Transportation Conference.

Credit: George Nield
CHAPTER 7 – FIRST STEPS TOWARD COMMERCIAL CREW 87 chapter 7

First Steps Toward 

Commercial Crew

Commercial Crew Development

Commercial Crew Program
88 CHAPTER 7 – FIRST STEPS TOWARD COMMERCIAL CREW

Following the same pattern as 

the two COTS competitions, on 

10 August 2009, NASA issued the 

Commercial Crew Development 

(CCDev) Announcement for potential 

industry partners interested in 

entering into funded Space Act 

Agreements to develop the 

vehicles and technologies needed 

for crew transportation. C3PO 

also began formulating draft 

requirements and standards for 

commercial crew safety.413

Of the 36 companies that submitted 

proposals by the September 22 

deadline, 18 made it through the 

Step 1 evaluation screening, including 

HMX Inc., a name familiar from 

NASA’s Alternate Access to Station 

effort in 2000. 

Eight were then selected as finalists 

to continue to the next step of due 

diligence: Ball Aerospace, Blue Origin, 

The Boeing Company, Paragon Space 

Development Corp., Sierra Nevada 

Corp., Space Exploration Technologies 

Corp. (SpaceX), United Launch 

Alliance (ULA), and XCOR Aerospace. 

For Selection Authority Geoffrey 

L. Yoder, discriminating factors 

included whether or not the 

proposal would advance technology 

for crew transportation within the 

approximately one-year timeframe 

of the agreement, as well as 

companies’ connections to other 

members of industry. 

“By engaging with potential customers 

early in development, there is a 

higher likelihood that its development 

activities will contribute to accelerating 

a commercial crew transportation 

capability,” Yoder wrote in his 

Selection Statement.414 For example, 

multiple companies’ proposals 

relied on ULA’s rockets to launch 

their vehicles and would be ULA 

customers, indicating a promising 

market for the launch provider. 

Yoder also looked for “tangible test 

or demonstration missions,” and 

aimed to include a variety of different 

types of technology systems in the 

selection portfolio.415 NASA sought 

to encourage the development of 

capabilities widely applicable to a 

range of spacecraft. 

Based on these criteria, on 

December 8, 2009, five companies 

were selected for funded Space 

Act Agreements. As in the COTS 

program, these awards were 

to be paid in increments upon 

the successful completion of 

the agreements’ predetermined 

milestones. The largest award 

went to the Sierra Nevada Corp., 

which received $20 million for the 

With the development of ISS cargo delivery services underway, in 2009 the 

Commercial Crew & Cargo Program Office (C3PO) moved forward with the 

development of the technologies needed for commercial crew transportation. 

C3PO was allocated $50 million of stimulus funds from the 2009 American 

Recovery and Reinvestment Act “to support efforts within the private sector 

to develop system concepts and capabilities that could ultimately lead to the 

availability of commercial human spaceflight services.”412

Commercial Crew 

Development
CHAPTER 7 – FIRST STEPS TOWARD COMMERCIAL CREW 89

development of the Dream Chaser 

spacecraft, the only proposed lifting 

body system. The Dream Chaser 

was originally developed by COTS 

competitor SpaceDev, Inc., which 

Sierra Nevada acquired in 2008. 

Next, Boeing received $18 million 

to develop the Crew Space 

Transportation (CST)-100 capsule. 

NASA cited Boeing’s “experience as 

a systems integrator and its previous 

work on the NASA human spaceflight 

program,” as one of the reasons for 

the company’s selection.416 Yoder 

interpreted Boeing’s use of the 

existing Atlas V rockets as a strength, 

but in the COTS Round 2 competition 

that took place in 2008, Selection 

Authority Richard Gilbrech saw this as 

a weakness because Boeing would 

be dependent on an external supplier.

ULA, a joint venture between Boeing 

and Lockheed formed in December 

2006, received $6.7 million for an 

Emergency Detection System for 

human rating its launch vehicles. 

Blue Origin, a startup founded by 

Amazon.com, Inc. mogul Jeff P. 

Bezos, was awarded $3.7 million for 

its “pusher” Launch Abort System 

and composite pressure vessels. 

Finally, Paragon Space Development 

Corp. received $1.4 million for a new 

modular Environmental Control and 

Life Support System.417

According to the CCDev Space Act 

Agreements that were signed by 

Yoder on January 30, 2010, all the 

companies’ milestones were originally 

scheduled for completion by August 

of that year, giving participants a 

little over half a year to pursue their 

development programs. 

C3PO brought in two additional 

project executives to monitor and 

support these new commercial 

partners. Scott D. Gahring, aided by 

his Assistant Project Executive Stokes 

McMillan, served as the NASA Project 

Executive for Blue Origin and Sierra 

Nevada. Donald W. Totton served 

as the NASA Project Executive for 

Boeing, Paragon, and ULA, and later 

continued to support the Agency’s 

commercial initiatives in the Systems 

Engineering and Integration Office of 

the Commercial Crew Program.

In February and March 2010, all 

the CCDev SAAs were amended 

to accommodate a three-month 

extension of the milestone completion 

dates. Sierra Nevada and Paragon 

completed their last milestones 

in December 2010, and Boeing 

completed its last milestone in 

February 2011. 

Both the Blue Origin and Boeing 

SAAs were further amended to 

extend the deadline for completion 

of their CCDev milestones to April 

30, 2011. C3PO Manager Alan J. 

Lindenmoyer signed the ULA letter 

of completion on April 5, about three 

weeks before the deadline, and 

Blue Origin had one uncompleted 

milestone remaining when its SAA 

expired at the end of the month.418

With this first step toward the 

development of key technologies 

needed for future crew transportation 

systems successfully completed, the 

Agency was ready to proceed with its 

program to support more full-scale 

development of commercial crew 

vehicles. These five companies now 

had the opportunity to participate in 

the CCDev2 competition announced 

in October 2010 and awarded in April 

2011. CCDev2 marked a change 

in strategy for NASA’s commercial 

endeavors, as the Agency elected 

to administer its future commercial 

programs from the Kennedy Space 

Center (KSC) in Florida.

Sierra Nevada 

Blue Origin

Boeing CST

United Launch Alliance

Paragon Space Development

Five companies (above) entered into 

funded NASA Space Act Agreements 

for Commercial Crew Development 

(CCDev). As with the COTS program, 

incremental funding was paid based 

upon the successful completion of 

predetermined milestones. 
90 CHAPTER 7 – FIRST STEPS TOWARD COMMERCIAL CREW

Commercial 

Crew 

Program

The new Commercial Crew 

Program (CCP) was established 

at KSC “to help the aerospace 

industry in the United States develop 

space transportation systems that 

can safely launch astronauts to 

the International Space Station 

(ISS) and other low-Earth orbit 

destinations.”419 CCP began with two 

follow-on commercial programs—

Commercial Crew Development 2 

(CCDev 2) and Commercial Crew 

integrated Capabilities (CCiCap). 

The KSC-based office applied some 

of the model first enacted by C3PO, 

including the use of funded Space Act 

Agreements, as well as partnerships 

with multiple, competing companies. 

In April 2011, CCDev 2 split $270 

million between Boeing ($92.3 million), 

Sierra Nevada ($80 million), SpaceX 

($75 million), and Blue Origin ($22 

million) for further development of 

their crewed systems. In August 

2012, for the CCiCap Space Act 

Agreements NASA narrowed these 

four competitors to three: Boeing 

($460 million), SpaceX ($440 million), 

and Sierra Nevada ($212.5 million).420

However, reasoning that carrying 

humans, not just cargo to ISS was 

of a fundamentally different nature, 

the Commercial Crew Program 

at KSC chose to utilize traditional 

procurements contracts in addition 

to SAAs. In December 2012, NASA 

awarded Certification Products 

Contracts (CPC) to Boeing, Sierra 

Nevada, and SpaceX, in the amount 

of approximately $10 million each.421

These FAR-based contracts ensured 

that NASA was able to provide what 

it deemed the necessary oversight 

for the safety of crewed systems. So 

although NASA has retained some 

elements of the model established 

by the COTS team at JSC, in other 

areas it has found the need to revert 

to more traditional means of working 

with the private sector.

NASA anticipated that the resulting 

commercial crew “space taxi” services 

would be available by 2017.422

The crewed variant of the SpaceX Dragon 

will have a capacity for seven seats and is 

being designed with an advanced launch 

escape system. The company has plans 

for a propulsive landing system to allow 

for a gentle touchdown to the ground.

Kathryn Lueders, Acting Program Manager for NASA’s Commercial Crew Program (CCP), 

answered questions during an event held by CCP partner Boeing. Prior to this position, 

Lueders worked closely with the C3PO team while she served as manager of the ISS 

Program’s Transportation Integration Office, responsible for the commercial cargo resupply 

missions to the International Space Station. She was also responsible for integration of the 

international partner vehicles traveling to the ISS. In her current role, Lueders oversees the 

NASA CCP helping private companies to develop a new U.S. capability to carry astronauts 

into low-Earth orbit and to eventually take crews to the International Space Station. 

Developed by the Sierra Nevada 

Corporation, the Dream Chaser will launch 

vertically on an Atlas V rocket and 

automatically land horizontally on a runway. 

The reusable lifting-body spacecraft is 

designed to carry a crew of up to seven 

people to and from low-Earth orbit.

Boeing’s Crew Space Transportation 

(CST)-100 spacecraft floated to a 

landing during a parachute drop test at 

the Delamar Dry Lake Bed near Alamo, 

Nevada. The CST-100 is designed to 

transport people and cargo to the ISS.

Credit: NASA/Robert Markowitz

Credit: SpaceX Credit: Sierra Nevada Corp.

Credit: Boeing
CHAPTER 8 – LEGACY 91 chapter 8

Legacy

From Contingency to Dependency

The COTS Model: A New Way

Conclusion
92 CHAPTER 8 – LEGACY

At the time of the first COTS award 

in 2006, Agency officials at NASA 

Headquarters in Washington, 

DC, envisioned that commercial 

companies would take over lowEarth orbit transportation services 

as a part of the overarching Vision 

for Space Exploration. Announced 

in January 2004, this Vision put the 

nation on a path of exploration to the 

Moon, then on to Mars, with NASA 

building powerful spacecraft for a 

new program called Constellation. 

Included in the plan was a relatively 

small piece of NASA’s mission: “to 

pursue commercial opportunities for 

providing transportation and other 

services supporting the International 

Space Station and exploration 

missions beyond low-Earth orbit.”424

NASA Administrator Michel Griffin 

allocated only $500 million, spread 

over five years, of the Agency’s 

After eight years of operations, the NASA Commercial Crew & Cargo Program 

Office (C3PO) at the Johnson Space Center (JSC) succeeded in inaugurating 

a new era in spaceflight. With its Commercial Orbital Transportation Services 

(COTS) initiative, C3PO demonstrated that the space agency could rely on 

non-government providers for safe, reliable, and cost-effective cargo delivery 

services to and from the International Space Station.

From 2005 to 2013, C3PO acted as an investor and advisor with three separate 

and distinct companies: Space Exploration Technologies Corp. (SpaceX) (from 

2006 to 2012), Rocketplane Kistler (from 2006 to 2007), and Orbital Sciences 

Corp. (from 2008 to 2013). Although Rocketplane Kistler was unable to complete 

its milestones, both SpaceX and Orbital developed space transportation systems 

capable of resupplying the International Space Station (ISS) after Space Shuttle 

retirement. Less than a year after the last Shuttle flight, the first cargo transported 

by a U.S. commercial provider arrived at the ISS.

In addition to these needed ISS resupply services, the COTS program 

saved taxpayer funds. While the space agency invested a total of about 

$788 million in partners’ development programs, industry provided the 

majority of funds (approximately $1 billion) for the two new launch vehicles, 

automated cargo carriers, and ground systems that resulted from the 

government-industry collaboration. 

The partnerships also provided a boost to the nation’s economy by creating 

jobs in the commercial space sector and enabled the U.S. to recapture a share 

of the global launch market. For the companies, the spacecraft developed as 

a result of the agreements gave them the opportunity to capitalize on potential 

new markets.

“The commercial space industry will be an engine of 21st century American 

economic growth and will help us carry out even more ambitious deep space 

exploration missions,” said NASA Administrator Charles F. “Charlie” Bolden. 

“America’s best days in space exploration are ahead of us thanks to the grit 

and determination of those in government, and the private sector, who dare to 

dream big dreams and have the skills to turn them into reality.”423

From Contingency 

to Dependency
CHAPTER 8 – LEGACY 93

multi-billion dollar budget for the 

COTS program. Griffin intended 

that the vehicles developed under 

this initiative would help provide ISS 

resupply at the end of the Space 

Shuttle program. Because of the 

relatively small allocation, members 

of C3PO at JSC saw that COTS 

was somewhat “off the radar” for 

many policy makers in Congress. 

They understood the development 

of commercial transportation 

capabilities as a “side bet” or “back 

burner” option for ISS resupply.425

In other words, COTS was a “highrisk” contingency being pursued 

as a backup for the vehicles being 

developed under Constellation 

or the Agency’s international partner 

cargo resupply vehicles.426

However, by the spring of 2011, NASA 

reported to Congress that the Agency 

was “depending on our commercial 

cargo partners. We need their 

COTS development efforts to succeed 

so that they can begin providing 

cargo resupply to the International 

Space Station.” In simple terms, 

the commercial cargo providers were 

“too important to fail.”427

Although there is no clear consensus 

on when exactly Congress began 

to take more notice, team members 

cited mounting delays within the 

Constellation Program as bringing 

greater attention to the COTS 

program and its objectives.428

The Commercial Resupply Services 

(CRS) contracts awarded in 

December 2008 were another 

contributing factor. Under the terms 

of the CRS contracts, Orbital was 

awarded a contract worth $1.9 billion 

to deliver 8 flights of cargo to ISS. 

SpaceX was awarded a contract 

worth $1.6 billion for 12 CRS delivery 

flights using its capsule-shaped 

Dragon spacecraft.

Then, President Barack H. Obama, 

inaugurated in January 2009, steered 

U.S. space policy on a different 

course by cancelling the Constellation 

Program in February 2010 and 

placing significantly more emphasis on 

commercial space activities. Obama 

directed Bolden, the new NASA 

Administrator, to lead a program that 

would send astronauts to an asteroid 

by 2025 instead of returning to the 

Moon, and facilitate the emergence of 

a commercial space industry.

A few years later the Obama 

administration policy was 

reemphasized in a statement released 

by the White House Office of Science 

and Technology Policy: “The growing 

potential of America’s commercial 

space industry and NASA’s use of 

public-private partnerships are central 

to President Obama’s strategy to 

ensure U.S. leadership in space 

exploration while pushing the bounds 

of scientific discovery and innovation 

in the 21st century.”429

President Barack Obama toured the SpaceX processing facility in Cape Canaveral, 

Florida, along with founder and CEO of the company (right) Elon Musk, in April 2010. 

On that trip, the President also spoke at the NASA Kennedy Space Center where he 

delivered remarks on the new course his administration was charting to maintain U.S. 

leadership in human spaceflight. In his speech, the President emphasized partnerships 

with the private sector to “make getting to space easier and more affordable.”

Credit: NASA/Bill Ingalls
94 CHAPTER 8 – LEGACY

Utilization of 

the International 

Space Station

The U.S. segment of the ISS was 

officially designated a National Lab in 

the NASA Authorization Act of 2005, 

and since then both Congress and 

NASA have emphasized maximizing 

the Station as a scientific research 

platform once assembly was 

completed in May 2011. The COTS 

commercial partners have become 

“essential to ensuring the capacity 

to ferry experiments to and from the 

Station” with their new low-Earth orbit 

transportation systems.430 All current 

and planned U.S. experiments 

aboard the Station will be facilitated 

in some way by a CRS mission and a 

COTS partner.431

ISS Transportation Integration 

Office Manager Kathryn L. Lueders 

reflected on how the SpaceX Dragon 

spacecraft has been able to not 

only transport additional supplies 

to Station—graduating from more 

basic internal pressurized cargo to 

the addition of external pressurized 

items and powered units for storing 

scientific experiments and samples—

but also return some of these back 

to Earth. By the fourth CRS mission, 

SpaceX planned to transport live 

mice and rats to Station, a capability 

not available on existing Progress, 

ATV, or HTV vehicles.432

Former ISS Program Manager 

Randolph H. Brinkley similarly 

applauded the Station’s new 

capabilities for scientific inquiry. 

In fact, Brinkley cited his concern 

for the scientific utility of the 

ISS without reliable up- and 

downmass capability as one of 

the primary reasons he joined the 

Rocketplane Kistler venture as its 

president. He stated that this 

is “a gap that’s just now being 

closed” after the retirement of the 

Space Shuttle in July 2011.433

In addition to using the commercial 

vehicles for NASA experiments, 

advocates of this new way of doing 

business, including William H. “Bill” 

Gerstenmaier, NASA’s Associate 

Administrator for Human Exploration 

and Operations, stated how the ISS 

can serve as a gateway market for 

private science customers to follow.434

Stimulating the 

Commercial Use 

of Space 

In August 2011, NASA signed a 

cooperative agreement with the Center 

for the Advancement of Science in 

Space (CASIS), tasking the nonprofit 

to manage non-NASA research on 

the ISS. CASIS is now working to find 

commercial opportunities for Station 

by marketing the Station’s capabilities 

to the science community and 

using the organization’s established 

contacts to “match investors and 

researchers.”435 Proposals submitted 

for Station must meet both scientific 

and economic criteria, i.e., market 

viability—the same dual criteria used 

to select the COTS commercial 

partners. NASA has also collaborated 

with NanoRacks, a venture that has 

been successful selling small payload 

accommodation on, and small satellite 

launches from ISS.436

Ideas for commercial research 

on ISS have focused particularly 

on pharmaceuticals research that 

can benefit from microgravity 

experiments, such as new vaccines 

and learning from changes in gene 

expression that occur in space.437

Gerstenmaier foresaw a future in 

which these experiments aboard 

Station became so valuable that all 

low-Earth orbit activities were funded 

by pharmaceutical companies, freeing 

NASA to explore beyond.438

NASA also has announced plans 

to expand the International Space 

Station itself in the near future. 

In January 2013, NASA signed a 

contract with Bigelow Aerospace, 

founded by Budget Suite Hotels 

executive Robert T. Bigelow, to 

develop an inflatable space habitat 

that is scheduled to begin a twoyear trial attached to ISS as early as 

2015. Bigelow contracted SpaceX 

to launch the Bigelow Expanded 

Activity Module (BEAM) on a Falcon 

rocket.439 As the market in low-Earth 

orbit matures, commercial space 

companies have begun buying 

services from one another.

Lori Garver, NASA Deputy Administrator, 

and Robert T. Bigelow, President and 

founder of Bigelow Aerospace stood next 

to the mock-up of the Bigelow Expandable 

Activity Module (BEAM) during a media 

briefing on January 16, 2013. At this 

event, Garver announced that NASA 

had awarded a $17.8 million contract to 

Bigelow Aerospace to provide a prototype 

of the expandable habitat to be added 

on the ISS for a two-year technology 

demonstration. The expandable habitat 

is scheduled to arrive at the International 

Space Station in 2015.

Credit: NASA/Bill Ingalls
CHAPTER 8 – LEGACY 95

Free-Fliers in 

Low-Earth Orbit

Phil McAlister, NASA Director 

of Commercial Spaceflight 

Development, observed that the 

government’s investment resulted 

in “two low-cost launch vehicles, 

two autonomous spacecraft 

capable of delivering cargo and 

two privately developed launch 

facilities,” providing a “very 

robust U.S. domestic cargo 

transportation capability.”440

The COTS partners plan to use 

this newly-developed capability 

to offer microgravity services to 

the pharmaceutical industry and 

other markets in addition to the 

ISS. SpaceX has marketed the 

DragonLab free-flier variant of its 

orbital spacecraft to customers in 

the science community to house 

experiments in microgravity.441

Orbital officials have seen possibilities 

for using the Cygnus capsule to sell 

“hosted payloads” to NASA and 

other government scientists. (In its 

current form, Cygnus can only send 

data back to Earth because the 

capsule is destroyed upon reentry to 

Earth’s atmosphere.) Potential Orbital 

customers include researchers at 

the NASA Glenn Research Center 

studying how fire behaves in zero 

gravity conditions.442

According to Robert T. “Bob” 

Richards, Orbital Vice President 

of Human Spaceflight Systems, 

the company also looked into the 

potential to use components of 

the Cygnus capsule for “adjacent 

markets,” for example utilizing the 

rendezvous sensors and technology 

for eventual satellite servicing.443

The COTS 

Model: A 

New Way

The COTS model developed and 

successfully executed by C3PO 

has proven an example of a new 

way for how NASA can cooperate 

with private industry. In addition to 

providing the space agency with 

a needed service to fulfill its mission 

to the ISS, innovative partnerships 

can benefit the government by 

achieving maximum return on 

investment from taxpayer funds. 

Key features of the COTS model 

include limited NASA oversight, a 

flexible and streamlined acquisition 

process, and fixed-price incentives to 

hold cost and schedule. Lindenmoyer 

expanded on these and other key 

features of this form of public-private 

partnerships in a white paper that is 

included in the Appendix.

Return on Investment

In 2011, NASA Deputy Administrator 

Lori B. Garver emphasized how the 

Agency was “working to invest the 

Nation’s valuable tax dollars to assure 

a healthier, more competitive industrial 

base ... while creating new markets, 

new industries, and new jobs in order 

to advance our national security and 

economic future.”444

Both the SpaceX and Orbital lowEarth orbit transportation systems 

were developed with a total NASA 

COTS investment of just $788 million 

($500 original funding plus $288 

million fiscal year 2011 augmentation). 

