JUNE 30, 2011

AUDIT REPORT

REPORT NO. IG-11-022 (ASSIGNMENT NO. A-10-010-00)

OFFICE OF AUDITS

NASA’S CHALLENGES CERTIFYING AND ACQUIRING 

COMMERCIAL CREW TRANSPORTATION SERVICES

OFFICE OF INSPECTOR GENERAL

National Aeronautics and 

Space Administration
REPORT NO. IG-11-022

Final report released by:

Paul K. Martin

Inspector General

Acronyms

CCDev Commercial Crew Development

COTS Commercial Orbital Transportation Services

CRS Commercial Resupply Services

EELV Evolved Expendable Launch Vehicle

FAA Federal Aviation Administration

FAR Federal Acquisition Regulation

FY Fiscal Year

NPD NASA Policy Directive

NPR NASA Procedural Requirements
JUNE 30, 2011

REPORT NO. IG-11-022

OVERVIEW

NASA’S CHALLENGES CERTIFYING AND ACQUIRING 

COMMERCIAL CREW TRANSPORTATION SERVICES

The Issue

After more than 30 years and 130 flights, NASA’s Space Shuttle fleet will retire this 

year, leaving the United States dependent on the Russian Soyuz vehicle for crew 

transportation to and from the International Space Station until the next generation of 

U.S. space vehicles is ready for flight.

1

1. Developing a Government-owned multi-purpose crew vehicle and Space Launch 

System for human exploration beyond low Earth orbit;

 To develop this next generation of vehicles, 

NASA is simultaneously embarking on two paths: 

2

2. Stimulating the development of a commercial space industry capable of providing 

NASA with safe, reliable, and cost-effective access to and from the International 

Space Station and low Earth orbit.

and 

3

While NASA has over 50 years of experience with contractor-built, Government-owned 

space vehicles, the Agency has never procured transportation for its astronauts aboard a 

commercially developed vehicle. Of primary concern in this new paradigm is how the 

Agency will work with its commercial partners to ensure that commercially developed 

vehicles meet NASA’s safety and human-rating requirements. These requirements seek 

to ensure that spaceflight systems accommodate human needs, control hazards, manage 

safety risks, and, to the maximum extent possible, provide the capability to recover the 

crew safely from hazardous situations.

 

4

 1 With completion of STS-133 on March 9, 2011, Space Shuttle Discovery has flown its last mission and 

is the first vehicle in the Shuttle fleet to be retired. Space Shuttle Endeavour completed its last mission 

(STS-134) on June 1, 2011 and the remaining Space Shuttle, Atlantis, will complete its final mission 

later this year. 

 

2 “Low Earth orbit” is commonly defined as between 100 and 1,240 miles above the Earth’s surface. 

3 The NASA Authorization Act of 2010 (Public Law 111-267) stipulated that NASA’s new multi-purpose 

crew vehicle and Space Launch System are to expand human spaceflight beyond the Space Station and 

low Earth orbit no later than December 31, 2016. The vehicles will also serve as a backup in the event 

that commercial industry cannot provide Space Station crew transportation services at that time. The 

NASA Authorization Acts of 2005 (Public Law 109-155), 2008 (Public Law 110-422), and 2010 

collectively directed NASA to use commercially developed systems to the maximum extent practicable 

for crew and cargo transportation to the Space Station. 

4 NASA Procedural Requirements 8705.2B, “Human-Rating Requirements for Space Systems 

(w/change 1 dated 12/7/2009),” May 6, 2008. 
OVERVIEW

ii REPORT NO. IG-11-022

Given the importance of the shift in NASA’s approach to acquiring human access to 

space, the Office of Inspector General examined the Agency’s efforts to modify its

existing safety and human-rating requirements to make them applicable to commercially 

developed vehicles. We also evaluated the overarching challenges associated with

possible approaches NASA may use to certify and acquire commercial crew 

transportation services. Details of the audit scope and methodology are in Appendix A.

Results

NASA is making sustained progress toward acquiring commercial crew transportation 

services. For example, in 2009 the Agency initiated the Commercial Crew Development 

(CCDev) effort to focus on developing systems and concepts that will help establish an 

industry capable of transporting astronauts to low Earth orbit and the Space Station. The 

following year, NASA awarded $50 million in funded Space Act