C3PO achieved maximum use of its 

limited budget by allocating over 93 

percent of funds to partner milestone 

payments, with the rest dedicated 

to program management, technical 

support, and overhead. 

And, by the end of the COTS 

program, NASA had provided less 

than one half of the cost for the 

commercial transportation systems’ 

development and demonstration, as 

seen in the figures below. Note that 

the government investment for Orbital 

includes funding sources other than 

COTS that were contributed toward 

the launch and ground facilities at 

Wallops Island, VA.445

The NASA Air Force Cost Model 

(NAFCOM) estimate for the cost to 

develop the SpaceX Falcon 9 vehicle, 

based on the NASA environment 

and culture, ranged from as low 

SpaceX COTS Orbital COTS

Government

$396M

47%

SpaceX

$454M

53%

Government

$425M

42%

Orbital

$590M

58%

Government funding sources provided less than one half of the cost for the development 

and demonstration of two commercial transportation systems.
96 CHAPTER 8 – LEGACY

SpaceX completed its milestones for the COTS partnership with its C2+ mission, 

launched on May 22, 2012, from Cape Canaveral, Florida. Since then, SpaceX has 

captured a share of the global satellite launch market using the Falcon 9 developed 

under COTS.

as $443 million to as high as 

approximately $4 billion.446 However 

the final cost for developing and 

demonstrating the Falcon 9 rocket 

was only about $400 million—up to 

10 times less than projected.447

Lisa P. Price, ISS Resources Branch 

Chief at JSC, reported that NASA was 

then able to acquire these U.S.-based 

cargo transportation services at a 

significantly lower cost than previous 

Space Shuttle flights.448

In a June 2009 report, the 

Government Accountability Office 

commended C3PO for its responsible 

use of government monies. 

Particularly noted was the very 

small percentage of the program’s 

budget applied to management and 

overhead. The report also found that 

C3PO “adhered to critical project 

management tools and activities,” 

describing how the COTS program 

did a creditable job of identifying, 

documenting, and mitigating risks; 

communicating with the commercial 

partners and providing them technical 

expertise; and by adhering to the 

established system of fixed-price 

milestone payments.449

Job Creation

The development of U.S.-based 

space transportation systems 

funded by the over $1 billion of 

combined government and industry 

funding of COTS encouraged job 

and economic growth in the domestic 

aerospace industry. For instance, 

in just one day in January 2013 

SpaceX hired 90 new employees at its 

Hawthorne, California headquarters.450

In July 2013, the Silicon Valley 

Business Journal reported that 

Credit: SpaceX
CHAPTER 8 – LEGACY 97

SpaceX was looking for 200 additional 

employees to complement its 3,000 

member team.451

On the East Coast, the Mid-Atlantic 

Regional Spaceport (MARS) utilized 

by Orbital Sciences Corp. for the 

launches of its Antares rocket has 

been credited for significant economic 

impact, as part of the overall Virginia 

space industry that “contributes 

$7.6 billion in annual direct economic 

output and directly supports 29,638 

jobs.”452 Maryland Senator Barbara 

A. Mikulski estimated that the Orbital 

missions to deliver cargo to ISS 

would bring 500 additional jobs to 

the Eastern Shore.453

Launch Markets

From its inception, one of the 

objectives of COTS was to “create 

a market environment in which 

commercial space transportation 

services are available to government 

and private sector customers.”454

As Sumara Thompson-King, NASA 

Deputy General Counsel, explained, 

“We didn’t view COTS as just 

supporting NASA. We thought 

that there would be other entities, 

both in the government and in the 

commercial sector, that would use 

those services.”455

While the space agency remains 

the only customer of low-Earth orbit 

delivery services, both SpaceX and 

Orbital have been able to sell launch 

services to customers outside NASA 

and the government.456

The question of U.S.-based launch 

capability was an important one 

for Marc G. Timm, COTS Program 

Executive at NASA Headquarters, 

Credit: NASA/Bill Ingalls

Orbital Sciences Corp. launched its Antares rocket and Cygnus cargo spacecraft 

towards the International Space Station on September 18, 2013, from the Mid-Atlantic 

Regional Spaceport, NASA Wallops Flight Facility, Virginia. In addition to providing 

commercial logistics to ISS, Antares is a new launch vehicle to help the United States 

compete in the global launch services market.
98 CHAPTER 8 – LEGACY

who observed that the availability 

of commercial rockets has allowed 

the U.S. “to become more globally 

competitive in the launch market.”457

Timm observed that the United 

States dominated the launch 

market in the 1980s, but by 2011 

the U.S. government was the only 

purchaser of domestic launch 

services. The availability of the 

SpaceX Falcon and Orbital Antares 

rockets has the potential to bring 

some of those launches back to 

the U.S., along with some satellite 

manufacturing capabilities that have 

been outsourced in order to avoid 

the complications of dealing with 

U.S. International Traffic in Arms 

Regulations restrictions.458

As evidence of the growing domestic 

launch market, SpaceX has found 

both military and commercial 

customers for its Falcon 9 launch 

services—even prompting Europeanbased Arianespace to increase the 

lift capacity of its Ariane rocket to 

make it more cost competitive.459

The Pentagon’s $900 million award of 

indefinite-quantity, indefinite-delivery 

contracts to Lockheed, Orbital, and 

SpaceX made headlines in December 

2012, as a significant contract 

awarded to the COTS partners.460

In addition to this military contract, 

Orbital hopes to find new customers 

for Antares, particularly those that 

previously would have used the 

phased-out Delta II rocket. The 

company has also contracted 

secondary launch payloads on 

Antares missions to ISS.461

Both COTS commercial partners reached their goal of providing cargo transportation 

systems that could resupply the ISS. (Top photo) In May 2012 the Dragon spacecraft 

launched on the SpaceX Falcon 9, separated from the rocket, then traveled to the 

International Space Station, where it was grappled and berthed to the Harmony node 

on May 25. (Bottom photo) Sixteen months later, Orbital Sciences Corp. launched 

its Antares rocket on September 18, 2013 with the Cygnus cargo capsule that moved into 

a low-Earth journey to the ISS. The cargo vehicle was berthed to the International Space 

Station 11 days later, staying 3 weeks before being released. The deliveries signified the 

end of the COTS agreements; now, both companies use the systems built under COTS to 

bring supplies to the ISS as part of NASA’s Commercial Resupply Services contracts.
CHAPTER 8 – LEGACY 99

Conclusion

Throughout the first five decades 

of the U.S. space program, the 

space transportation systems NASA 

depended on to pursue its goals 

of exploration were owned and 

operated by the government. Space 

policy analyst Jeff Foust observed 

that, “For a long time ... we’ve seen 

a lot of promises and PowerPoint 

presentations about proposed 

(private) spacecraft,” continuing, 

“Now we’re seeing those PowerPoints 

turn into actual hardware.”462

Only time will tell if this most recent 

surge of promising activity in the 

private spaceflight sector will 

produce the much-awaited thriving 

commercial space transportation 

industry. However, there are some 

indicators pointing to an optimistic 

future. Anticipating the commercial 

space industry’s growing momentum, 

Embry-Riddle Aeronautical University 

offered the first degree program in 

Commercial Space Operations in 

the fall of 2013.463 And, a report by 

the Space Foundation stated that 

the world space economy grew 6.7 

percent from 2011 to 2012, especially 

in the area of commercial space 

infrastructure and support.464

With this initial success achieved, the 

direction of commercial enterprise 

in space still contains unforeseen 

market potential. As Harvard 

Business School professor Clayton 

M. Christensen observed in his 

book The Innovator’s Dilemma, “Not 

only are the market applications for 

disruptive technologies unknown at 

the time of their development, they 

are unknowable.”465 What is known 

at this stage is that COTS has played 

an important and demonstrable role 

in the burgeoning commercial space 

transportation market. 

In its 2013 Annual Report, the NASA 

Aerospace Safety Advisory Panel 

(ASAP) led by Vice Admiral Joseph W. 

Dyer, USN (Ret.) included statements 

emphasizing the success of the COTS 

program. The report pointed out that 

it “was not simply the use of fixedprice Space Act Agreements that led 

to the Program’s success, although 

that helped to enable the successful 

outcome. Rather, NASA did a number 

of things right along the way, such 

as maintaining excellent program 

management, appointing well-qualified 

technical representatives [as project 

executives], providing the right amount 

of insight, requesting the right amount 

of information, and having the right 

number of Government attendees at 

industry meetings.”466

Calling the COTS program “extremely 

successful,” the ASAP agreed that 

while it would not be appropriate for 

every government program to use a 

COTS-type management philosophy, 

“we would encourage NASA (and 

other Government agencies) to 

consider adopting similar approaches 

where possible.”467

NASA Headquarters acknowledged 

this new way of business by revising 

NASA Policy Directive (NPD) 1000.5, 

the Policy for NASA Acquisition, to 

recognize the role that partnerships 

can play in meeting the space 

agency’s mission needs. This new 

approach required NASA to “consider 

the full spectrum of acquisition 

approaches,” including procurement, 

grants, cooperative agreements, and 

Space Act Agreements.468 NASA 

has also taken steps to establish 

a Partnership Integration Council, 

chaired by the Deputy Administrator, 

to foster consistent guidance, 

governance, and processes across 

the Agency when considering new 

industry partnerships.469

Building on the successful legacy of 

COTS, in early 2014, NASA’s Human 

Exploration and Operations Mission 

Directorate began several initiatives 

to continue partnerships with the 

commercial space industry, including 

Lunar Cargo Transportation and 

Landing by Soft Touchdown (Lunar 

CATALYST) opportunities to spur 

commercial cargo transportation 

capabilities to the surface of the moon, 

and Collaborations for Commercial 

Space Capabilities (CCSC) to help 

pioneer paths to Mars and other deep 

space destinations.

Though not complete, commercial 

space advocates have witnessed a 

“victory” in the NASA cultural change 

in progress.470 In the words of NASA 

Deputy Administrator Lori B. Garver, 

NASA is “like a big ship and we don’t 

turn easily, but when we do it’s also 

hard to turn back. This program, 

while just a teeny-tiny fraction of our 

budget, has caused a shift in Agency 

thinking, and hopefully the thinking of 

all of us about how we’re going to go 

forward in space.”471

Said Lindenmoyer, “NASA knows 

all too well there will be failures and 

setbacks ahead. But we also know 

that through the trusted partnerships 

we have forged with our industry 

colleagues, problems will be solved 

and a new era in commercial space 

will begin.”472
100 CHAPTER 8 – LEGACY

Three months after the last COTS demonstration mission, SpaceNews printed the above editorial, calling 

COTS a success and stating that the two partners were “well on their way to securing the program’s 

legacy as a winner for both government and industry.”473 The figure of $850 million includes the total of 

approximately $800 million received for the COTS cargo demonstrations, plus the $50 million allocation 

for the Commercial Crew Development (CCDev) Program.

Volume 24, Issue 49
APPENDIX 101 appendix

Appendix

Acknowledgments

COTS Model for NASA Public-Private Partnerships

Chronology

COTS Oral History Interviews

Bibliography

Endnotes
102 APPENDIX

Acknowledgments

NASA Commercial Crew & Cargo Program Office (C3PO) 

acknowledges and thanks the following for providing 

the use of images for this publication: Gary C. Hudson, 

Alan Marty, George Nield, Boeing, Orbital Sciences 

Corporation, Sierra Nevada Corp., SpaceX, 

Thales Alenia Space. Also, from C3PO Team members: 

Alan Lindenmoyer, Valin Thorn, Dennis Stone, 

Mark Erminger, Warren Ruemmele, and Kevin Meehan. 

Photo credit is noted on images; all others are from a 

NASA imagery repository. 

C3PO thanks Perry Jackson of the JSC Graphics 

group for his design of this book; and to John 

Bretschneider and Todd Hegemier for their assistance 

in gathering information.
APPENDIX 103

COTS Model for 

NASA Public-Private 

Partnerships

Alan Lindenmoyer

Manager, Commercial Crew & Cargo Program

April 18, 2010

Background

In 2004, President Bush established the U.S. Space 

Exploration Policy which called for a return to the moon 

by 2020 and the Space Shuttle to be retired by the end 

of 2010 after completion of the International Space 

Station (ISS) assembly. Since the shuttle was planned 

to provide routine crew rotation and cargo resupply 

services throughout the service life of the station, this 

led to a shortfall of ISS resupply capabilities and a gap 

in U.S. human spaceflight. The Progress, HTV, and ATV 

International Partner cargo transportation capabilities 

were no longer sufficient to meet the logistics needs of 

the station and the ISS would become dependent on the 

Russian Soyuz vehicles for crew rotation and rescue until 

the Constellation vehicles became operational.

Soon after Mike Griffin became the new NASA 

Administrator in 2005, he challenged U.S. private industry 

to develop cargo and eventually crew space transportation 

capabilities that could meet the needs of the ISS. The 

Administrator established the Commercial Crew & Cargo 

Program Office (C3PO) at JSC under the Exploration 

Systems Mission Directorate (ESMD) and allocated $500 

million over five years to stimulate the development 

and demonstration of commercial capabilities. Once 

demonstrated, NASA would purchase the emerging 

services to meet the U.S. obligations for servicing the ISS 

soon after the shuttle was retired in 2010.

Introduction

For over 50 years NASA has been the vanguard of 

human spaceflight. From the first flights of Mercury to a 

permanent presence on the International Space Station, 

NASA and its industry partners have pioneered some of 

the greatest accomplishments in history. The resulting 

technology spinoffs coupled with American ingenuity and 

entrepreneurial opportunities have transformed our world. 

These spinoffs are typically what come to mind when one 

speaks of the commercialization of space technology. 

But we have not seen the growth of the commercial 

space transportation industry as we have with the first 

50 years of commercial aviation. The commercial space 

communications sector has grown into a thriving multibillion dollar industry and we have purchased commercial 

launch vehicles and payload services for many years 

now. The transportation of people to space remains an 

ambitious goal only achieved by governments due to 

extreme cost and risk barriers.

Since NASA blazed the trail for human spaceflight and 

the technology exists, the question becomes can industry 

capitalize on this opportunity if NASA seeds the market 

with funding to reduce the cost barrier and offers the 

space station as a predictable and reliable market for 

the transportation services? Perhaps with a substantial 

Government investment, NASA experience, and the 

promise of follow-on contracts, the industry will grow 

similarly to what was seen in the late 19th and early 20th 

centuries with railroads and aviation.

The premise of what became known as Commercial 

Orbital Transportation Services, or COTS, is different than 

the commercialization of a NASA technology transfer. 

COTS challenges American industry to develop, own, and 

operate their own space transportation systems that could 

be suitable for use by NASA and other customers. NASA 

would define the needs and safety expectations of the 

transportation service, but commercial companies would 

define the concept of operations and all of the detailed 

requirements and specifications for the entire system 

including ground operations, launch, orbital operations, 

reentry, and recovery. NASA would become a true partner 

in the commercial venture to provide specific expertise, 

lessons learned, and other requested information. We would 

also make our vast infrastructure of facilities and laboratories 

available on a marginal cost reimbursable basis.

The purpose of this paper is to define what is meant by 

commercial in the context of a space transportation system 

acquisition and the key features of what became the COTS 

model for NASA public-private partnerships.

U.S. Space Laws and Policies

Since it was NASA’s intent to ultimately purchase 

commercial transportation services, as opposed to a 

Government developed capability, the C3PO acquisition 

planning team researched the Federal Acquisition 

Regulations (FAR) and other U.S. laws and policies for 

guidance on how to structure the acquisition. The key 

findings from this research are as follows. 
104 APPENDIX

According to the Commercial Space Act of 1998, 

...the Federal Government shall acquire space transportation 

services from U.S. commercial providers whenever such services 

are required in the course of its activities.

 ...space transportation services shall be considered to be a 

commercial item. 

The law allows exceptions to these requirements if the 

Administrator determines that... 

(1) a payload requires the unique capabilities of the 

Space Shuttle;

(2) cost effective space transportation services that meet 

specific mission requirements would not be reasonably available 

from United States commercial providers when required;

(3) the use of space transportation services from United 

States commercial providers poses an unacceptable risk of 

loss of a unique scientific opportunity;

(4) the use of space transportation services from United 

States commercial providers is inconsistent with national 

security objectives;

(5) the use of space transportation services from United 

States commercial providers is inconsistent with international 

agreements for international collaborative efforts relating to 

science and technology;

(6) it is more cost effective to transport a payload in conjunction 

with a test or demonstration of a space transportation vehicle 

owned by the Federal Government; or 

(7) a payload can make use of the available cargo space on 

a Space Shuttle mission as a secondary payload, and such 

payload is consistent with the requirements of research, 

development, demonstration, scientific, commercial, and 

educational programs authorized by the Administrator.

These exceptions allowed NASA to use the Space 

Shuttle and International Partner vehicles for servicing the 

ISS throughout the assembly phase. However, with the 

promise of emerging new U.S. commercial capabilities, 

the Administrator determined that these exceptions may 

no longer apply after the ISS construction is completed 

and the shuttle is retired. This law defines U.S. commercial 

providers to be more than 50% owned by U.S. nationals 

or a subsidiary of a foreign company subject to certain 

conditions determined by the Secretary of Transportation.

The team then turned to the FAR which defines a 

commercial item to mean ...

(1) Any item, other than real property, that is of a type 

customarily used by the general public or by non-governmental 

entities for purposes other than governmental purposes, and— 

(i) Has been sold, leased, or licensed to the general public; or 

(ii) Has been offered for sale, lease, or license to the 

general public; 

(2) Any item that evolved from an item described in 

paragraph (1) of this definition through advances in technology 

or performance and that is not yet available in the commercial 

marketplace, but will be available in the commercial 

marketplace in time to satisfy the delivery requirements 

under a Government solicitation; 

(3) Any item that would satisfy a criterion expressed in 

paragraphs (1) or (2) of this definition, but for— 

(i) Modifications of a type customarily available in the 

commercial marketplace; or 

(ii) Minor modifications of a type not customarily 

available in the commercial marketplace made to meet 

Federal Government requirements. Minor modifications 

means modifications that do not significantly alter the 

nongovernmental function or essential physical characteristics 

of an item or component, or change the purpose of a 

process. Factors to be considered in determining whether a 

modification is minor include the 

value and size of the modification and the comparative value 

and size of the final product. Dollar values and percentages 

may be used as guideposts, but are not conclusive evidence 

that a modification is minor; 

(Note: only items 1-3 were excerpted here for brevity.)

The FAR Part 12 goes on to prescribe the procedures for 

the acquisition of commercial items which includes the 

use of firm-fixed price contracts and other provisions to 

streamline the acquisition process.

The Commercial Space Launch Act (as amended in 2004) 

is also relevant to commercial space acquisitions. The 

purpose of this law is...

(1) to promote economic growth and entrepreneurial activity 

through use of the space environment for peaceful purposes; 

(2) to encourage the United States private sector to provide 

launch vehicles, reentry vehicles, and associated services by - 

(A) simplifying and expediting the issuance and transfer of 

commercial licenses; 

(B) facilitating and encouraging the use of Governmentdeveloped space technology; and 

(C) promoting the continuous improvement of the safety 

of launch vehicles designed to carry humans, including 

through the issuance of regulations, to the extent permitted 

by this chapter; 

(3) to provide that the Secretary of Transportation is to oversee 

and coordinate the conduct of commercial launch and reentry 

operations, issue permits and commercial licenses and transfer 

commercial licenses authorizing those operations, and protect 

the public health and safety, safety of property, and national 

security and foreign policy interests of the United States; and 

(4) to facilitate the strengthening and expansion of the United 

States space transportation infrastructure, including the 

enhancement of United States launch sites and launch-site 

support facilities, and development of reentry sites, with 

Government, State, and private sector involvement, to support 

the full range of United States space-related activities.

Item 3 is a key aspect of this law since historically most 

NASA missions were declared to be carried out by and for 

the Government and not subject FAA licensing.

Other important national policies and law include the U.S. 

Space Transportation Policy of 2005 which emphasizes use 

of launch vehicles manufactured in the U.S.; the National 

Space Policy of 2006 which reiterates U.S. commitment 

to encouraging and facilitating a growing entrepreneurial 
APPENDIX 105

U.S. commercial space sector; and the Iran, North Korea, 

and Syria, Nonproliferation Act (INKSNA) which restricts 

the purchase of Russian space systems supporting the ISS 

(restrictions currently waived through July 2016).

These laws and policies form the governing framework that 

must be addressed when planning any commercial space 

acquisition for NASA.

Acquisition Approach

The acquisition team determined that the cargo or crew 

transportation services needed to service the ISS were 

not yet available in the marketplace as a commercial item 

from U.S. commercial providers. Although launch services 

have been sold to the general public for many years, the 

additional capabilities necessary to deliver payloads to and 

from a human destination in low-Earth orbit (LEO) were 

not yet offered for public sale. The necessary complex 

technologies such as automated rendezvous and docking 

among other things, were under development and test, 

but were not at the maturity level needed to be purchased 

under a firm-fixed price commercial service contract.

At this point the team decided to pursue the acquisition 

of commercial space transportation capabilities in two 

phases. The first phase would be a period of development 

and demonstration to enable and accelerate advances in 

technology such that the emerging capabilities could evolve 

and become available in time to satisfy the Government 

needs. This would then meet the second condition for the 

definition of a commercial item as described in the FAR 

definition above and enable the subsequent purchase of 

services in a follow-on second phase.

In the first phase, NASA decided to take on the role of an 

investor, technical consultant, and partner instead of a 

traditional Government customer that pays full development 

costs and fees to a prime contractor. Since NASA did not 

intend to purchase any goods or services in the first phase 

of the program, the C3PO used NASA’s other transaction 

authority in the form of funded Space Act Agreements 

(SAA) as the optimal legal instrument to provide financial 

and technical resources to commercial companies. 

As the mission of the program became clear, the C3PO 

established the following three major program objectives: 

1) implement Space Exploration policy with investments to 

stimulate the commercial space industry, 2) facilitate U.S. 

private industry demonstration of cargo and crew space 

transportation capabilities with the goal of achieving safe, 

reliable, cost effective access to low-Earth orbit, and 3) 

create a market environment where commercial services 

are available to Government and private sector customers. 

The vision would extend human presence in space by 

enabling an expanding and robust U.S. commercial space 

transportation industry. If successful, NASA’s expanded 

vision and mission to reduce the cost of access to space 

could open new markets and seed a vibrant and thriving 

new industry for the long term benefit of all Americans. 

Of course NASA would also directly benefit by freeing up 

encumbered resources that could be refocused on the 

more difficult challenges of human exploration beyond LEO.

After receiving positive and constructive feedback from 

industry endorsing the proposed new acquisition approach, 

the C3PO conducted COTS competitions where companies 

could bid on the development and demonstration on any 

combination of the following four basic space transportation 

capabilities to service a human destination in LEO. 

Capability A: the delivery and disposal on unpressurized/

external cargo, B: the delivery and disposal on pressurized/

internal cargo, C: the delivery and return of pressurized/

internal cargo, and D: crew transportation. In order to fund 

the maximum number of companies possible with the 

limited funds available, NASA required the demonstration of 

cargo capabilities before crew. The crew proposals would 

become options to the SAA should NASA receive additional 

funding and elect to exercise the option at some later 

time. The demonstrations would culminate with an orbital 

flight demonstration of the selected capabilities. The ISS 

was offered as a test bed and orbital destination for these 

capabilities if companies chose to meet the ISS visiting 

vehicle requirements. In addition to financial payments 

based on the successful achievement of pre-negotiated 

milestones, companies awarded SAAs would also receive 

NASA technical expertise to assist with ISS integration and 

share knowledge, experience, and lessons learned over our 

50 years of human spaceflight.

The resulting funded SAAs represent a new way of doing 

business with the private sector. The COTS model for 

public-private partnerships is fundamentally different than 

traditional Government contracting in many ways. Since the 

outcome cannot be assured, it has advantages and risks 

that must be carefully assessed before a determination 

is made on whether or not this approach is suitable for a 

specific acquisition. 

Features of the COTS Space 

Act Agreements

Most of the terms and conditions of the COTS SAAs were 

specially crafted to optimize the commercial development 

nature of the agreements for the mutual benefit of NASA 

and the commercial partners. The ability to customize 
106 APPENDIX

the agreements for this specific purpose is perhaps the 

single largest advantage of the SAA. But NASA must first 

determine that no other legal instrument including, but not 

limited to; procurement contracts, grants, and cooperative 

agreements are appropriate for the stated purpose. The 

primary purpose of the COTS agreements is to stimulate 

the commercial space industry to develop and demonstrate 

innovative, cost effective space transportation capabilities. 

The agreements are for demonstrations and not for the 

acquisition of goods or services. 

The key features and advantages of the COTS SAAs 

are as follows:

1) Enables a portfolio investment in multiple, diverse 

commercial partners.

The investment in this context is analogous to the risks 

versus rewards inherent in any financial portfolio. As 

in most financial investments, there is no guarantee 

that a return will be provided, but a diversified portfolio 

increases the chances of a positive outcome over time. 

NASA’s strategy in COTS was to enable the ability to 

fund a range of companies including large, established 

companies representing lower technical risk balanced 

by small or emerging companies with higher risk. The 

expectation was that if successful, the higher risk 

companies could result in a transformational payoff by 

offering significantly lower service prices. A balanced 

portfolio would also allow NASA a greater chance to 

invest in multiple companies since NASA’s contribution 

to the development costs for small companies would 

likely be less than that required of large businesses. 

Funding the maximum possible number of companies 

was a key risk mitigation strategy in COTS since it 

is common in high risk ventures that only the best 

and strongest companies will survive and succeed. 

Companies were selected based on NASA’s level of 

confidence in their ability to meet both the technical 

goals as well as the execution of their business plan. 

In contrast, FAR contracts are typically evaluated and 

scored based on the degree to which companies 

meet a definitive set of requirements as well as past 

performance and cost. This would most likely favor 

companies with lower overall risk and those with a 

history of doing business with Government. 

2) Leverages NASA investment with additional company 

provided capital.

The COTS SAAs require that NASA not be the 

only source of funding necessary to complete the 

demonstrations. As with most new business ventures, 

companies typically seek financial investors or approval 

to apply corporate research and development funds 

to bring a product to market. NASA learned to think 

like an investor when soliciting and evaluating the 

COTS proposals. A successful venture requires a 

company to have a solid value proposition, a strong 

business case, and the financial and intellectual capital 

necessary to be the first to market or capture a share 

of an existing market. We expected companies to have 

“skin in the game” in order for us to share the cost risk 

as a lead investor. The degree to which companies 

were willing and credibly able to contribute financially 

to the demonstrations was an important factor in the 

selection. The selected COTS companies committed 

several hundred million dollars in addition to NASA’s 

funding which further enabled our ability to invest in 

multiple companies. 

3) Enables known/limited cost risk using pay for 

performance milestones.

The COTS SAAs utilize a series of pre-negotiated 

milestones as the sole basis for performance evaluation 

and incremental payments. Upon award, NASA agreed 

to pay up to a fixed maximum amount over the life of 

the agreement thereby establishing a known and limited 

financial risk. The SpaceX SAA includes 22 milestones 

for payments totaling up to $278M. The Orbital SAA 

includes 19 milestones totaling up to $170M. The 

milestones measure key progress events throughout 

the design and development cycle and are typically 

spaced at least one per quarter. The milestones include 

a clear and concise description of the event, objective 

success criteria, and a planned completion date to 

enable an easy assessment of technical and schedule 

progress. Payments are made after NASA determines 

that the milestone was completed in accordance with 

the established success criteria. This clear and simple 

payment process avoids subjective cost and fee 

evaluations and simplifies fiscal year budget planning. 

More importantly, since NASA’s contribution is capped 

at a pre-negotiated maximum limit, any overrun at any 

point in the project becomes the responsibility of the 

commercial partner. NASA’s milestone payments remain 

fixed regardless of the actual costs incurred by the 

company. Regarding schedule delays, the milestones 

were initially defined as events only but completion 

dates were added during negotiations so a planning 

baseline could be established. According to the terms 

of the SAA, once a milestone is missed, NASA must 

ascertain the cause of the failure and determine if 

additional efforts are in the Government’s best interest. 

Delays in completing the milestones are not sufficient 

cause for termination as long as NASA determines that 
APPENDIX 107

reasonable progress is being made. It should also be 

noted that NASA recognized the schedules proposed 

by the COTS partners were extremely aggressive and 

delays would be expected.

4) Mitigates cost impacts due to evolving requirements.

One of the most elegant features of a funded SAA 

partnership in a design and development environment 

is that the system requirements are permitted to evolve 

and mature without the constant administration of 

contract change orders and equitable adjustments. 

Since NASA only provided top level system performance 

goals and objectives, representative of one customer’s 

needs for such services, this allowed companies to 

freely innovate and optimize their system throughout 

the design cycle. Instead of constantly evaluating and 

independently analyzing system performance against 

detailed design requirements and specifications NASA 

typically applies on a contract, NASA monitors the 

progress of the design to assure that the system is 

being built and tested in accordance with the original 

scope of the agreement. Even the ISS safety and 

interface requirements have evolved over time with 

mutual agreement. Since the inception of the SAAs, 

NASA has processed over 70 changes to the COTS 

Interface Requirements Document (IRD) without a single 

dollar of equitable adjustment. The reason for this is 

commercial companies volunteered to meet the IRD 

in their COTS proposal. The ISS was offered, but not 

required to be used as the orbital flight destination. 

Companies serious about producing a transportation 

system with NASA as a reliable customer took on the 

challenge of meeting the ISS requirements for the best 

possible opportunity to be awarded a lucrative service 

contract. Also over these last four years, the SAAs were 

only modified six times to document mutually agreeable 

content changes, again without any adjustment in total 

payments. It is highly doubtful that NASA would be 

able to achieve the flexibility of implementing these type 

changes without cost adjustments under a contract.

5) Enables streamlined/flexible acquisition process.

Government acquisitions under the FAR are designed 

to assure federal funds are awarded fairly and are 

disbursed in strict accordance with a contract terms and 

conditions. The regulations typically require contracts 

to contain certain standard clauses regarding specific 

reporting requirements and deliverables, systems to 

validate contractor costs, and other paperwork and 

processes to provide the necessary and appropriate 

controls on such a massive system. NASA is one 

of the few organizations in the Government granted 

other transaction authority to enter into agreements 

outside the FAR. If and only when no other instrument 

is deemed appropriate, NASA can utilize this authority 

to carry out its mission. Because the use of SAAs was 

deemed most appropriate for COTS partnerships, this 

has allowed NASA to streamline the acquisition and 

execution process. Reducing some of the so called 

“red tape” and other requirements for doing business 

with the Government has leveled the playing field. 

The COTS competitions were structured such that 

large, established companies with a long history of 

Government contracts could compete equally and fairly 

with small, even startup emerging companies who have 

little or no experience with Government acquisitions. 

For example, instead of evaluating a company’s past 

performance on similar work, NASA focused on the 

skills and demonstrated abilities of the management 

team proposed to lead the effort. While still assuring 

federal funds are awarded fairly and are disbursed under 

strict control, the flexibility of the SAAs enabled each 

step of the process to be specially tailored. This resulted 

in decreased overhead costs to both the Government 

and the commercial partner and a streamlined 

acquisition schedule. 

6) Simplifies program management/oversight with objective 

milestone success criteria.

Because the milestones listed in the SAAs are the sole 

basis for monitoring progress and making payments 

to the commercial partner, this greatly simplifies and 

streamlines program management. The C3PO employs 

only 14 direct and matrixed personnel to oversee 

and manage the two COTS SAAs and five recently 

awarded Commercial Crew Development SAAs which 

also used the COTS model. These include program /

project managers and deputies, program integration, 

safety, procurement, financial, and administrative 

personnel. Additional insight is gained during informal 

day to day communications with the partners as 

well as more formal quarterly program management 

reviews, but the official basis for assessing progress 

and making payments are the SAA milestones. The 

milestones form the basis for NASA’s limited program 

oversight responsibilities. The program also budgets 

for approximately 10 additional FTE to provide specific 

technical expertise as needed from the NASA centers 

and procured program technical support.

7) Minimum requirements encourage innovation 

and enables reduced/appropriate level of NASA 

oversight/insight.
108 APPENDIX

NASA holds ourselves accountable for the validation 

and verification of each and every requirement we 

impose on our contractors. Many thousands of 

requirements are typically invoked on any complex 

space system development. Ultimately, NASA certifies 

that the requirements have been met to our satisfaction 

and the system is ready for its mission. This system 

of checks and balances provides us with the highest 

assurance of mission success but at the expense 

of a large workforce, cost, and schedule. Indeed it 

is this experience and expertise behind each of our 

requirements that make up the incredible workforce 

NASA employs today. The COTS model seeks to 

minimize the firm system performance requirements 

leaving the commercial partner responsible for the 

flow down and verification of most all requirements. 

By sharing our needs as a primary, but not necessarily 

the only customer early on, commercial partners are 

free to optimize their systems to best fit their business 

case. Because the level of insight is driven by our 

mutual goal of helping the partnership succeed, 

NASA is able to closely manage and prioritize the 

level of technical support we provide. The ISS safety 

and interface requirements are an exception to this 

approach. The closure of ISS requirements requires 

close oversight and must be verified by NASA to 

the same extent as any of our other contracted 

requirements. Even so, ISS requirements number into 

the hundreds, not thousands and NASA is able to 

accomplish the necessary oversight function with a 

much smaller number of people.

8) Maximizes incentive to hold cost and schedule.

Since COTS payments are made only after the 

successful completion of a defined milestone, 

companies are required to raise the capital necessary 

to accomplish the work up front. This approach builds 

in an automatic incentive for companies to complete 

the effort on or under cost and as soon as possible so 

they can be reimbursed and move forward to the next 

milestone. COTS companies are also highly incentivized 

to hold cost and schedule because of our strategy to 

invest in multiple companies. This engages the engine 

of competition where companies strive to offer the best 

value and capture a share of existing markets or create 

new markets as soon as possible.

9) Commercial friendly intellectual/physical property and 

data rights.

The COTS SAAs include special provisions for 

minimal Government retention, licensing, and use of 

intellectual property developed by companies under 

the agreements. Similarly, the Government will not take 

title to property acquired or developed using funding 

provided under the agreement. These provisions assure 

companies will retain the benefit of their investment and 

further encourages the development of the commercial 

space industry. If however, the agreements are 

terminated for failure to perform, NASA may exercise all 

rights to property and data.

10) Limited termination liability.

Unlike most contracts, NASA may not unilaterally 

terminate the agreements for the convenience of the 

Government. In other words NASA cannot walk away 

from the agreement except for reasons that are beyond 

our control (such as failure of Congress to appropriate 

sufficient funding). Likewise, the commercial partners 

are obligated to meet the terms and conditions of 

the agreements or they will be terminated for failure 

to perform. If the Government is forced to unilaterally 

terminate, the maximum financial liability shall not exceed 

the total amount of the next milestone. The agreements 

also allow for mutual agreement to terminate if ever 

needed. These limited termination provisions were found 

to be very important and advantageous to companies 

seeking additional outside investments.

11) FAA licensing/liability/indemnification/enforcement.

The COTS flight demonstrations are not NASA missions 

carried out by and for the Government and therefore fall 

under the FAA licensing regulations. The FAA is directed 

by law to encourage and promote entrepreneurial space 

activity and is further directed to simplify and expedite 

the issuance of licenses. This determination relieves 

NASA from conducting our launch oversight of these 

missions and prepares the companies for follow-on 

commercial space transportation services under the 

FAA regulations.

Lessons Learned

1) In October 2007, NASA terminated its $207 million 

SAA with Rocketplane Kistler (RpK) for failure to meet 

milestones just over a year after award. RpK committed 

to raise an additional $500 million in order to complete 

the development and demonstration of its K1 reusable 

launch vehicle but was unable to close the necessary 

rounds of financing. NASA recognized the risk 

associated with raising this large amount of capital and 

purposely limited the initial milestones until the funding 

was secured. RpK completed the first three milestones 
APPENDIX 109

and received $32 million in payments. As the program 

was designed to do, the termination was conducted 

swiftly resulting in minimum financial and schedule loss. 

Within four months, NASA conducted a second round 

competition and awarded the remaining $170 million to 

Orbital Sciences Corporation.

RpK informed NASA that the primary reason they were 

unable to complete the financing was because NASA 

could not guarantee or even commit to the follow-on 

ISS resupply service contract. Investors in the financial 

markets were simply not willing to take on this high 

risk venture without an assured return on investment. 

They recognized NASA was the only reliable customer 

for these services since other markets have had 

limited development and have yet to materialize. This 

concern was expressed by most companies seeking 

outside or corporate investment when NASA received 

RFI responses from industry in preparation for the ISS 

Commercial Resupply Services contracts. 

Therefore, given that the requirement for additional 

company investment is an important part of this form 

of partnership, NASA should not expect companies 

to raise funds from financial markets unless we 

are willing to commit to purchase their services. 

The transition from development partnerships to 

operational service contracts is important to any 

future acquisition planning using this approach. NASA 

should consider ways to assure selected partners will 

be offered follow-on contracts if they are successful in 

demonstrating their capabilities.

2) Another lesson learned from COTS is that NASA does 

not have the statutory authority to provide Government 

Furnished Equipment (GFE) under the SAA. Even 

though GFE for certain rendezvous and proximity 

operations equipment was contemplated in the original 

agreements, transferring this equipment has been 

problematic. Conversely, NASA also does not have the 

authority to receive deliverables from the partner under 

the SAA. For example, NASA was unable to accept 

additional UHF Communications Units developed 

by SpaceX for ISS proximity communications with 

commercial spacecraft. The additional units were to 

be provided in exchange for other associated NASA 

services and could have been used for the Orion 

project or perhaps other visiting vehicles.

Therefore, NASA should clearly identify and list the 

hardware and software deliverables that are necessary 

to be exchanged prior to signing the initial agreement. 

Alternatively, NASA should seek legislation or determine 

an appropriate legal way to accommodate such 

equipment transfers under a SAA.

3) NASA saw significant growth in service prices from 

those projected in the COTS proposals to those 

finally negotiated in the CRS contracts. Some of the 

growth may be due to additional requirements in the 

contracts. Another factor may be that the systems 

were matured since the initial proposals and the 

pricing was more accurately reflective of the actual 

costs incurred and projected costs to complete. Since 

the prices projected in the COTS proposals were not 

binding, future evaluation teams should consider the 

large uncertainty range in these prices if they are used 

as part of the selection criteria. Also, NASA should 

carefully plan the point in the development cycle 

when a Request for Proposals for service contracts is 

issued. Ideally, NASA should wait until the capability is 

demonstrated, but this would likely result in an 18-24 

month gap before an operational mission is flown due 

to vehicle production lead time. Conversely, issuing 

RFPs too early will lead to inaccurate price projections 

and perhaps schedule delays and penalties due to 

unexpected development issues.

Summary

The COTS model for public-private partnerships has 

paved the way for the procurement of commercial space 

transportation services. What started as an unknown 

experiment four years ago has resulted in a new medium 

class launch vehicle poised to launch in the days ahead, 

another under construction and soon ready for test, and 

a sure promise of two highly advanced cargo carrying 

spacecraft planned to visit the space station in the year 

ahead. This was made possible because NASA was willing 

to risk $500 million as a bold lead investor confident in 

its commercial partners. This strategic investment was 

significant enough to break through the barriers to entry 

in this extremely difficult and risky business, yet modest 

enough to be affordable and fiscally responsible. NASA 

knows all too well there will be failures and setbacks ahead. 

But we also know that through the trusted partnerships we 

have forged with our industry colleagues, problems will be 

solved and a new era in commercial space will begin.
110 APPENDIX

Chronology

1800s – 1900s

1863 – 1869 Construction of the First 

Transcontinental Railroad

1925 Contract Air Mail Act (Kelly Act)

1958 NASA founded 

Federal Aviation Administration (FAA) founded

1970s and 1980s

1979 First Joint Endeavor Agreement

4/12/1981 First Space Shuttle launch (STS-1)

1982 Reagan’s National Space Policy

4/1982 Orbital Sciences Corp. founded

9/1984 NASA Office of Commercial 

Programs established

10/30/1984 Commercial Space Launch Act

1/28/1986 Challenger disaster

8/15/1986 Commercial payloads banned from Shuttle

1990s

11/5/1990 Launch Services Purchase Act

1993 Kistler Aerospace Corp. founded

2/1995 Report of the Space Shuttle Management 

Independent Review Team (Kraft Report)

10/28/1998 Commercial Space Act of 1998

6/1999 Decadal Planning Team formed

2000s 

2001 – 2002 Space Launch Initiative (SLI)

Alternate Access to Space Station (AAS)

2002 SpaceX founded

2/1/2003 Columbia disaster

1/14/2004 Vision for Space Exploration announced

9/2004 Concept Exploration & Refinement Studies

10/4/2004 Ansari X Prize awarded

12/23/2004 Commercial Space Launch Amendments Act

2005

4/25/2005 ISS Commercial Cargo Services Industry Day

10/5/2005 First COTS “kickoff” meeting

10/28/2005 COTS Space Flight Demonstrations 

synopsis released

11/2005 Commercial Crew & Cargo Program Office 

established at JSC 

Exploration Systems Architecture Study 

(ESAS) Final Report

12/5/2005 COTS Draft Announcement released

12/21/2005 JSC Request for Proposal for Venture 

Capitalist Consulting Services

2006

1/18/2006 COTS Round 1 Announcement released

1/25/2006 COTS ISS Integration & Interface 

Requirements Document released

3/3/2006 COTS Round 1 proposals due

5/5/2006 COTS Round 1 finalists selected

7/14/2006 COTS Round 1 negotiations completed

8/18/2006 Space Act Agreements signed with 

SpaceX and Rocketplane Kistler

12/19/2006 COTS Round 1 GAO protest 

successfully defended
APPENDIX 111

2007

1/2007 and 

6/2007 Unfunded Space Act Agreements signed

10/18/2007 Rocketplane Kistler Space Act 

Agreement terminated

10/22/2007 COTS Round 2 Announcement released

11/22/2007 COTS Round 2 proposals due

2008

1/28/2008 COTS Round 2 GAO protest 

successfully defended

2/19/2008 Space Act Agreement signed with 

Orbital Sciences Corp.

5/2008 – 

10/2008 Unfunded Space Act Agreements terminated

9/28/2008 First launch of the SpaceX Falcon 1 rocket

12/23/2008 Commercial Resupply Service (CRS) 

contracts awarded

2009

4/22/2009 CRS protest successfully defended

8/10/2009 Commercial Crew Development (CCDev) 

Announcement released

9/22/2009 CCDev proposals due

10/2009 Report of the Review of United States 

Human Spaceflight Plans Committee 

(Augustine Commission) 

12/8/2009 CCDev selection

2010

2/2010 Constellation Program cancelled

6/4/2010 First launch of the SpaceX Falcon 9 rocket

10/11/2010 NASA Authorization Act of 2010 allocated 

$300 million COTS augmentation funding

12/8/2010 SpaceX C1 demonstration mission 

2012 

5/22/2012 – 

5/31/2012 SpaceX C2+ final COTS 

demonstration mission

10/8/2012 – 

10/28/2012 First SpaceX Cargo Resupply 

Services mission

2013 

4/21/2013 Orbital Sciences Corp. Antares rocket 

demonstration flight

9/18/2013 – 

10/23/2013 Orbital Sciences Corp. final COTS 

demonstration mission

2014

1/9/2014 – 

2/19/2014 First Orbital Sciences Corp. Cargo 

Resupply Services mission
112 APPENDIX

SpaceX COTS Milestones

SpaceX Augmented COTS Milestones

Amended SAA Plan

Actual Completion Date*

Initial SAA Plan

* Actual Completion Date is when NASA verified that the partner completed the milestone.
APPENDIX 113

Orbital COTS Milestones

Orbital Augmented COTS Milestones

Amended SAA Plan

Actual Completion Date*

Initial SAA Plan

* Actual Completion Date is when NASA verified that the partner completed the milestone.
114 APPENDIX

COTS Oral History Interviews

The NASA Johnson Space Center History Office conducted a series of oral history interviews to gather information from key individuals 

involved with the Commercial Crew & Cargo Program. Interviews were conducted by Rebecca Hackler and Rebecca Wright. To access 

the transcripts from the interview sessions, go to the JSC History Portal, http://www.jsc.nasa.gov/history/oral_histories/c3po.htm.

NASA 

Lori Garver NASA Deputy Administrator

Bill Gerstenmaier NASA Associate Administrator, Human Exploration and Operations

Marc Timm NASA HQ COTS Program Executive

Alan Lindenmoyer C3PO Manager

Valin Thorn C3PO Deputy Program Manager

Dennis Stone C3PO Program Integration Manager

Mike Horkachuck C3PO Project Executive – SpaceX

Bruce Manners C3PO Project Executive – RpK, Orbital Sciences 

Lisa Price COTS Financial Team

Kathy Lueders Manager, ISS Program Transportation Integration Office 

HQ Legal Team Mike Wholley, NASA Chief Counsel

Sumara Thompson-King, Deputy General Counsel

Courtney Graham, Associate General Counsel for Commercial and Intellectual Property Law

Karen Reilley, Attorney, Contracts and Procurement

Amy Xenofos Chief Counsel for General Law and External Partnerships, Johnson Space Center

Jon Arena Counsel, Johnson Space Center

Others 

Mike Griffin NASA Administrator, April 2005 - January 2009

Alan Marty Venture Capitalist, Managing Director, Legacy Venture

George Nield Federal Aviation Administration Associate Administrator for Commercial Space Transportation

Brett Alexander Blue Origin, Business Development/Strategy

Jim Muncy President, PoliSpace, co-founder Space Frontier Foundation

SpaceX

Gwynne Shotwell President, Chief Operating Officer

Hans Koenigsmann Vice President of Mission Assurance 

Tim Buzza Vice President of Launch and Test 

David Giger Director, Dragon Propulsion and Product Development 

John Couluris Senior Director, Launch and Mission Operations

Peter Capozzoli Mission Manager

Rocketplane Kistler

Randy Brinkley President

Joe Cuzzupoli Chief Engineer

George French Chief Executive Officer

Orbital Sciences Corp. 

David Thompson President, Chairman, Chief Executive Officer

Antonio Elias Executive Vice President and Chief Technical Officer

Frank Culbertson Executive Vice President and General Manager Advance Programs Group

Bob Richards Vice President of Human Spaceflight Systems

Frank DeMauro Vice President and Program Director COTS/CRS Program (Cygnus)

Mike Pinkston Antares Space Launch Vehicle, Managers

 & Kurt Eberly
APPENDIX 115

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APPENDIX 117

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118 APPENDIX

Endnotes

Introduction

1 Gwynne E. Shotwell, interview by Rebecca Wright, 

January 15, 2013, transcript, Commercial Crew & Cargo 

Program Office History Project, JSC History Collection, 

University of Houston-Clear Lake, Houston, TX (hereafter 

cited as C3PO OHP).

2 David W. Thompson, interview by Rebecca Wright, June 3, 

2013, transcript, C3PO OHP.

3 Michael Griffin, “NASA and the Business of Space” (speech 

made at the 52nd annual conference of the American 

Astronautical Society, November 2005), in Leadership in 

Space: Selected Speeches of NASA Administrator Michael 

Griffin, May 2005–October 2008 (Washington, DC: NASA 

SP-2008-564, 2008), 179, accessed September 30, 2013, 

http://history.nasa.gov/leadership.pdf. 

Chapter 1

4 Wayne Hale and Frank Bauer, “Government Insight/

Oversight for Commercial Crew Transportation,” 

Rev. N, March 2010, 1, accessed September 30, 

2013, http://www.nasa.gov/pdf/469245main_

GovernmentInsightForCommercialCrewTransportation.

pdf. For more on NASA’s early relationships with industry 

see Joan Lisa Bromberg, NASA and the Space Industry 

(Baltimore: John Hopkins University Press, 1999), 45–74. 

5 Bromberg, 115.

6 Ronald Reagan, “Statement on Signing the Commercial 

Space Launch Act,” October 30, 1984. Online by Gerhard 

Peters and John T. Woolley, The American Presidency 

Project, accessed September 30, 2013, http://www.

presidency.ucsb.edu/ws/?pid=39335. For more on Reagan’s 

space policy see Edward Ridley Finch, Jr. and Amanda Lee 

Moore, Astrobusiness: A Guide to the Commerce and Law of 

Outer Space (New York: Praeger, 1984), 56–58.

7 For more on Space Services, Inc. see Bromberg, 116–117 

and David P. Gump, Space Enterprise: Beyond NASA (New 

York: Praeger, 1990), 37–38.

8 For more on the Shuttle privatization proposals of the Space 

Transportation Company (SpaceTran) and Astrotech see 

Bromberg, 134–137.

9 Judy A. Rumerman, comp., “Commercial Programs,” in 

NASA Historical Data Book, vol. 6, NASA Space Applications, 

Aeronautics and Space Research and Technology, Tracking 

and Data Acquisition/Support Operations, Commercial 

Programs, and Resources, 1979–1988 (Washington, DC: 

NASA SP-4012,1999), 355, accessed September 30, 2013, 

http://history.nasa.gov/SP-4012/vol6/ch5.pdf. See also 

Bromberg, 121–124.

10 Bromberg, 128. For more on the Commercial Space Launch 

Act and the formation of AST see Ronald K. Gress, “The Early 

Years, AST – A Historical Perspective,” in 2002 Commercial 

Space Transportation Lecture Series (Washington, DC: 

Office of the Associate Administrator for Commercial Space 

Transportation, April 2003), 2–20, accessed September 30, 

2013, http://www.faa.gov/about/office_org/headquarters_

offices/ast/reports_studies/archives/media/Volume_1.pdf and 

Courtney A. Stadd, interview by Rebecca Wright, January 8, 

2003, transcript, NASA Headquarters Oral History Project, 

JSC History Collection, University of Houston-Clear Lake, 

Houston, TX (hereafter cited as NASA HQ OHP).

11 Bromberg, 153; Gump, 27. For more on Reagan’s 

commercial space policy after Challenger see Bonnie E. 

Fought, “Legal Aspects of the Commercialization of Space 

Transportation Systems,” Berkeley Technology Law Journal 

3 (1988), accessed September 30, 2013, http://www.law.

berkeley.edu/journals/btlj/articles/vol3/fought.html.

12 For more information on concepts for private space modules, 

as well as the ISF and related Congressional hearings, see 

Bromberg, 163–173. See also Stadd, interview. 

13 For more on the SpaceHab, Inc. concept see 

Bromberg, 165.

14 Howard E. McCurdy, Faster, Better, Cheaper: Low-Cost 

Innovation in the U.S. Space Program (Baltimore: John 

Hopkins University Press, 2001), 94.

15 Bromberg, 178; “First private space shuttle unveiled,” BBC 

News, March 2, 1999, accessed September 30, 2013, http://

news.bbc.co.uk/2/hi/science/nature/289106.stm. For more 

on space companies that emerged in the 1990s see Bretton 

Alexander, interview by Rebecca Wright, March 18, 2013, 

transcript, Commercial Crew & Cargo Program Office History 

Project, JSC History Collection, University of Houston-Clear 

Lake, Houston, TX (hereafter cited as C3PO OHP).

16 Bromberg, 181.

17 Ibid., 182.

18 The NASA Space Shuttle and the Reusable Launch Vehicle 

Programs: Hearing before the Subcommittee on Science, 

Technology, and Space, United States Senate, 104th Cong., 

1st sess., May 16, 1995 (statement of John Mansfield, NASA 

Associate Administrator for Space Access and Technology), 

13, accessed September 30, 2013, http://ia700303.

us.archive.org/24/items/hearingonnasaspa1995unit/

hearingonnasaspa1995unit.pdf.

19 Bromberg, 181–183. The Kraft Report asserted that the 

safety procedures instituted after Challenger had become 

excessively cumbersome for efficient Shuttle operations. 

In 1996, following the Kraft Report recommendations, 

NASA awarded the Space Flight Operations Contract 

to United Space Alliance, a joint venture between The 

Boeing Company and Lockheed Martin Corp., to take 

over the majority of consolidated Shuttle operations and 

assess commercial markets. Report of the Space Shuttle 
APPENDIX 119

Management Independent Review Team (Washington, DC: 

NASA, 1995), accessed September 30, 2013, http://www.

fas.org/spp/kraft.htm.

20 Dan Mulville, “Commercial Space Transportation” (Federal 

Aviation Administration), C-SPAN Video Library, February 

10, 1998, accessed September 30, 2013, http://www.cspanvideo.org/program/SpaceTr.

21 For more on the Rotary Rocket Company see McCurdy, 

145–147; “First private space shuttle unveiled”; and Daniel 

R. Mulville, interview by Rebecca Wright, June 13, 2013, 

transcript, NASA HQ OHP.

22 Mulville, “Commercial Space Transportation.”

23 Commercial Space Act of 1998, Public Law 105–303, 105th 

Cong., 2d sess. (October 28, 1998), §201(a), accessed 

February 24, 2014, http://www.nasa.gov/offices/ogc/

commercial/CommercialSpaceActof1998.html. For more on 

the space transportation studies see “NASA Contracts for 

Future Space Transportation Studies,” NASA Headquarters 

Press Release, September 4, 1998, accessed September 30, 

2013, http://www.nasa.gov/home/hqnews/contract/1998/

c98-n.txt; “The Space Launch Initiative: Technology to 

Pioneer the Space Frontier,” Marshall Space Flight Center, 

FS-2002-04-87-MSFC, April 2002, accessed September 

30, 2013, http://www.nasa.gov/centers/marshall/news/

background/facts/slifactstext02.html.

24 NASA EXploration Team, “Charting America’s Course 

for Exploration & Discovery in the Twenty-first Century” 

(PowerPoint presentation). Online by Stephen Garber and 

Glen Asner, “NASA’s Decadal Planning Team and the Policy 

Formulation of the Vision for Space Exploration,” NASA 

History Program Office, accessed September 30, 2013, 

http://history.nasa.gov/DPT/DPT.htm. 

25 “Space Launch Initiative.” 

26 NASA FY 2001 Appropriations: Hearing before the 

Subcommittee on VA, HUD, and Independent Agencies, 

United States Senate, 106th Cong., 2d sess., April 13, 

2000 (statement of Daniel S. Goldin, NASA Administrator), 

5, NASA Headquarters Historical Reference Collection, 

Washington, DC.

27 Government Accountability Office, Space Transportation: 

Challenges Facing NASA’s Space Launch Initiative, GAO02-1020, September 17, 2002, 3, accessed September 30, 

2013, http://www.gao.gov/assets/240/235577.pdf.

28 HMX, Inc. “Alternate Access to Station,” Final Briefing 

NAS8-00172 (PowerPoint presentation, November 

17, 2000), 3. Courtesy of Gary C. Hudson, email 

communication to JSC History Office, March 4, 2013.

29 “Space Launch Initiative”; “Small Companies to Study 

Potential Use of Emerging Launch Systems for Alternative 

Access to Space Station,” NASA Marshall Space Flight Center 

Press Release, August 24, 2000, accessed September 30, 

2013, http://www.nasa.gov/home/hqnews/contract/2000/

c00-g.txt. For a commercial space advocate’s account of SLI 

and AAS see Greg Klerkx, “Back to the Future,” in Lost in 

Space: The Fall of NASA and the Dream of a New Space Age 

(New York: First Vintage Books, 2005), 115–141.

30 Robert T. Richards, interview by Rebecca Hackler, June 

4, 2013, transcript, C3PO OHP. See also Antonio L. Elias, 

interview by Rebecca Hackler, June 3, 2013, transcript, 

C3PO OHP.

31 The concepts developed under the Space Launch Initiative 

also contributed to Marshall’s follow-on Orbital Space Plane 

crew rescue and transfer vehicle project. See “OSP Facts,” 

Marshall Space Flight Center, FS-2003-05-64-MSFC, May 

2003, accessed September 30, 2013, http://www.nasa.

gov/centers/marshall/news/background/facts/ospfacts.

html. Other commercial initiatives included the Constellation 

Services International (CSI) concept to use a vehicle based 

at the International Space Station for satellite servicing. CSI 

submitted a proposal for the COTS Round 1 competition in 

2006, but was not awarded a Space Act Agreement. James 

A.M. Muncy, interview by Rebecca Wright, June 21, 2013, 

transcript, C3PO OHP.

32 George W. Bush, preface to the Vision for Space Exploration 

(Washington, DC: NASA, February 2004), accessed 

September 30, 2013, http://www.nasa.gov/pdf/55583main_

vision_space_exploration2.pdf; NASA Authorization Act of 

2005, Public Law 109–155, 109th Cong., 1st sess. (Dec. 

30, 2005), §108, accessed September 30, 2013, http://

www.gpo.gov/fdsys/pkg/PLAW-109publ155/pdf/PLAW109publ155.pdf. Emphasis added. 

33 Michael D. Griffin, interview by Rebecca Wright, January 12, 

2013, transcript, C3PO OHP.

34 Muncy, interview; Alexander, interview; Valin B. Thorn, 

interview by Rebecca Hackler, December 17, 2012, 

transcript, C3PO OHP; Lori B. Garver, interview by Rebecca 

Wright, June 26, 2013, transcript, C3PO OHP.

35 Gump, 17.

36 “Taking the Vision to the Next Step,” NASA Feature, October 

5, 2004, accessed September 30, 2013, http://www.nasa.

gov/missions/solarsystem/vision_concepts.html.

37 W. Henry Lambright, “Launching a New Mission: Michael 

Griffin and NASA’s Return to the Moon,” Organizational 

Transformation Series, IBM Center for The Business of 

Government, 2009, 11, accessed September 30, 2013, 

http://www.businessofgovernment.org/sites/default/files/

ReturntotheMoon.pdf; Alexander, interview.

38 Alexander, interview; Gary C. Hudson, email communication 

to JSC History Office, March 4, 2013. For more details on 

the t/Space architecture concept, see Transformational 

Space Corp., “Sustainable Lunar Exploration Requires a 

Competition-Based Open Architecture,” Concept Exploration 

& Refinement BAA (PowerPoint presentation, September 13, 

2004), accessed September 30, 2013, http://www.nasa.gov/

pdf/65852main_tSpace.pdf. 
120 APPENDIX

39 Mark Stucker, “A Preliminary Strategy for Inclusion of 

Innovative Access in NASA ESMD’s Spiral 1 Acquisitions” 

(PowerPoint presentation, December 16, 2004), Commercial 

Crew & Cargo Program Office, Houston, TX.

40 “Space Flight Summary: International Space Station,” NASA 

FY 2005 Budget Summary, EC 5-17, February 3, 2004, 

accessed September 30, 2013, http://www.nasa.gov/

pdf/55411main_28%20ISS.pdf. 

41 “NASA Special Notice: International Space Station 

Commercial Cargo Services,” SpaceRef.com, April 7, 2005, 

accessed September 30, 2013, http://www.spaceref.com/

news/viewsr.html?pid=16081.

42 Valin Thorn, Neil Lemmons, and Matt Scheutz, “ISS 

Commercial Cargo Service: Requirements & Constraints 

Summary” (PowerPoint presentation at ISS Commercial 

Cargo Service Industry Day, Houston, TX, April 25, 2005), 

accessed September 30, 2013, http://ntrs.nasa.gov/archive/

nasa/casi.ntrs.nasa.gov/20060055384_2006256513.pdf. 

See also Thorn, interview.

43 NASA FY 2007 Budget Request, February 6, 2006, 

accessed September 30, 2013, http://www.nasa.gov/

pdf/142458main_FY07_budget_full.pdf. See also Alan 

Lindenmoyer, “Commercial Crew/Cargo Project Strategy 

Briefing” (PowerPoint presentation to NASA Headquarters, 

November 15, 2005), 6, Commercial Crew & Cargo Program 

Office, Houston, TX.

44 “Space Launch Initiative.”

45 Ibid. For more on the perspective and arguments of 

commercial space advocates see Bromberg, 187–190.

46 Oral History Workshop: Commercial Space Policies of the 

1980s, moderated by Woody Kay, November 1, 1999, 

transcript, NASA Headquarters Historical Reference 

Collection, Washington, DC.

47 Conference Report, National Aeronautics and Space 

Administration Authorization Act of 2000, H.R. Rep. 106–

843, 106th Cong., 2d sess., Sept. 12, 2000, 30, accessed 

September 30, 2013, http://www.gpo.gov/fdsys/pkg/CRPT106hrpt843/pdf/CRPT-106hrpt843.pdf.

48 Since the retirement of the Space Shuttle fleet in July 2011, 

the U.S. has relied solely on the Russian Soyuz to transport 

its ISS crew members to and from their long-duration stays 

aboard the orbiting laboratory. Under the original ISS bilateral 

agreements, the Russian Federal Space Agency (Roscosmos) 

provided flights to U.S. astronauts at no cost to NASA through 

the year 2005. At that point, the U.S. Congress needed to 

secure an exemption to the 2000 Iran Nonproliferation Act in 

order to allow the space agency to purchase hardware and/or 

services from Russia, and in January 2006 NASA was able to 

contract with Roscosmos to secure Soyuz flights at the rate of 

$21.8 million per passenger. In less than a decade, the price 

for flights aboard the Soyuz increased exponentially, soaring 

to over three times the amount agreed on in 2006. On 30 April 

2013, NASA signed a contract with Roscosmos to purchase 

rides for its astronauts on the Soyuz through June 2015 at 

a cost of roughly $70 million per seat, a substantial increase 

from the already pricey $63 million of the previous agreement 

signed in 2011. See Frank Morring, Jr. “NASA To Pay Russia 

$424 Million For Six Soyuz Seats,” Aviation Week & Space 

Technology, May 1, 2013, accessed September 30, 2013, 

http://www.aviationweek.com/Article.aspx?id=/article-xml/

asd_05_01_2013_p01-02-575108.xml. 

49 Griffin, interview.

50 “Meet the CIA’s Venture Capitalist,” Bloomberg 

Businessweek, May 9, 2005, accessed September 30, 2013, 

http://www.businessweek.com/stories/2005-05-09/meetthe-cias-venture-capitalist.

51 Bromberg, 51.

52 Griffin, interview.

53 Stucker, “Preliminary Strategy,” 15; Griffin, interview; Scott 

J. Horowitz, interview by Rebecca Wright, March 1, 2013, 

transcript, JSC Oral History Project, JSC History Collection, 

University of Houston-Clear Lake, Houston, TX.

54 Commercial Space Act of 1998, Public Law 105–303, 

105th Cong., 2d sess. (Oct. 28, 1998), §202, accessed 

September 30, 2013, http://www.gpo.gov/fdsys/pkg/PLAW105publ303/pdf/PLAW-105publ303.pdf. 

55 Chris Crumbly and Michelle Bailey, “NASA’s Alternate Access 

to Station Concept” (PowerPoint presentation at the 53rd 

International Astronautical Congress, Houston, TX, October 

10–19, 2002), 2. Marshall Space Flight Center History Office, 

Huntsville, Alabama. Emphasis in the original. See also Alan 

J. Lindenmoyer, interview by Rebecca Wright, October 31, 

2012, transcript, C3PO OHP.

56 Bromberg, 157.

57 Ibid., 157–159. See also Stadd, interview.

58 National Aeronautics and Space Administration Authorization 

Act, Fiscal Year 1991, Public Law 101–611, 101st Cong., 

2d. sess. (November 16, 1990), Title II—Launch Services 

Purchase, §204. 

59 See for example Thorn, interview.

60 Stucker, 5.

61 Griffin, interview.

62 Rumerman, 361.

63 Crumbly and Bailey, 3. 

64 Gump, 22.

65 Surya Gablin Gunasekara, “Other Transaction” Authority: 

NASA’s Dynamic Acquisition Instrument for the 

Commercialization of Manned Spaceflight or Cold War 

Relic?” Public Contract Law Journal 40 (2011): 896.
APPENDIX 121

66 See Lindenmoyer, interview.

67 Crumbly and Bailey, 3 and 13–14. “Disruptive innovation” 

is a term from the 1997 book The Innovator’s Dilemma by 

Clayton M. Christensen. The book’s principles would have a 

significant influence on the COTS program.

68 Crumbly and Bailey, 5 and 10.

69 Stucker, 7.

Chapter 2

70 Alan J. Lindenmoyer, interview by Rebecca Wright, October 

31, 2013, transcript, Commercial Crew & Cargo Program 

Office History Project, JSC History Collection, University of 

Houston-Clear Lake, Houston, TX (hereafter cited as C3PO 

OHP).

71 Michael D. Griffin, NASA FY 2006 Operating Plan letter to 

Congress, February 6, 2006, 8, accessed September 30, 

2013, http://images.spaceref.com/news/2006/2006.02.06.

fy06.plan.griffin.pdf. See also Griffin, interview and Horowitz, 

interview. In the traffic-model analysis of a December 

2006 NASA ISS SPEAR (Strategic Planning Evaluation 

and Resource Analysis) report, future COTS vehicles were 

identified as the primary option for meeting the anticipated 

cargo shortfall after Shuttle retirement. At that time, COTS 

was projected to start resupplying ISS in 2010, while the 

Orion Crew Exploration Vehicle would not be ready until 

2015. International Space Station Program, ISS Strategic 

Planning and Resource Analysis (SPEAR2006), December 

28, 2006, A-20. JSC Library: Scientific and Technical 

Information (STI) Center, Houston, TX.

72 William H. Gerstenmaier, interview by Rebecca Wright, June 

12, 2013, transcript, C3PO OHP. See also Amy V. Xenofos, 

interview by Rebecca Hackler, December 7, 2012, transcript, 

C3PO OHP and Michael C. Wholley, interview by Rebecca 

Hackler, March 19, 2013, transcript, C3PO OHP.

73 Michael J. Horkachuck, interview by Rebecca Wright, 

November 6, 2013, transcript, C3PO OHP. See also Alan J. 

Lindenmoyer, interview and Amy V. Xenofos, interview.

74 Alan Lindenmoyer and Brant Sponberg, “Commercial Crew/

Cargo Project: Status Report to Administrator” (PowerPoint 

presentation, October 19, 2005), 2, Commercial Crew & 

Cargo Program Office, Houston, TX. Some commercial 

advocates argued that piloted crew vehicles would have 

been easier to develop first, rather than the complicated 

automated rendezvous systems required for cargo only. 

Bretton Alexander, interview by Rebecca Wright, March 18, 

2013, transcript, C3PO OHP; Gary C. Hudson, “It’s a Trap! 

Monopsony and NewSpace” (PowerPoint presentation at 

Space Access 2011 Conference, Phoenix, Arizona, April 7–9, 

2011), 5. Courtesy of Gary C. Hudson, email communication 

to JSC History Office, March 6, 2013.

75 Scott J. Horowitz, interview by Rebecca Wright, March 

1, 2013, transcript, JSC Oral History Project, JSC History 

Collection, University of Houston-Clear Lake, Houston, TX.

76 Gerstenmaier, interview.

77 “Alan Lindenmoyer, Manager,” NASA Commercial Crew 

& Cargo Program Office, last modified October 30, 2012, 

accessed September 30, 2013, http://www.nasa.gov/offices/

c3po/about/alindenmoyer.html; Lindenmoyer, interview.

78 For more details on the formulation of the COTS program see 

Marc G. Timm, interview by Rebecca Wright, June 12, 2013, 

transcript, C3PO OHP.

79 Marc Timm, “Commercial Crew & Cargo Program: Program 

Overview” (PowerPoint presentation at Commercial Space 

Transportation Advisory Committee meeting, Washington, DC, 

May 18, 2007), 4, accessed September 30, 2013, http://www.

faa.gov/about/office_org/headquarters_offices/ast/advisory_

committee/meeting_news/media/CCCProgram_TIMMCOMSTAC_%205-16-07.ppt.

80 Timm, interview; Alan Lindenmoyer, “Commercial Crew/

Cargo Transportation Procurement Development Team 

Kickoff Briefing” (PowerPoint presentation at Johnson Space 

Center, Houston, Texas, October 5, 2005), Commercial Crew 

& Cargo Program Office, Houston, TX. 

81 NASA’s Exploration Systems Architecture Study: Final 

Report, NASA-TM-2005-214062, November 2005, i, 

accessed September 30, 2013, http://www.nasa.gov/

pdf/140649main_ESAS_full.pdf; Timm, interview.

82 “A--Commercial Orbital Transportation Services (COTS) 

Space Flight Demonstrations,” NASA Solicitation NASASNOTE-051028-001, originally posted on October 28, 2005, 

accessed September 30, 2013, https://www.fbo.gov/spg/

NASA/JSC/OPDC20220/NASA-SNOTE-051028-001/listing.

html. For Lindenmoyer’s description of the capabilities see 

Lindenmoyer, interview.

83 All capability descriptions from: Commercial Orbital 

Transportation Services (COTS) Demonstrations, 

Announcement Number COTS-01-05, Commercial Crew/

Cargo Project Office, January 18, 2006 (As Amended 

February 17, 2006), A1-A2, accessed September 30, 2013, 

available at http://www.nasa.gov/offices/c3po/about/cots_

demo_competition.html.

84 See Valin B. Thorn, interview by Rebecca Hackler, December 

17, 2012, transcript, C3PO OHP.

85 Jonathan A. Arena, interview by Rebecca Hackler, April 22, 

2013, transcript, C3PO OHP. See also Xenofos, interview and 

Wholley, interview.

86 Sumara M. Thompson-King, Courtney B. Graham, and Karen 

M. Reilley, interview by Rebecca Hackler, March 19, 2013, 

transcript, C3PO OHP. 
122 APPENDIX

87 Wholley, interview. See also Thompson-King, Graham, and 

Reilley, interview and Arena, interview.

88 National Aeronautics and Space Act of 1958 (Unamended), 

Public Law 85-568, 85th Cong., 2d sess. (July 29, 1958), 

§203, accessed September 30, 2013, http://history.nasa.

gov/spaceact.html. Emphasis added. 

89 Xenofos, interview. For more on the use of Other Transaction 

Authority in the Federal government, see Congressional 

Research Service, Other Transaction (OT) Authority, by L. 

Elaine Halchin, RL34760, July 15, 2011, accessed September 

30, 2013, http://www.fas.org/sgp/crs/misc/RL34760.

pdf and Surya Gablin Gunasekara, “Other Transaction” 

Authority: NASA’s Dynamic Acquisition Instrument for the 

Commercialization of Manned Spaceflight or Cold War Relic?” 

Public Contract Law Journal 40 (2011): 894.

90 Xenofos, interview.

91 Joint Sponsored Research Agreements had been used in the 

past to provide funding to outside entities under NASA’s OTA, 

but COTS was the first time funded Space Act Agreements 

had been established as such. NASA Headquarters attorney 

Courtney B. Graham explained that under COTS, the Agency 

was “acting as an arm’s-length investor to stimulate the 

development of that capability, rather than working jointly 

with someone on something that’s of mutual interest to both 

parties.” Thompson-King, Graham, and Reilley, interview. 

92 Oral History Workshop: Commercial Space Policies of the 

1980s, moderated by Woody Kay, November 1, 1999, 

transcript, NASA Headquarters Historical Reference 

Collection, Washington, DC.

93 Dennis A. Stone, interview by Rebecca Hackler, November 

26, 2012, transcript, C3PO OHP.

94 NASA JSC Solicitation: Venture Capitalist Consulting 

Services, Solicitation Number: NNJ06139211R, posted 

December 21, 2005, accessed September 30, 2013, http://

www.spaceref.com/news/viewsr.html?pid=19046.

95 Alan Marty, interview by Rebecca Hackler, January 18, 2013, 

transcript, C3PO OHP.

96 The book’s first edition was published by the Harvard 

School Business Press in 1997 as The Innovator’s Dilemma: 

When New Technologies Cause Great Firms to Fail. For the 

edition referenced in this work see Clayton M. Christensen, 

The Innovator’s Dilemma: The Revolutionary Book That 

Will Change the Way You Do Business (New York: Harper 

Business, 2011). 

97 Marty reported that his original recommendation to Griffin, as 

they discussed the initiative during an informal conversation 

at a White House dinner, was to base the COTS program 

out of the NASA Ames Research Center in Moffett Field, 

California, to remove the program as far as possible from 

the Agency’s traditional human spaceflight culture. However, 

by that point an office had already been established at JSC. 

Marty, interview.

98 Marty, interview; Lindenmoyer, interview.

99 Marty, interview.

100 Michael D. Griffin, interview by Rebecca Wright, January 12, 

2013, transcript, C3PO OHP.

101 Marty, interview. See also Lindenmoyer, interview.

102 Bruce A. Manners, interview by Rebecca Hackler, December 

5, 2013, transcript, C3PO OHP; Dennis Stone, email 

communication to JSC History Office, July 21, 2013.

103 Marty, interview. Around the same time as the first COTS 

award, in September 2006, NASA founded its own venture 

capital firm, Red Planet Capital, to invest in companies 

that were developing technologies that could be of use 

in NASA’s future missions to Mars. The project was shut 

down less than a year later due to concerns about the 

government competing with the private sector. “NASA 

Forms Partnership with Red Planet Capital, Inc.,” NASA 

News Release 06-317, September 20, 2006, accessed 

September 30, 3013, http://www.nasa.gov/home/

hqnews/2006/sep/HQ_06317_red_capital.html; Marc 

Kaufman, “NASA Invests in Its Future With Venture Capital 

Firm,” Washington Post, October 31, 2006, accessed 

September 30, 2013, http://www.washingtonpost.com/wpdyn/content/article/2006/10/30/AR2006103001069.html. 

See also Marty, interview and Thompson-King, Graham, 

and Reilley, interview.

104 National Aeronautics and Space Administration Authorization 

Act of 1985, Public Law 98–361, 98th Cong., 2d sess. (July 

16, 1984), §110(c), accessed September 30, 2013, http://

uscodebeta.house.gov/statutes/1984/1984-098-0361.pdf. 

In 2010 the Space Act was amended so that this phrasing 

was now found in §20102(c). National Aeronautics and 

Space Act, Public Law 111–314, 111th Cong., 2d sess. 

(December 18, 2010), accessed September 30, 2013, http://

www.gpo.gov/fdsys/pkg/BILLS-111hr3237enr/pdf/BILLS111hr3237enr.pdf. 

105 COTS Announcement, COTS-01-05. 

106 Ibid., Also Timm, interview. Joan Lisa Bromberg noted that in 

traditional contract procurements “arrogant” proposals, i.e., 

those that did not strictly conform to government-defined 

Request for Proposal requirements, often resulted in greater 

creativity. Joan Lisa Bromberg, NASA and the Space Industry 

(Baltimore: John Hopkins University Press, 1999), 43.

107 Lindenmoyer, interview.

108 COTS Announcement, COTS-01-05, A21.

109 Marty, interview.
APPENDIX 123

110 According to NASA attorney Amy V. Xenofos, one company 

did in fact propose to, instead of visiting the ISS, launch 

a spent stage to orbit and then dock with it in order to 

demonstrate its low-Earth orbit capabilities. Xenofos, 

interview. See also Manners, interview.

111 COTS Announcement, COTS-01-05, 19.

112 “Valin Thorn, Deputy Manager,” NASA Commercial Crew 

& Cargo Program Office, last modified August 17, 2011, 

accessed September 30, 2013, http://www.nasa.gov/

offices/c3po/about/vthorn.html; Thorn, interview.

113 Valin Thorn, Neil Lemmons, and Matt Scheutz, “ISS 

Commercial Cargo Service: Requirements & Constraints 

Summary” (PowerPoint presentation at ISS Commercial 

Cargo Service Industry Day Conference, Houston, 

TX, April 25, 2005), accessed September 30, 2013, 

http://ntrs.nasa.gov/archive/nasa/casi.ntrs.nasa.

gov/20060055384_2006256513.pdf.

114 Thorn, interview. 

115 Commercial Orbital Transportation Service: ISS Integration & 

Interface Requirements Document, SSP 50784, Version 1.0, 

January 25, 2006, 15, Commercial Crew & Cargo Program 

Office, Houston, TX.

116 Lindenmoyer, interview.

Chapter 3

117 Commercial Orbital Transportation Services (COTS) 

Demonstrations, Announcement Number COTS-01-05, 

Commercial Crew/Cargo Project Office, January 18, 2006 

(As Amended February 17, 2006), accessed September 30, 

2013, available at http://www.nasa.gov/offices/c3po/about/

cots_demo_competition.html. The amendments released 

in February were fairly minor, consisting of clarifications 

regarding instructions for electronic proposal submittal 

(§5.1.3 and §5.1.5) and the use of government-furnished 

equipment (Appendix B). 

118 COTS Announcement, COTS-01-05, 8-9. The requirement 

for U.S. funding would prove to be one of the factors in RpK’s 

failed quest to meet its financial milestones.

119 At the time of the announcement, the Iran and Syria 

Nonproliferation Act prohibited payments to Russia for ISSrelated services after December 2011; on 14 January 2013, 

Congress extended NASA’s waiver from the Iran North 

Korea and Syria Nonproliferation Act (INKSNA), allowing the 

Agency to purchase ISS services from Russia through 2020. 

Space Exploration Sustainability Act, Public Law 112-273, 

112th Congress, 2d sess. (January 14, 2013), §4, accessed 

September 30, 2013, http://www.gpo.gov/fdsys/pkg/

PLAW-112publ273/pdf/PLAW-112publ273.pdf. 

120 Dennis Stone, email communication to JSC History Office, 

July 15, 2013.

121 Valin B. Thorn, interview by Rebecca Hackler, December 

17, 2012, transcript, Commercial Crew & Cargo Program 

Office History Project, JSC History Collection, University of 

Houston-Clear Lake, Houston, TX (hereafter cited as C3PO 

OHP); Bruce A. Manners, interview by Rebecca Hackler, 

December 5, 2013, transcript, C3PO OHP.

122 Amy V. Xenofos, interview by Rebecca Hackler, December 7, 

2012, transcript, C3PO OHP.

123 Dennis Stone, email communication to JSC History Office, 

July 15, 2013.

124 Thorn, interview. See also Joan Lisa Bromberg, NASA and 

the Space Industry (Baltimore: John Hopkins University 

Press, 1999), 7.

125 Participant Evaluation Plan, Commercial Orbital 

Transportation Services Demonstrations, Announcement 

Number COTS-01-05, 5-6, Commercial Crew & Cargo 

Program Office, Houston, TX.

126 Participant Evaluation Plan, 11. See also Dennis A. Stone, 

interview by Rebecca Hackler, November 26, 2012, 

transcript, C3PO OHP.

127 “COTS 2006 Demo Competition,” Commercial Crew & Cargo 

Program Office, last updated March 2, 2012, accessed 

November 21, 2013, http://www.nasa.gov/offices/c3po/

about/cots_demo_competition.html. 

128 Scott J. Horowitz, interview by Rebecca Wright, March 

1, 2013, transcript, JSC Oral History Project, JSC History 

Collection, University of Houston-Clear Lake, Houston, TX. 

See also Michael C. Wholley, interview by Rebecca Hackler, 

March 19, 2013, transcript, C3PO OHP.

129 Jeff Foust, “Small Steps Forward for NewSpace,” The Space 

Review, April 24, 2006, accessed September 30, 2013, 

http://www.thespacereview.com/article/609/1.

130 Participant Evaluation Plan, 8.

131 Ibid., 9; Scott J. Horowitz, Commercial Orbital Transportation 

Services (COTS) Final Selection Statement, August 18, 2006, 

Attachment A, Commercial Crew & Cargo Program Office, 

Houston, TX.

132 Alan J. Lindenmoyer, interview by Rebecca Wright, October 

31, 2012, transcript, C3PO OHP.

133 Participant Evaluation Plan, 17. See also Lindenmoyer, 

interview.

134 Horowitz, Final Selection Statement, 1; Alan Marty, interview 

by Rebecca Hackler, January 18, 2013, transcript, C3PO 

OHP.

135 Dennis Stone, email communication to JSC History Office, 

July 15, 2013.

136 Participant Evaluation Plan, 22.

137 Ibid., 17. 
124 APPENDIX

138 NASA Administrator Michael Griffin later expressed 

surprise that some major aerospace contractors failed 

to submit competitive proposals. Those that did submit 

proposals requested more than the available NASA 

funding. Michael D. Griffin, interview by Rebecca Wright, 

January 12, 2013, transcript, C3PO OHP. See also Wholley, 

interview. Economist Clayton M. Christensen observed that 

small markets—such as the relatively insignificant $500 

million COTS funding—do not provide enough growth 

opportunities for large companies. In other words, “an 

opportunity that excites a small organization isn’t large 

enough to be interesting to a very large one. One of the 

bittersweet rewards of success is that as companies 

become large, they lose the capability to enter small 

emerging markets.” Clayton M. Christensen, The Innovator’s 

Dilemma: The Revolutionary Book That Will Change the Way 

You Do Business (New York: Harper Business, 2011), 190. 

139 Stone, interview. See also Jonathan A. Arena, interview by 

Rebecca Hackler, April 22, 2013, transcript, C3PO OHP.

140 Xenofos, interview; Sumara M. Thompson-King, Courtney B. 

Graham, and Karen M. Reilley, interview by Rebecca Hackler, 

March 19, 2013, transcript, C3PO OHP.

141 In the case of SpaceHab, Inc., however, the level of confidence 

rating actually decreased after the face-to-face due diligence 

meetings. Horowitz, Final Selection Statement, Attachment B.

142 Marc G. Timm, interview by Rebecca Wright, June 12, 2013, 

transcript, C3PO OHP.

143 Horowitz, Final Selection Statement, 4-5.

144 Ibid.

145 Dennis Stone, email communication to JSC History Office, 

July 15, 2013.

146 Horowitz, interview.

147 Horowitz, Final Selection Statement, 5. This was true despite 

the fact that RpK, like SpaceX, proposed the development of 

all four capabilities and SpaceDev proposed only C and D. 

148 The Space Act Agreements of all three of NASA’s COTS 

commercial partners are available online. “Commercial Orbital 

Transportation Services Demonstration (COTS),” JSC Library, 

accessed September 30, 2013, http://www.nasa.gov/

centers/johnson/news/contracts/cots.html.

149 Lindenmoyer, interview; Thorn, interview. 

150 Government Accountability Office, Decision, Matter of: 

Exploration Partners, LLC, B-298804, December 19, 2006, 

accessed September 30, 2013, http://www.gao.gov/

assets/380/378416.pdf. 

151 Xenofos, interview.

152 Ibid.; Thompson-King, Graham, and Reilley, interview; 

Arena, interview.

153 Thompson-King, Graham, and Reilley, interview.

154 Arena, interview.

155 Alan J. Lindenmoyer, interview by Rebecca Wright, 

November 7, 2012, transcript, C3PO OHP. See also 

Manners, interview.

156 Stone, interview. In the words of NASA General Counsel Mike 

Wholley, “It was well begun as first done.” Wholley, interview.

157 Commercial Orbital Transportation Services, Phase 1 

Demonstrations, Announcement Number JSC-COTS-2, 

Commercial Crew & Cargo Program Office, October 

22, 2007, accessed September 30, 2013, available at 

http://www.nasa.gov/offices/c3po/about/cots_demo_

competition_2007.html. Emphasis added. Also Xenofos, 

interview. While the Round 1 Announcement (COTS-01-05) 

stated that “NASA intends to use its Space Act authority 

to enter into at least one and preferably multiple funded 

agreements,” the Round 2 Announcement stated, “NASA 

intends to use its Space Act authority to enter into at least 

one and potentially multiple funded agreements.” 

158 COTS Announcement, JSC-COTS-2, 18–19.

159 Xenofos, interview.

160 Douglas R. Cooke, Selection Statement for the Commercial 

Orbital Transportation Services Phase 1 Demonstrations 

(Announcement Number JSC-COTS-2), February 15, 2008, 

3, Commercial Crew & Cargo Program Office, Houston, TX.

161 Cooke, Selection Statement, 11.

162 Ibid.

163 Antonio L. Elias, interview by Rebecca Hackler, June 3, 2013, 

transcript, C3PO OHP.

164 Cooke, Selection Statement, 12.

165 Manners, interview.

166 Government Accountability Office, Decision, Matter of: 

Rocketplane Kistler, B-310741, January 28, 2008, 3, 

accessed September 30, 2013, http://www.gao.gov/

assets/390/381890.pdf.

167 Ibid., 5. See also Xenofos, interview and Thompson-King, 

Graham, and Reilley, interview.

168 See Brian Berger, “NASA Signs Space Act Agreements with 

Three More Firms,” Space.com, June 19, 2007, accessed 

September 30, 2013, http://www.space.com/3975-nasasigns-space-act-agreements-firms.html. 

169 Thompson-King, Graham, and Reilley, interview.

170 Arena, interview. See also Xenofos, interview.

171 Thompson-King, Graham, and Reilley, interview. See also 

Arena, interview.

172 Arena, interview; Stone, interview.

173 Cooke, Selection Statement.

174 Thomas B. Pickens III (CEO of SpaceHab, Inc.) to Alan 

Lindenmoyer, May 29, 2008, Commercial Crew & Cargo 

Program Office, Houston, TX.
APPENDIX 125

175 Charles Miller (President and CEO of Constellation Services 

International, Inc.) to Alan Lindenmoyer, July 15, 2008, 

Commercial Crew & Cargo Program Office, Houston, TX.

176 Charles Duelfer (CEO of the Transformational Space Corp.) 

to Alan Lindenmoyer, October 16, 2008, Commercial Crew & 

Cargo Program Office, Houston, TX.

Chapter 4

177 Scott J. Horowitz, Program Formulation Authorization 

Document, Commercial Crew & Cargo Program, 3, August 

14, 2006, Commercial Crew & Cargo Program Office, 

Houston, TX.

178 The SAA between NASA and SpaceX also included an option 

for COTS Capability D, a Crewed Vehicle Demonstration 

valued at $308 million, that was never activated. Space Act 

Agreement between NASA and SpaceX for Commercial 

Orbital Transportation Services Demonstration, Appendix 

1: Executive Summary, 3, accessed September 30, 2013, 

http://www.nasa.gov/centers/johnson/pdf/189228main_

setc_nnj06ta26a.pdf. 

179 Lisa P. Price, email communication to JSC History Office, 

September 19, 2013. See also Consolidated Appropriations 

Act, 2008, Public Law 110–161, 110th Cong., 1st sess. 

(December 26, 2007), accessed September 30, 2013, http://

www.gpo.gov/fdsys/pkg/PLAW-110publ161/pdf/PLAW110publ161.pdf. 

180 Alan J. Lindenmoyer, interview by Rebecca Wright, October 

31, 2012, transcript, Commercial Crew & Cargo Program 

Office History Project, JSC History Collection, University of 

Houston-Clear Lake, Houston, TX (hereafter cited as C3PO 

OHP). See also Lisa P. Price, interview by Rebecca Hackler, 

May 14, 2013, transcript, C3PO OHP.

181 Price, interview.

182 NASA’s Commercial Cargo Providers; Are They Ready to 

Supply the Space Station in the Post-Shuttle Era?: Hearing 

before the Subcommittee on Space and Aeronautics, 

United States House of Representatives, 112th Cong., 1st 

sess., May 26, 2011 (statement of William H. Gerstenmaier, 

Associate Administrator for Space Operations), accessed 

September 30, 2013, http://science.house.gov/sites/

republicans.science.house.gov/files/documents/

hearings/052611_Gerstenmaier%20Testimony.pdf.

183 William H. Gerstenmaier, interview by Rebecca Wright, June 

12, 2013, transcript, C3PO OHP.

184 Bretton Alexander, interview by Rebecca Wright, March 18, 

2013, transcript, C3PO OHP.

185 Review of the U.S. Human Spaceflight Plans Committee 

(Public Meeting, Ronald Reagan Building and International 

Trade Center Amphitheater, Washington, DC, August 12, 

2009), transcript, 69-70, accessed September 30, 2013, 

http://www.nasa.gov/382774main_081209_DC_Transcript.txt.

186 Seeking a Human Spaceflight Program Worthy of a Great 

Nation: Final Report of the Review of U.S. Human Spaceflight 

Plans Committee (Washington, DC: NASA, 2009), 57, 

accessed September 30, 2013, http://www.nasa.gov/

pdf/396093main_HSF_Cmte_FinalReport.pdf. Emphasis 

added.

187 “Fiscal Year 2011 Budget Estimate,” NASA, February 2010, 

accessed September 30, 2013, http://www.nasa.gov/news/

budget/2011.html.

188 Marc G. Timm, interview by Rebecca Wright, June 12, 2013, 

transcript, C3PO OHP.

189 The National Aeronautics and Space Administration 

Authorization Act of 2010, Public Law 111–267, 111th 

Cong., 2d sess. (October 11, 2010), §§101 and 401, 

accessed September 30, 2013, http://www.nasa.gov/

pdf/649377main_PL_111-267.pdf. 

190 Price, interview.

191 When the COTS program was initiated the Commercial 

Crew & Cargo Program Office was under the Exploration 

Systems Mission Directorate (ESMD) at NASA Headquarters. 

After the retirement of the Space Shuttle in July 2011, the 

System Operations Mission Directorate (SOMD) merged with 

ESMD to form the Human Exploration and Operations (HEO) 

Mission Directorate under Associate Administrator William H. 

“Bill” Gerstenmaier.

192 Bruce A. Manners, interview by Rebecca Hackler, December 

5, 2013, transcript, C3PO OHP.

193 Michael J. Horkachuck, interview by Rebecca Hackler, 

January 16, 2013, transcript, C3PO OHP.

194 Manners, interview.

195 Lori B. Garver, interview by Rebecca Wright, June 26, 2013, 

transcript, C3PO OHP.

196 Horkachuck, interview, January 16, 2013.

197 Manners, interview.

198 Michael J. Horkachuck, interview by Rebecca Wright, 

November 6, 2013, transcript, C3PO OHP.

199 Horkachuck, interview, January 16, 2013.

200 Horkachuck, interview, November 6, 2012.

201 Bryan D. O’Connor, interview by Rebecca Wright, December 

18, 2012, transcript, JSC Oral History Project, JSC History 

Collection, University of Houston-Clear Lake, Houston, TX; 

Jeffrey H. Cyphert, email communication to JSC History 

Office, July 24, 2013.

202 Mark D. Erminger, email communication to Commercial Crew 

& Cargo Program Office, November 20, 2013.

203 Horkachuck, interview, November 6, 2012.

204 Ibid.

205 David W. Thompson, interview by Rebecca Wright, June 3, 

2013, transcript, C3PO OHP.
126 APPENDIX

206 Kurt Eberly and Michael R. Pinkston, interview by Rebecca 

Wright, June 3, 2013, transcript, C3PO OHP. 

207 Peter Capozzoli, interview by Rebecca Wright, January 16, 

2013, transcript, C3PO OHP.

208 Horkachuck, interview, November 6, 2013.

209 Ibid.; Manners, interview.

210 Eberly and Pinkston, interview.

211 Timm, interview.

212 Manners, interview.

213 John E. Bretschneider (Booz Allen Hamilton), email 

communication to JSC History Office, September 25, 2013.

214 Horkachuck, interview, November 6, 2012.

215 Antonio L. Elias, interview by Rebecca Hackler, June 3, 2013, 

transcript, C3PO OHP.

Chapter 5

216 See David Giger, interview by Rebecca Hackler, 

January 15, 2013, transcript, Commercial Crew & Cargo 

Program History Project, JSC History Collection, University 

of Houston-Clear Lake, Houston, TX (hereafter cited as 

C3PO OHP). 

217 Scott J. Horowitz, Commercial Orbital Transportation 

Services (COTS) Final Selection Statement, August 18, 2006, 

Attachment B, Commercial Crew & Cargo Program Office, 

Houston, TX.

218 Musk’s confident persona, sometimes even described as 

“brash,” has been credited as an instrumental factor in the 

company’s success. For more on Musk see “Elon Musk, the 

Rocket Man with a Sweet Ride,” Smithsonian Magazine, 

December 2012, accessed September 30, 2013, http://

www.smithsonianmag.com/science-nature/Elon-Musk-theRocket-Man-With-a-Sweet-Ride-179998091.html. 

219 “About SpaceX: Company,” Space Exploration 

Technologies Corp., accessed September 30, 2013, 

http://www.spacex.com/about. 

220 In December 2012, SpaceX made headlines when it was 

awarded launch contracts with the U.S. Air Force, a market 

previously dominated by established launch contractors 

such as Boeing and United Launch Alliance. Aaron Metha, 

“SpaceX president discusses Air Force launches,” Defense 

News, December 12, 2012, accessed September 30, 

2013, http://www.defensenews.com/article/20121212/

DEFREG02/312120007/SpaceX-President-Discusses-U-SAir-Force-Launches; Ryan Grim and Jason Cherkis, “Elon 

Musk Battles Entrenched Rivals Over NASA Contracts,” 

Huffington Post, February 20, 2013, accessed September 

30, 2013, http://www.huffingtonpost.com/2013/02/20/elonmusk-spacex_n_2727312.html.

221 Michael J. Horkachuck, interview by Rebecca Wright, 

November 6, 2013, transcript, C3PO OHP.

222 Hans Koenigsmann, interview by Rebecca Hackler, January 

15, 2013, transcript, C3PO OHP.

223 Tim Buzza, interview by Rebecca Wright, January 15, 2013, 

transcript, C3PO OHP.

224 Horowitz, Final Selection Statement, Attachment B.

225 “Falcon 1 Overview,” Space Exploration Technologies Corp., 

accessed March 29, 2013, http://www.spacex.com/falcon1.

php. This page was removed from the SpaceX website after 

the last date of access and is no longer publically available. 

For more on the first successful Falcon 1 launch, see Aaron 

Rowe, “SpaceX Did It — Falcon 1 Made it to Space,” Wired, 

September 28, 2008, accessed September 30, 2013, http://

www.wired.com/wiredscience/2008/09/space-x-did-it/. 

226 Koenigsmann, interview.

227 See “Falcon 9,” Space Exploration Technologies Corp., 

accessed September 30, 2013, http://www.spacex.com/

falcon9; “SpaceX Achieves Orbital Bullseye with Inaugural 

Flight of Falcon 9 Rocket,” Press Release, Space Exploration 

Technologies Corp., June 7, 2010, accessed September 30, 

2013, http://www.spacex.com/press/2012/12/19/spacexachieves-orbital-bullseye-inaugural-flight-falcon-9-rocket. 

228 Koenigsmann, interview.

229 “Dragon,” Space Exploration Technologies Corp., accessed 

September 30, 2013, http://www.spacex.com/dragon; 

“Dragon Lab Fact Sheet,” Space Exploration Technologies 

Corp., accessed September 30, 2013, http://www.spacex.

com/sites/spacex/files/pdf/DragonLabFactSheet.pdf. 

230 Denise Chow, “5 Fun Facts About Private Rocket Company 

SpaceX,” Space.com, May 21, 2012, accessed September 

30, 2013, http://www.space.com/15799-spacex-dragoncapsule-fun-facts.html; W.J. Hennigan, “SpaceX’s 

‘Secret’ Payload? A Wheel of Cheese,” Los Angeles 

Times Technology Blog, December 9, 2010, accessed 

September 30, 2013, http://latimesblogs.latimes.com/

technology/2010/12/spacexs-secret-payload.html.

231 Clayton M. Christensen, The Innovator’s Dilemma: The 

Revolutionary Book That Will Change the Way You Do 

Business (New York: Harper Business, 2011), 16.

232 Jennifer Reingold, “Hondas in Space,” Fast Company, 

February 1, 2005, accessed September 30, 2013, http://

www.fastcompany.com/52065/hondas-space.

233 John Couluris, interview by Rebecca Hackler, January 15, 

2013, transcript, C3PO OHP.

234 Giger, interview.

235 Couluris, interview.

236 Koenigsmann, interview

237 Horkachuck, interview, November 6, 2012.
APPENDIX 127

238 “NASA’s Marshall Center Concludes Wind Tunnel Testing 

to Aid in SpaceX Reusable Launch System Design,” NASA 

Marshall Space Flight Center, Press Release 12-058, May 23, 

2012, accessed September 30, 2013, http://www.nasa.gov/

Centers/marshall/news/news/releases/2012/12-058.html.

239 Gwynne E. Shotwell, interview by Rebecca Wright, January 

15, 2013, transcript, C3PO OHP.

240 Horowitz, Final Selection Statement, 3.

241 A copy of the company’s Space Act Agreement and its 

subsequent amendments is available at Commercial Orbital 

Transportation Services Demonstration (COTS), JSC Library, 

accessed September 30, 2013, http://www.nasa.gov/

centers/johnson/news/contracts/cots.html.

242 Alan Marty, interview by Rebecca Hackler, January 18, 2013, 

transcript, C3PO OHP.

243 Shotwell, interview.

244 John E. Bretschneider (Booz Allen Hamilton), email 

communication to JSC History Office, June 13, 2013.

245 Michael J. Horkachuck, email communication to Commercial 

Crew & Cargo Program Office, November 17, 2013.

246 Horkachuck, interview, November 6, 2012. In interviews 

with engineers at SpaceX, employees denied such fears, 

always expressing confidence in NASA’s commitment to 

the partnership. Koenigsmann, interview; Peter Capozzoli, 

interview by Rebecca Wright, January 16, 2013, transcript, 

C3PO OHP.

247 Alan J. Lindenmoyer, interview by Rebecca Wright, 

November 7, 2012, transcript, C3PO OHP. According to 

Selection Authority Scott Horowitz, none of the Round 1 

competitors scored higher than a 20 percent confidence 

level for the feasibility of completing their proposals on time 

and on budget. Scott J. Horowitz, interview by Rebecca 

Wright, March 1, 2013, transcript, JSC Oral History Project, 

JSC History Collection, University of Houston-Clear Lake, 

Houston, TX.

248 Alan Lindenmoyer, “COTS Status” (PowerPoint presentation 

at NASA Advisory Council meeting, Ames Research Center, 

Moffett Field, CA, August 2, 2011), 3, accessed September 

30, 2013, http://www.nasa.gov/pdf/580727main_4%20-%20

Lindenmoyer%20COTS%20Status_508.pdf.

249 Shotwell, interview. The Associate Administrator of NASA’s 

Human Exploration and Operations Directorate disagreed, 

stating the company did not believe those tests were 

necessary. William H. Gerstenmaier, interview by Rebecca 

Wright, June 12, 2013, transcript, C3PO OHP.

250 Buzza, interview.

251 Horkachuck, interview, November 6, 2012. 

252 Ibid.

253 Michael J. Horkachuck, interview by Rebecca Hackler, 

January 16, 2013, transcript, C3PO OHP.

254 Horkachuck, interview, November 6, 2012.

255 “Space Shuttle Mission STS-127: A Porch in Space,” 

NASA Press Kit,” June 2009, 83-84, accessed November 

14, 2013, http://www.nasa.gov/pdf/358018main_

sts127_press_kit.pdf; “SpaceX’s DragonEye Navigation 

Sensor Successfully Demonstrated On Space Shuttle,” 

Press Release, Space Exploration Technologies Corp., 

September 24, 2009, accessed November 8, 2013, http://

www.spacex.com/press/2012/12/19/spacexs-dragoneyenavigation-sensor-successfully-demonstrated-spaceshuttle; Chris Bergen, “STS-133: SpaceX’s DragonEye 

Set for Late Installation on Discovery,” NASASpaceflight, 

July 19, 2010, accessed November 8, 2013, http://

www.nasaspaceflight.com/2010/07/sts-133-spacexsdragoneye-late-installation-discovery/. 

256 Warren P. Ruemmele, email communication to Commercial 

Crew & Cargo Program Office, November 8, 2013.

257 Couluris, interview; Capozzoli, interview; Horkachuck, 

interview, November 6, 2012.

258 Horkachuck, interview, November 6, 2012; Giger, 

interview; Capozzoli, interview. See also Hearing before 

the House Subcommittee on Space and Aeronautics, 

“NASA’s Commercial Cargo Providers; Are They Ready 

to Supply the Space Station in the Post-Shuttle Era?” 

Hearing Charter, 112th Cong., 1st sess., May 26, 2011, 

7-8, accessed September 30, 2013, http://science.house.

gov/sites/republicans.science.house.gov/files/documents/

hearings/052611_charter_1.pdf.

259 Horkachuck, interview, November 6, 2012; Valin B. Thorn, 

interview by Rebecca Hackler, December 17, 2012, 

transcript, C3PO OHP.

260 Douglas R. Cooke, Selection Statement for the Commercial 

Orbital Transportation Services Phase 1 Demonstrations 

(Announcement Number JSC-COTS-2), February 15, 2008, 

3, Commercial Crew & Cargo Program Office, Houston, TX.

261 Geoffrey L. Yoder, Selection Statement for Commercial Crew 

Development (Announcement Number JSC-CCDev-1), 

December 8, 2009, 19–20, Commercial Crew & Cargo 

Program Office, Houston, TX.

262 For more on SpaceX’s work with ISS astronauts see Couluris, 

interview. For details of the launch delays see Chris Bergin, 

“SpaceX, NASA Managers Decide on May 7 Launch 

Date Following Slip,” NASASpaceflight, April 23, 2012, 

accessed September 30, 2013, http://www.nasaspaceflight.

com/2012/04/spacexnasa-new-falcon-9-launch-date-slip/.

263 Shotwell, interview.

264 For a detailed review of the mission, see Chris Bergin, 

“SpaceX’s Dragon Berthed on the ISS to Complete 

Historic Arrival,” NASASpaceflight, May 25, 2012, 

accessed September 30, 2013, http://www.

nasaspaceflight.com/2012/05/spacexs-dragon-historicattempt-berth-with-iss/.
128 APPENDIX

265 See Capozzoli, interview; Kathryn L. Lueders, interview by 

Rebecca Hackler, April 17, 2013, transcript, C3PO OHP.

266 Shotwell, interview; Alan J. Lindenmoyer, interview, 

November 7, 2012.

267 Buzza, interview.

268 “Successful Launch Kicks Off SpaceX’s Historic Mission,” 

Press Release, Space Exploration Technologies Corp., May 

22, 2012, accessed September 30, 2013, http://www.

spacex.com/press/2012/12/19/successful-launch-kicksspacexs-historic-mission. 

269 Joan Lisa Bromberg, NASA and the Space Industry 

(Baltimore: John Hopkins University Press, 1999), 178.

270 “Kistler Aerospace Corporation’s K-1,” GlobalSecurity.org,

page last modified July 21, 2011, accessed September 30, 

2013, http://www.globalsecurity.org/space/systems/kistler.

htm. For more on the Kistler Corp. and the K-1 see Greg 

Klerkx, “Back to the Future,” in Lost in Space: The Fall of 

NASA and the Dream of a New Space Age (New York: First 

Vintage Books, 2005), 115–141.

271 See Bruce A. Manners, interview by Rebecca Hackler, 

December 5, 2013, transcript, C3PO OHP. Mueller explained 

the choice of the Woomera launch site as a result of the 

difficulty of attaining launch and reentry permits for domestic 

launch sites. However, the FAA Office of Commercial Space 

Transportation still has jurisdiction over launches conducted 

by U.S. companies abroad. Space Shuttle and the Future of 

Space Launch Vehicles: Hearing before the Subcommittee 

on Science, Technology, and Space, United States Senate, 

108th Cong., 2d sess., May 5, 2004 (statement of George 

E. Mueller, CEO of Kistler Aerospace Corp.), accessed 

September 30, 2013, http://www.Rocketplane Kistler.com/

newsinfo/pressreleases/060404SenateResponse.html.

272 Space Act Agreement between NASA and Kistler Aerospace 

Corporation and Rocketplane Limited, Inc. for Commercial 

Orbital Transportation Services Demonstration (COTS), 

Appendix 1: Technical Approach Summary, 40-42, accessed 

September 30, 2013, http://www.nasa.gov/centers/johnson/

pdf/189226main_kistler_nnj06ta27s.pdf; “RocketplaneKistler (RpK),” Commercial Partners, NASA C3PO, accessed 

September 30, 2013, http://www.nasa.gov/offices/c3po/

partners/rpk/; “Kistler Aerospace Corporation’s K-1.”

273 Randolph H. Brinkley, interview by Rebecca Hackler, May 1, 

2013, transcript, C3PO OHP.

274 Joseph W. Cuzzupoli NASA Biographical Data Sheet 

(January 1999), Joseph W. Cuzzupoli Biographical File, 

JSC History Collection, University of Houston-Clear Lake, 

University Archives, Houston, TX; Joseph W. Cuzzupoli, 

interview by Rebecca Hackler, April 29, 2013, transcript, 

C3PO OHP.

275 Manners, interview.

276 Warren Fester, “Loral Signs on with Kistler,” SpaceNews, 

February 3-9, 1997; “Kistler Aerospace Corporation’s K-1.”

277 “The Space Launch Initiative: Technology to Pioneer the 

Space Frontier,” Marshall Space Flight Center, FS-2002-04-

87-MSFC, April 2002, accessed September 30, 2013, http://

www.nasa.gov/centers/marshall/news/background/facts/

slifactstext02.html. 

278 Future of Space Launch Vehicles, Hearing; Brian Berger, 

“Entrepreneurial Rocket Firms Face Different Hurdles,” 

Space.com, May 31 2004, accessed September 30, 2013, 

http://www.freerepublic.com/focus/f-news/1145377/posts.

279 Future of Space Launch Vehicles, Hearing.

280 Ibid.; Berger, “Entrepreneurial Rocket Firms.”

281 George D. French, interview by Rebecca Hackler, May 1, 

2013, transcript, C3PO OHP.

282 Ibid.

283 Ibid., Lon L. Rains, “Rocketplane’s Majority Owner Buys 

Kistler,” Space.com, February 27, 2006, accessed 

September 30, 2013, http://www.space.com/2092-

rocketplane-majority-owner-buys-kistler.html.

284 Horowitz, Final Selection Statement, Attachment B.

285 The Orbital Sciences Corp. briefly worked with Rocketplane 

Kistler as a subcontractor during RpK’s COTS development. 

Orbital officials, aware of RpK’s financial circumstances, 

“parted ways” with the company before the termination 

of RpK’s Space Act Agreement with NASA. David W. 

Thompson, interview by Rebecca Wright, June 3, 2013, 

transcript, C3PO OHP. Also Antonio L. Elias, interview by 

Rebecca Hackler, June 3, 2013, transcript, C3PO OHP.

286 Space Act Agreement Amendment One between NASA 

and Kistler Aerospace Corp. and Rocketplane Limited, 

Inc. for Commercial Orbital Transportation Services 

Demonstration (COTS), accessed September 30, 2013, 

http://www.nasa.gov/centers/johnson/pdf/389028main_

kistler_amend1.pdf; “Rocketplane-Kistler (RpK),” NASA 

C3PO; Bruce Manners, “RpK SAA Progress and Plan,” 

Commercial Crew & Cargo Program Office, August 16, 

2007, 4-5, Commercial Crew & Cargo Program Office, 

Houston, TX. See also French, interview.

287 Manners, “RpK SAA Progress and Plan, 5”; George French, 

email communication to Commercial Crew & Cargo Program 

Office, November 20, 2013.

288 Alan Marty, interview.

289 Manners, interview; Jonathan A. Arena, interview by Rebecca 

Hackler, April 22, 2013, transcript, C3PO OHP.

290 Arena, interview.

291 Manners, “RpK SAA Progress and Plan,” 5-6.

292 Manners, interview; Arena, interview.

293 Horowitz, interview.

294 Arena, interview.
APPENDIX 129

295 “NASA Extends Contract with Russia’s Federal Space 

Agency,” NASA Headquarters Press Release, Contract 

Release: C07-18, April 9, 2007, accessed September 30, 

2013, http://www.nasa.gov/home/hqnews/2007/apr/HQ_

C07-18_Roscosmos.html; Randolph H. Brinkley to Scott J. 

Horowitz, September 20, 2007, 2. Courtesy of Randolph H. 

Brinkley, email communication to JSC History Office, May 

25, 2013.

296 Brinkley, interview.

297 French, interview. See also Lindenmoyer, interview, 

November 7, 2012.

298 Randolph H. Brinkley to Scott J. Horowitz, September 20, 

2007, 4. 

299 Brinkley, interview.

300 Manners, interview; Sumara M. Thompson-King, Courtney B. 

Graham, and Karen M. Reilley, interview by Rebecca Hackler, 

March 19, 2013, transcript, C3PO OHP.

301 Doug Messier, “Rocketplane Global Filed for Bankruptcy,” 

Parabolic Arc, July 7, 2010, accessed September 30, 2013, 

http://www.parabolicarc.com/2010/07/07/rocketplaneglobal-files-bankruptcy/.

302 French, interview; Jennifer Palmer, “Rocketplane Emerges 

from Bankruptcy, Keeps Reaching for Moon,” NewsOK 

(Oklahoma), Janury 14, 2013, accessed September 30, 2013,

http://newsok.com/rocketplane-emerges-from-bankruptcykeeps-reaching-for-moon/article/3745490/?page=1; Doug 

Messier, “Rocketplane Global Out of Bankruptcy, Seeks 

Funding for Space Plane,” Parabolic Arc, February 28, 2012, 

accessed September 30, 2013, http://www.parabolicarc.

com/2012/02/28/rocketplane-global-out-of-bankruptcyseeks-funding-for-space-plane/.

303 Cuzzupoli, interview.

304 Brinkley, interview.

305 Bromberg, 119-120; Dave Thompson, “An Exciting 

Adventure Is In Store (1982-1986),” in An Adventure Begins: 

Orbital’s First 25 Years (Dulles, VA: Orbital Sciences Corp., 

2007), 6-15.

306 Thompson, interview.

307 Bromberg, 119-120; Elias, interview.

308 Thompson, “An Exciting Adventure,” 10.

309 Ibid., 14; Bromberg, 155; Elias, interview.

310 David P. Gump, Space Enterprise: Beyond NASA (New York: 

Praeger, 1990), 1.

311 Ibid., 35-36.

312 Elias, interview. For more on the Pegasus rocket see 

“Fact Sheet: Pegasus,” Orbital Sciences Corp., accessed 

September 30, 2013, http://www.orbital.com/SpaceLaunch/

Pegasus/ and Antonio Elias, “The Pegasus Rocket: We Said 

We’d Do It... And We Did It! (1987–1990),” in An Adventure 

Begins: Orbital’s First 25 Years, 18–31.

313 Robert T. Richards, interview by Rebecca Hackler, June 4, 

2013, transcript, C3PO OHP.

314 Ibid.; “The Space Launch Initiative: Technology to Pioneer the 

Space Frontier,” Marshall Space Flight Center, FS-2002-04-

87-MSFC, April 2002, accessed September 30, 2013, http://

www.nasa.gov/centers/marshall/news/background/facts/

slifactstext02.html; 

315 Thompson, interview.

316 See Elias, interview; Richards, interview.

317 Kurt Eberly and Michael R. Pinkston, interview by Rebecca 

Wright, June 3, 2013, transcript, C3PO OHP; Elias, interview.

318 “Fact Sheet: Taurus,” Orbital Sciences Corp., accessed 

September 30, 2013, http://www.orbital.com/NewsInfo/

Publications/Taurus_fact.pdf.

319 “Fact Sheet: Antares,” Orbital Sciences Corp., accessed 

September 30, 2013, http://www.orbital.com/NewsInfo/

Publications/Antares_fact.pdf; Karl Tate, “Private Antares 

Rocket & Cygnus Spacecraft Explained (Infographic),” Space.

com, April 14, 2013, accessed September 30, 2013, http://

www.space.com/20526-antares-rocket-cygnus-spacecraftexplained.html.

320 “Fact Sheet: Antares”; Eberly and Pinkston, interview.

321 Elias, interview.

322 Peter B. Selding, “Dutch Space To Build Solar Arrays for 

Cygnus,” SpaceNews, November 12, 2009, accessed 

September 30, 2013, http://www.spacenews.com/article/

dutch-space-build-solar-arrays-cygnus#.UcCzY_nVA1I. 

In August 2013, Orbital announced that for its fifth ISS 

resupply mission, the enhanced version of the Cygnus PCM 

would instead utilize solar arrays originally developed by 

Alliant Techsystems, Inc. (ATK) for NASA’s Orion capsule. 

Dan Leone, “Ousted from First Orion Flight, Circular ATK 

Solar Arrays Still Set to Power Cygnus,” SpaceNews, 

August 1, 2013, accessed September 30, 2013, 

http://www.spacenews.com/article/civilspace/36576ousted-from-first-orion-flight-circular-atk-solararrays-still-set-to-power. 

323 Space Act Agreement between NASA and Orbital 

Corporation for Commercial Orbital Transportation Services 

Demonstration (COTS), Appendix 1, E3. Technical Approach, 

accessed September 30, 2013, http://www.nasa.gov/

centers/johnson/pdf/214893main_Orbital_COTS_Ph1_

Redacted_SAA_2_27_08.pdf.

324 Frank DeMauro, interview by Rebecca Hackler, June 4, 2013, 

transcript, C3PO OHP.

325 Eberly and Pinkston, interview.

326 Ibid.

327 Frank L. Culbertson, interview by Rebecca Wright, June 4, 

2013, transcript, C3PO OHP.

328 Ibid.
130 APPENDIX

329 SpaceUp Houston, 2013 Commercial Spaceflight Panel, Part 

1 - COTS/CCiCap, Houston, TX, February 8, 2013, accessed 

September 30, 2013, http://livestre.am/4kEmv.

330 Thompson, interview. See also David W. Thompson, “Space 

Enterprise and Capital Formation” (paper presented at the 

Financing Business in Space Conference, Arlington, VA, 

March 27, 1984), discussed in Edward Ridley Finch, Jr. 

and Amanda Lee Moore, Astrobusiness: A Guide to the 

Commerce and Law of Outer Space (New York: Praeger, 

1984), 48-49.

331 Garrett Pierce, “Financings, Acquisitions, and Divestitures: 

No Bucks, No Buck Rogers (1988-2003),” in An Adventure 

Begins: Orbital’s First 25 Years, 100.

332 David W. Thompson, email communication to JSC 

History Office, November 19, 2013; Thompson, interview; 

Culbertson, interview.

333 See Elias, interview. A copy of Orbital’s Space Act Agreement 

and its subsequent amendments is available at Commercial 

Orbital Transportation Services Demonstration (COTS), JSC 

Library, accessed September 30, 2013, http://www.nasa.

gov/centers/johnson/news/contracts/cots.html.

334 Manners, interview.

335 Eberly and Pinkston, interview.

336 Ibid.

337 Culbertson, interview.

338 Ibid.; Eberly and Pinkston, interview.

339 “History of MARS,” Mid-Atlantic Regional Spaceport, 

accessed September 30, 2013, http://www.marsspaceport.

com/mid-atlantic-spaceport-history.

340 The State of Virginia allocated $10 million via infrastructure 

bonds through the Virginia Public Building Authority to 

“Improve Wallops Island Flight Facilities” for the 2008 to 

2010 biennium. See “Capital Projects for the 2008–2010 

Biennium,” Commonwealth of Virginia Department 

of Transportation, accessed September 30, 2013, 

http://dpb.virginia.gov/budget/buddoc09/pdf/partb/

Rpt0510aDetailTablesCapital.pdf. 

341 Elias, interview.

342 Thompson, interview.

343 Elias, interview.

344 “Orbital Begins Antares Rocket Operations at Mid-Atlantic 

Regional Spaceport,” Press Release, Orbital Sciences 

Corp., October 1, 2012, accessed September 30, 2013, 

http://www.orbital.com/NewsInfo/release.asp?prid=829; 

Thompson, interview; Elias, interview; Eberly and Pinkston, 

interview; Manners, interview.

345 Alan Lindenmoyer, “COTS Status.”

346 For more on Orbital’s application of the augmentation 

funding see Thompson, interview; Elias, interview; and 

Richards, interview.

347 Eberly and Pinkston, interview. See also DeMauro, interview.

348 “Orbital Successfully Launches First Antares Rocket,” Press 

Release, Orbital Sciences Corp., April 21, 2013, accessed 

September 30, 2013, http://www.orbital.com/NewsInfo/

release.asp?prid=852; Jonathan Amos, “Orbital’s Antares 

Rocket Makes Test Flight,” BBC News, April 21 2013, 

accessed September 30, 2013, http://www.bbc.co.uk/news/

science-environment-22193330; William Graham, “Antares 

Conducts a Flawless Maiden Launch,” NASASpaceflight, 

April 21, 2013, accessed September 30, 2013, http://www.

nasaspaceflight.com/2013/04/orbital-antares-debut-launchattempt/; Brock Vergakis, “Rocket That Will Carry Cargo Ship 

Test Launched,” Associated Press, April 21, 2013, accessed 

September 30, 2013, http://bigstory.ap.org/article/rocketwill-carry-cargo-ship-test-launched-1.

349 DeMauro, interview.

350 Eberly and Pinkston, interview.

351 DeMauro, interview.

352 Ben Evans, “Antares Mission Flies Low-Cost Smartphone 

Satellites,” America Space, April 24, 2013, accessed 

September 30, 2013, http://www.americaspace.

com/?p=34813.

353 Ben Evans, “Orbital Sciences Primed for First Cygnus 

Cargo Mission to Space Station,” America Space, 

September 16, 2013, accessed September 20, 2013, 

http://www.americaspace.com/?p=42271. Orbital’s funded 

Space Act Agreement with NASA was signed on Low’s 

52nd birthday, February 19, 2008. Low died of colon cancer 

less than one month later on March 15, 2008. 

354 Dan Leone, “Cygnus on Way to Station, Orbital 

Sciences on Way to Collecting from NASA,” SpaceNews, 

September 18, 2013, accessed September 20, 2013, 

http://www.spacenews.com/article/launchreport/37284cygnus-on-way-to-station-orbital-sciences-onway-to-collecting-from-nasa. 

355 Ben Evans, “A Beautiful Swan Came Calling: Orbital’s 

Cygnus Cargo Ship Arrives at Space Station,” America 

Space, September 29, 2013, accessed October 1, 2013, 

http://www.americaspace.com/?p=43097. See also Chris 

Bergen, “Orbital’s Cygnus successfully berthed on the 

ISS,” NASASpaceflight, September 29, 2013, accessed 

October 1, 2013, http://www.nasaspaceflight.com/2013/09/

cygnus-second-attempt-berth-iss/ and Jonathan Amos, 

“Orbital’s Cygnus freighter reaches International Space 

Station,” BBC News, September 29, 2013, accessed 

October 1, 2013, http://www.bbc.co.uk/news/scienceenvironment-24306173.

356 NASA Television, “Recapping the Flight of Cygnus” (Press 

Conference, Johnson Space Center, Houston, Texas, 

September 29, 2013), accessed October 1, 2013, http://

www.youtube.com/watch?v=Hslr5jkR568. 

357 Manners, interview.
APPENDIX 131

358 Mark Carreau, “NASA Approves Orbital Sciences For ISS 

Commercial Resupply Missions,” Aviation Week & Space 

Technology, October 1, 2013, accessed October 2, 2013, 

http://www.aviationweek.com/Article.aspx?id=/article-xml/

asd_10_01_2013_p01-02-622251.xml. Although Orbital was 

prepared to complete the first CRS mission by December 

2013, the launch was delayed until January due to technical 

issues aboard the ISS. “NASA Postpones Orbital Launch, 

Sets Spacewalks to Repair Faulty Pump Module,” NASA, 

December 17, 2013, accessed February 24, 2014, http://

www.nasa.gov/content/nasa-postpones-orbital-launch-setsspacewalks-to-repair-faulty-pump-module/. 

359 NASA Television, “Recapping the Flight of Cygnus.”

360 Orbital Sciences Corp., An Adventure Begins: Orbital’s First 

25 Years (Dulles, VA: Orbital Sciences Corp., 2007), 63.

Chapter 6

361 John K. Trainor, “International Space Station Program: Safety 

Review Process” (PowerPoint presentation, December 

6, 2006), 3, Commercial Crew & Cargo Program Office, 

Houston, TX.

362 The first ATV mission did not launch until March 9, 2008, 

roughly a year and a half after the first COTS Space Act 

Agreements were signed. The final ATV mission is scheduled 

for 2014. “Automated Transfer Vehicle,” European Space 

Agency, accessed November 8, 2013, http://www.esa.

int/Our_Activities/Human_Spaceflight/ATV. The first HTV 

mission launched in September 2011. “HTV-1 Mission,” 

Japan Aerospace Exploration Agency, accessed November 

8, 2013, http://iss.jaxa.jp/en/htv/mission/htv-1/. 

363 Kathryn L. Lueders, interview by Rebecca Hackler, April 

17, 2013, transcript, Commercial Crew & Cargo Program 

Office History Project, JSC History Collection, University of 

Houston-Clear Lake, Houston, TX (hereafter cited as C3PO 

OHP).

364 Ibid.

365 Ibid.

366 Frank DeMauro, interview by Rebecca Hackler, June 4, 

2013, transcript, C3PO OHP. For more details and examples 

from the SpaceX perspective see John Couluris, interview 

by Rebecca Hackler, January 15, 2013, transcript, C3PO 

OHP; David Giger, interview by Rebecca Hackler, January 15, 

2013, transcript, C3PO OHP; and Tim Buzza, interview by 

Rebecca Wright, January 15, 2013, transcript, C3PO OHP.

367 DeMauro, interview; Antonio L. Elias, interview by Rebecca 

Hackler, June 3, 2013, transcript, C3PO OHP; Frank L. 

Culbertson, interview by Rebecca Wright, June 4, 2013, 

transcript, C3PO OHP.

368 Gwynne E. Shotwell, interview by Rebecca Wright, January 

15, 2013, transcript, C3PO OHP.

369 Michael J. Horkachuck, interview by Rebecca Hackler, 

January 16, 2013, transcript, C3PO OHP.

370 Michael J. Horkachuck, interview by Rebecca Wright, 

November 6, 2013, transcript, C3PO OHP.

371 Shotwell, interview. See also Lueders, interview.

372 Hans Koenigsmann, interview by Rebecca Hackler, January 

15, 2013, transcript, C3PO OHP.

373 Elias, interview.

374 Lueders, interview; Buzza, interview.

375 Lueders, interview.

376 Ibid.; William Gerstenmaier, “Need for Commercial Cargo 

to ISS” (PowerPoint presentation at Commercial Space 

Transportation Advisory Committee meeting, Washington, 

DC, May 18, 2007), 3, accessed September 30, 2013, http://

www.faa.gov/about/office_org/headquarters_offices/ast/

advisory_committee/meeting_news/media/COMSTAC_

Gerstenmaier%205_18_07.ppt. 

377 Issues Facing the U.S. Space Program after Retirement 

of the Space Shuttle: Hearing before the Subcommittee 

on Space, Aeronautics, and Related Sciences, United 

States Senate, 110th Cong., 1st sess., November 15, 

2007 (statement of Michael D. Griffin, NASA Administrator), 

accessed September 30, 2013, http://www.hq.nasa.gov/

legislative/hearings/2007%20hearings/11-15-07%20Griffin.

pdf; Michael Suffredini, “ISS Commercial Resupply Services” 

(PowerPoint presentation for Augustine Committee, June 17, 

2009), accessed September 30, 2013, http://www.nasa.gov/

pdf/361840main_13a%20-%20UPDATED%20Augustine%20

CRS%20final.pdf; Randolph H. Brinkley to Scott J. Horowitz, 

September 20, 2007, 2. Courtesy of Randolph H. Brinkley, 

email communication to JSC History Office, May 25, 2013. 

Griffin stated in his testimony that the RFI was issued on July 

7, 2007, but the other available sources state the date of 

issue as August 7, 2007.

378 Suffredini, “ISS Commercial Resupply Services,” 4; Lueders, 

interview. NASA Headquarters attorney Courtney Graham 

discussed how the timing of the CRS contract has led to 

the mistaken assumption within NASA that there is a natural 

transition from Space Act Agreement to contract in what is 

often referred to as the COTS/CRS model, when in actuality 

there is no requirement for a follow-on procurement. Sumara 

M. Thompson-King, Courtney B. Graham, and Karen M. 

Reilley, interview by Rebecca Hackler, March 19, 2013, 

transcript, C3PO OHP.

379 William H. Gerstenmaier, interview by Rebecca Wright, June 

12, 2013, transcript, C3PO OHP. See also Lueders, interview.

380 Thompson-King, Graham, and Reilley, interview.

381 Gerstenmaier, interview.

382 Government Accountability Office, Decision, Matter of: 

PlanetSpace, Inc., B-401016; B-401016.2, April 22, 

2009, accessed September 30, 2013, http://gao.gov/

assets/390/385763.pdf.

383 Ibid., 1.

384 Ibid., 7.
132 APPENDIX

385 “NASA Awards Space Station Commercial Resupply Services 

Contracts,” Contract Release: C08-069, NASA Headquarters 

Press Release, December 23, 2008, accessed September 

30, 2013, http://www.nasa.gov/home/hqnews/2008/dec/

HQ_C08-069_ISS_Resupply.html.

386 GAO, Decision, Matter of: PlanetSpace, Inc. 

387 Gerstenmaier, interview; Thompson-King, Graham, and 

Reilley, interview.

388 Lueders, interview.

389 Ibid. See also Alan J. Lindenmoyer, interview by Rebecca 

Wright, November 7, 2012, transcript, C3PO OHP.

390 Elias, interview.

391 Lueders, interview.

392 Ibid.

393 Commercial Cargo Augmentation White Paper, May 19, 

2010, 3, Commercial Crew & Cargo Program Office, 

Houston, TX.

394 NASA attorney Amy V. Xenofos described how she worked 

with C3PO and other members of the legal team to ensure 

the additional milestones fit within the scope of the original 

COTS Announcement and proposals. Amy V. Xenofos, 

interview by Rebecca Hackler, December 7, 2012, transcript, 

C3PO OHP.

395 Budget analysis by C3PO Resource Analysts Todd M. 

Hegemier and Lisa P. Price.

396 For the legal perspective on carrying cargo on the COTS 

demonstration flights see Xenofos, interview.

397 Commercial Launch Vehicles: NASA Taking Measures 

to Manage Delays And Risks: Hearing before the 

Subcommittee on Space and Aeronautics, United States 

House of Representatives, 112th Cong., 1st sess., 

May 26, 2011 (statement of Cristina T. Chaplain, GAO 

Director of Acquisition and Sourcing Management), 

accessed September 30, 2013, http://www.gao.gov/

assets/130/126310.pdf. 

398 Horkachuck, interview, January 16, 2013.

399 Bryan D. O’Connor, interview by Rebecca Wright, December 

18, 2012, transcript, JSC Oral History Project, JSC History 

Collection, University of Houston-Clear Lake, Houston, TX.

400 Cheryl Pellerin, “U.S. Agency Proposes Rules for Commercial 

Human Space Flights,” IIP Digital, January 13, 2006, accessed 

September 30, 2013, http://iipdigital.usembassy.gov/st/

english/article/2006/01/20060112141230lcnirellep0.3723871.

html#ixzz2Scxepl3O. 

401 “About the Office,” Office of Commercial Space 

Transportation, Federal Aviation Administration, last modified 

February 13, 2013, accessed September 30, 2013, http://

www.faa.gov/about/office_org/headquarters_offices/ast/

about/. See also Ronald K. Gress, “The Early Years, AST 

– A Historical Perspective,” in 2002 Commercial Space 

Transportation Lecture Series (Washington, DC: Office 

of the Associate Administrator for Commercial Space 

Transportation, April 2003), 2-20, accessed September 30, 

2013, http://www.faa.gov/about/office_org/headquarters_

offices/ast/reports_studies/archives/media/Volume_1.pdf.

402 George C. Nield, interview by Rebecca Hackler, March 

20, 2013, transcript, C3PO OHP. Nield began his tenure 

at the FAA in 2003 as Deputy Associate Administrator 

for AST, and in 2008 was promoted to the Associate 

Administrator for Commercial Spaceflight. Nield previously 

worked in the Space Shuttle Program at the NASA Johnson 

Space Center, followed by a few years at Orbital Sciences 

Corp. as the Senior Scientist for the Advanced Programs 

Group. “Dr. George C. Nield,” Office of Commercial Space 

Transportation, Federal Aviation Administration, last modified 

April 22, 2008, accessed September 30, 2013, http://www.

faa.gov/about/key_officials/nield/.

403 George Nield, interview by David Livingston, The Space 

Show (podcast), Broadcast 984, July 20, 2008, accessed 

September 30, 2013, http://www.thespaceshow.com/detail.

asp?q=984. 

404 Kurt Eberly and Michael R. Pinkston, interview by Rebecca 

Wright, June 3, 2013, transcript, C3PO OHP.

405 “Licenses, Permits & Approvals,” Office of Commercial Space 

Transportation, Federal Aviation Administration, last modified 

July 30, 2012, accessed September 30, 2013, http://www.

faa.gov/about/office_org/headquarters_offices/ast/licenses_

permits/safety_approvals/.

406 George C. Nield, email communication to JSC History Office, 

November 5, 2013. 

407 Commercial Space Launch Amendments Act of 2004, Public 

Law 108-492, 108th Cong., 2d. sess., (December 23, 2004), 

accessed September 30, 2013, http://www.faa.gov/about/

office_org/headquarters_offices/ast/media/PL108-492.

pdf. See also “House Approves H.R. 3752, The Commercial 

Space Launch Amendments Act of 2004,” House of 

Representatives Press Release, March 4, 2004, accessed 

September 30, 2013, http://www.spaceref.com/news/

viewpr.html?pid=13774.

408 FAA Modernization and Reform Act of 2012, Public Law 

112–95, 112th Cong., 2d. sess. (February 12, 2012), 

§827, accessed September 30, 2013, http://www.

faa.gov/regulations_policies/reauthorization/media/

PLAW-112publ95[1].pdf. See also Hearing before the 

Subcommittee on Science and Space, United States 

Senate, 112th Cong., 2d sess., June 20, 2012 (statement 

of Michael Lopez-Alegria, President of the Commercial 

Spaceflight Federation), accessed September 30, 2013, 

http://www.hq.nasa.gov/legislative/hearings/2012%20

hearings/6-20-2012%20LOPEZ-ALEGRIA.pdf.

409 See Jeff Foust, “Doubting Indemnification,” Space Politics 

(blog), March 27, 2012, accessed September 30, 2013, 

http://www.spacepolitics.com/2012/03/27/doubtingindemnification/; Michael Lopez-Alegria, statement.
APPENDIX 133

410 Government Accountability Office, Commercial Space 

Launches: FAA Needs Continued Planning and Monitoring to 

Oversee the Safety of the Emerging Space Tourism Industry, 

GAO-07-16, October 2006, accessed September 30, 2013, 

http://www.gao.gov/assets/260/252808.pdf.

411 Nield, interview.

Chapter 7

412 Commercial Crew Development, Announcement Number 

JSC-CCDev-1, Commercial Crew & Cargo Program Office, 

August 10, 2009, 1, Commercial Crew & Cargo Program 

Office, Houston, TX. The Program Integration Manager at 

JSC complied with the reporting requirements associated 

with these funds. Dennis A. Stone, email communication to 

JSC History Office, October 29, 2013.

413 Assessing Commercial Space Capabilities: Hearing before the 

Subcommittee on Science and Space, United States Senate,

111th Cong., 2d sess., March 18, 2010 (statement of Bryan 

O’Connor, NASA Chief of Safety and Mission Assurance), 

accessed September 30, 2013, http://www.gpo.gov/fdsys/

pkg/CHRG-111shrg66983/pdf/CHRG-111shrg66983.pdf. 

414 Geoffrey L. Yoder, Selection Statement for Commercial Crew 

Development (Announcement Number JSC-CCDev-1), 

December 8, 2009, 18, Commercial Crew & Cargo Program 

Office, Houston, TX.

415 Ibid.

416 Ibid., 19.

417 “CCDev Information,” NASA Commercial Crew & Cargo 

Program Office, last updated March 7, 2012, accessed 

November 20, 2013, http://www.nasa.gov/offices/c3po/

partners/ccdev_info.html. 

418 Alan Lindenmoyer to Michael J. Holquin (United Launch 

Alliance), April 5, 2011, Commercial Crew & Cargo Program 

Office, Houston, TX. CCDev Space Act Agreements 

courtesy of the Commercial Crew & Cargo Program Office, 

Houston, TX.

419 “Commercial Crew Program,” NASA Fact Sheet FS-2013-04-

084-KSC, accessed September 30, 2013, http://www.nasa.

gov/pdf/608888main_CCP.pdf. 

420 “NASA Awards Next Set Of Commercial Crew Development 

Agreements,” NASA Headquarters Press Release, April 18, 

2011, accessed September 30, 2013, http://www.nasa.gov/

home/hqnews/2011/apr/HQ_11-102_CCDev2.html. 

421 “NASA Awards Commercial Crew Certification Contracts,” 

NASA Commercial Space Transportation, December 11, 

2012, accessed September 30, 2013, http://www.nasa.gov/

exploration/commercial/crew/cpc-awards.html. 

422 Denise Chow, “NASA Revises Plan to Buy Private Space 

Taxis,” Space.com, December 15, 2011, accessed 

September 30, 2013, http://www.space.com/13953-nasacommercial-crew-space-act-agreements.html.

Chapter 8

423 “NASA Hails Success of Commercial Space Program 

Private Space Station Resupply Underway, Plans Readied 

for Astronauts,” NASA Press Release, November 13, 2013, 

accessed November 14, 2013, http://www.nasa.gov/

press/2013/november/nasa-hails-success-of-commercialspace-program-private-space-station-resupply/. 

424 Vision for Space Exploration (Washington, DC: NASA, 

February 2004), introductory material, accessed September 

30, 2013, http://www.nasa.gov/pdf/55583main_vision_

space_exploration2.pdf. Emphasis added.

425 Michael J. Horkachuck, interview by Rebecca Wright, 

November 6, 2013, transcript, Commercial Crew & Cargo 

Program Office History Project, JSC History Collection, 

University of Houston-Clear Lake, Houston, TX (hereafter 

cited as C3PO OHP). See also Amy V. Xenofos, interview 

by Rebecca Hackler, December 7, 2012, transcript, C3PO 

OHP and Alan J. Lindenmoyer, interview by Rebecca Wright, 

October 31, 2012, transcript, C3PO OHP. Congressional 

testimony by GAO representatives in 2007 reported that 

NASA planned to use the commercial services under 

development to fill the gap between Shuttle retirement and 

NASA’s new Orion and Ares vehicles. See Issues Surrounding 

the Transition from the Space Shuttle to the Next Generation 

of Human Space Flight Systems: Hearing before the 

Subcommittee on Space, Aeronautics, and Related Sciences, 

United States Senate, 110th Cong., 1st sess., March 28, 

2007 (statement of Allen Li, GAO Director of Acquisition and 

Sourcing Management), accessed September 30, 2013, 

http://www.gao.gov/assets/120/116060.pdf.

426 William H. Gerstenmaier, interview by Rebecca Wright, June 

12, 2013, transcript, C3PO OHP.

427 Hearing Charter: NASA’s Commercial Cargo Providers; Are 

They Ready to Supply the Space Station in the Post-Shuttle 

Era?: Hearing before the Subcommittee on Space and 

Aeronautics, United States House of Representatives,112th 

Cong., 1st sess., May 26, 2011, 7, accessed September 30, 

2013, http://science.house.gov/sites/republicans.science.

house.gov/files/documents/hearings/052611_charter_1.pdf.

428 Horkachuck, interview; Alan J. Lindenmoyer, interview by 

Rebecca Wright, November 7, 2012, transcript, C3PO OHP; 

Marc G. Timm, interview by Rebecca Wright, June 12, 2013, 

transcript, C3PO OHP.

429 “Statement on the Launch of Antares,” White House 

Office of Science and Technology Policy, April 21, 2013, 

accessed September 30, 2013,http://www.whitehouse.gov/

blog/2013/04/21/statement-launch-antares.

430 NASA Office of Inspector General, NASA’s Efforts to 

Maximize Research on the International Space Station,

Report No. IG-13-019, July 8, 2013, i, accessed 

September 30, 2013,http://oig.nasa.gov/audits/reports/

FY13/IG-13-019.pdf.
134 APPENDIX

431 “NASA Hails Success of Commercial Space Program 

Private Space Station Resupply Underway, Plans Readied 

for Astronauts,” NASA Press Release, November 13, 2013, 

accessed November 14, 2013, http://www.nasa.gov/

press/2013/november/nasa-hails-success-of-commercialspace-program-private-space-station-resupply/.

432 Kathryn L. Lueders, interview by Rebecca Hackler, April 17, 

2013, transcript, C3PO OHP; Peter Capozzoli, interview by 

Rebecca Wright, January 16, 2013, transcript, C3PO OHP.

433 Randolph H. Brinkley, interview by Rebecca Hackler, May 1, 

2013, transcript, C3PO OHP.

434 Frank Morring, Jr., “Gerstenmaier: ISS Will Shape 

Commercial Spaceflight,” Aviation Week & Space Technology, 

February 7, 2013, accessed September 30, 2013, http://

www.aviationweek.com/Article.aspx?id=/article-xml/

asd_02_07_2013_p04-02-545867.xml. For more on 

potential scientific uses of suborbital and orbital space 

vehicles see S. Alan Stern, “The Low-Cost Ticket to Space,” 

Scientific American, April 2013.

435 NASA’s Efforts to Maximize Research on the International 

Space Station, 4.

436 See “Fact Sheet: NanoRacks Platforms,” International 

Space Station, NASA, accessed November 8, 2013, 

http://www.nasa.gov/mission_pages/station/research/

experiments/829.html. 

437 See NASA’s Efforts to Maximize Research on the International 

Space Station, 9.

438 Gerstenmaier, interview. See also James A.M. Muncy, 

interview by Rebecca Wright, June 21, 2013, transcript, 

C3PO OHP.

439 “NASA to Test Bigelow Expandable Module on Space 

Station,” International Space Station Feature, January 16, 

2013, accessed September 30, 2013, http://www.nasa.gov/

mission_pages/station/news/beam_feature.html; Kenneth 

Chang, “For Space Station, a Pod That Folds Like a Shirt 

and Inflates Like a Balloon,” New York Times, January 

16, 2013, accessed September 30, 2013, http://www.

nytimes.com/2013/01/17/science/space/for-nasa-bigelowaerospaces-balloonlike-module-is-innovative-and-a-bargaintoo.html.

440 Irene Klotz, “NASA Pushing to Keep ‘Space Taxi’ Competition 

Going,” Reuters, July 31, 2013, accessed September 30, 

2013, http://www.reuters.com/article/2013/07/31/us-spacetaxis-idUSBRE96U1IY20130731. 

441 “DragonLab Fact Sheet,” Space Exploration Technologies 

Corp., accessed September 30, 2013, http://www.spacex.

com/sites/spacex/files/pdf/DragonLabFactSheet.pdf; David 

Giger, interview by Rebecca Hackler, January 15, 2013, 

transcript, JSC Oral History Project, C3PO OHP; John 

Couluris, interview by Rebecca Hackler, January 15, 2013, 

transcript, C3PO OHP.

442 SpaceUp Houston, 2013 Commercial Spaceflight Panel, 

Part 1 - COTS/CCiCap, Houston, TX, February 8, 2013, 

accessed September 30, 2013, http://livestre.am/4kEmv; 

Frank DeMauro, interview by Rebecca Hackler, June 4, 2013, 

transcript, C3PO OHP; Frank L. Culbertson, interview by 

Rebecca Wright, June 4, 2013, transcript, C3PO OHP. 

443 Robert T. Richards, interview by Rebecca Hackler, June 4, 

2013, transcript, C3PO OHP. See also David W. Thompson, 

interview by Rebecca Wright, June 3, 2013, transcript, 

C3PO OHP.

444 Lori Garver, “Business at the Speed of Innovation” (speech 

delivered at International Symposium for Personal and 

Commercial Spaceflight, Las Cruces, New Mexico, October 

20, 2011), accessed September 30, 2013, http://www.nasa.

gov/pdf/598634main_102011_Garver_Remarks_FINAL.pdf.

445 The government investment total for Orbital included 

approximately $137 million in funding sources other 

than COTS, including the ISS Program, the NASA Wallops 

Flight Facility, and the Commonwealth of Virginia. 

David W. Thompson, email communication to JSC History 

Office and Commercial Crew & Cargo Program Office, 

November 21, 2013.

446 NASA Associate Deputy Administrator for Policy, “Falcon 

9 Launch Vehicle NAFCOM Cost Estimates” (PowerPoint 

presentation, August 2011), accessed September 30, 2013, 

http://www.nasa.gov/pdf/586023main_8-3-11_NAFCOM.pdf. 

447 Budget analysis by Todd M. Hegemier and Lisa P. Price, 

C3PO Resource Analysts. See also “Falcon 9,” Space 

Exploration Technologies Corp., accessed September 30, 

2013, http://www.spacex.com/falcon9.

448 Lisa P. Price, interview by Rebecca Hackler, May 14, 2013, 

transcript, C3PO OHP. Price was unable to share more 

specific figures due to the priority to protect competition 

sensitive information. See also NASA Aerospace Safety 

Advisory Panel, Annual Report for 2013, 12, January 15, 

2014, accessed February 24, 2014, http://oiir.hq.nasa.gov/

asap/documents/2013_ASAP_Annual_Report.pdf. 

449 Government Accountability Office, Commercial Partners 

Are Making Progress, but Face Aggressive Schedules 

to Demonstrate Critical Space Station Cargo Transport 

Capabilities, GAO-09-618, June 2009, 9, accessed 

September 30, 2013, http://www.gao.gov/new.items/

d09618.pdf.

450 Mike Horkachuck, conversation with JSC History 

Office at SpaceX headquarters in Hawthorne, California, 

January 16, 2013.

451 Lauren Hepler, “Mars needs workers! Space startups 

desperate for talent,” Silicon Valley Business Journal, July 

19, 2013, accessed September 30, 2013, http://www.

bizjournals.com/sanjose/news/2013/07/18/the-next-stemtalent-crunch-space-tech.html?page=all. 
APPENDIX 135

452 “History of MARS,” Mid-Atlantic Regional Spaceport, 

accessed September 30, 2013, http://www.marsspaceport.

com/mid-atlantic-spaceport-history.

453 Kody Leibowitz, “Antares Set To Launch Wednesday With 

High Hopes From Congress,” WMDT 47 News, September 

17, 2013, accessed September 30, 2013, http://www.wmdt.

com/story/23458667/antares-set-to-launch-wednesdaywith-high-hopes-from-congress. 

454 “Goal and Objectives,” Commercial Crew & Cargo Program 

Office, accessed September 30, 2013, http://www.nasa.gov/

offices/c3po/home/c3po_goal_objectives.html.

455 Sumara M. Thompson-King, Courtney B. Graham, and Karen 

M. Reilley, interview by Rebecca Hackler, March 19, 2013, 

transcript, C3PO OHP.

456 Since ending his term as Administrator, Mike Griffin has 

argued for the establishment of a Moon base in order to 

build a truly commercial space transportation industry—

what Griffin had originally envisioned at the outset of the 

COTS program. This new outpost would require much 

greater cargo delivery services than the ISS. Michael 

D. Griffin, “Enabling Complementary Commercial and 

Government Enterprises in Space” (paper presented at the 

62nd International Astronautical Congress, Cape Town, 

South Africa, October 3–7, 2011).

457 Timm, interview. See also Lori B. Garver, interview by 

Rebecca Wright, June 26, 2013, transcript, C3PO OHP.

458 Timm, interview; Irene Klotz, “Europe Braces for Competition 

from Low-Cost U.S. Satellite Launcher,” Reuters, June 

19, 2013, accessed September 30, 2013, http://www.

reuters.com/article/2013/06/19/us-air-show-spacexidUSBRE95I16D20130619. See also Hearing before the 

Subcommittee on Science and Space, United States 

Senate, 112th Cong., 2d sess., June 20, 2012 (statement 

of Michael Lopez-Alegria, President of the Commercial 

Spaceflight Federation), accessed September 30, 2013, 

http://www.hq.nasa.gov/legislative/hearings/2012%20

hearings/6-20-2012%20LOPEZ-ALEGRIA.pdf.

459 Klotz, “Europe Braces for Competition”; Jonathan Amos, 

“ESA Selects Ariane 6 Basic Design,” BBC News, July 9, 

2013, accessed September 30, 2013, http://www.bbc.

co.uk/news/science-environment-23241158. Arianespace 

has been in competition with the U.S. launch market since 

the company’s founding in 1980. See David P. Gump, Space 

Enterprise: Beyond NASA (New York: Praeger, 1990), 41–42. 

For a list of future contracted SpaceX missions see “Launch 

Manifest,” Space Exploration Technologies Corp., accessed 

September 30, 2013, http://www.spacex.com/missions. 

460 Warren Ferster, “$900M in Pentagon Launch Contracts 

Awarded to Lockheed, Orbital, SpaceX,” SpaceNews,

December 3, 2012, accessed September 30, 2013, www.

spacenews.com/article/900m-in-pentagon-launch-contractsawarded-to-lockheed-orbital-spacex.

461 Kurt Eberly and Michael R. Pinkston, interview by Rebecca 

Wright, June 3, 2013, transcript, C3PO OHP.

462 Traci Watson, “Second Private Spacecraft Set for Space 

Station Run,” USA Today, September 18, 2013, accessed 

September 30, 2013, http://www.usatoday.com/story/news/

nation/2013/09/17/spacecraft-resupply-international-spacestation/2825541/. 

463 “World’s First Commercial Space Operations Degree OK’d 

for Liftoff at Embry-Riddle,” Embry-Riddle Aeronautical 

University Press Release, March 26, 2013, accessed 

September 30, 2013, http://daytonabeach.erau.edu/news/

space-operations-degree.html; Deborah Circelli, “ERAU 

students over the moon about new degree,” Daytona Beach 

News-Journal, September 8, 2013, accessed September 30, 

2013, http://www.news-journalonline.com/article/20130908/

NEWS/130909512/1042/NEWS0401?Title=ERAU-studentsin-outer-space-with-new-degree&tc=ar. 

464 Zach Rosenberg, “Worldwide Space Economy Grew 

in 2011,” Flight International, April 2, 2013, accessed 

September 30, 2013, http://www.flightglobal.com/news/

articles/worldwide-space-economy-grew-in-2011-384121/.

465 Clayton M. Christensen, The Innovator’s Dilemma: The 

Revolutionary Book That Will Change the Way You Do 

Business (New York: Harper Business, 2011), 165. Emphasis 

in the original.

466 NASA Aerospace Safety Advisory Panel, Annual Report for 

2013, 19. 

467 Ibid.

468 NASA Policy Directive 1000.5B, Policy for NASA Acquisition, 

December 19, 2013, accessed February 24, 2014, http://

nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPD&c=1000&s=5B.

469 “Enhancing NASA Partnerships,” NASA Executive Council, 

Decision Memo EC-2013-05-001a, July 17, 2013, 

Commercial Crew & Cargo Program Office, Houston, TX. 

470 Bretton Alexander, interview by Rebecca Wright, March 18, 

2013, transcript, C3PO OHP.

471 Garver, interview.

472 Alan J. Lindenmoyer, “The COTS Model for NASA PublicPrivate Partnerships,” April 18, 2010. Commercial Crew & 

Cargo Program Office, Houston, TX.

473 Editorial, “A Space Policy Success Story,” SpaceNews, 

December 16, 2013, accessed February 27, 2014, http://

www.spacenews.com/article/opinion/38718editorial-aspace-policy-success-story. Reprinted by permission of 

Brian Berger, (SPACENEWS), 

email communication to Commercial Crew & Cargo Program 

Office, February 27, 2014.
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Commercial Orbital Transportation Services: A New Era in Spaceflight

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From 2006 to 2013, the Commercial Orbital Transportation Services (COTS) program administered by the Commercial Crew & 

Cargo Program Office (C3PO) at the Johnson Space Center endeavored to stimulate U.S. commercial space transportation capabilities 

by pursuing a new way of doing business with industry. C3PO collaborated with a team of attorneys, procurement specialists, and even 

a venture capitalist to formulate and implement a new form of funded Space Act Agreement (SAA) based on the Agency’s “Other 

Transaction” Authority. In August 2006, NASA selected SpaceX and Rocketplane Kistler as its first COTS partners. However, NASA 

terminated the agreement with Rocketplane Kistler due to the company’s funding issues, and in February 2008 the Agency selected 

Orbital Sciences Corporation as its new industry partner. NASA worked with SpaceX and Orbital to meet the financial, programmatic, 

and technical milestones of their funded SAAs—milestones that would culminate in the development of new, commercially-owned 

transportation services to the International Space Station. The COTS program helped to realize the vision of cost-effective, U.S. space 

transportation capabilities and a successful partnership with industry.

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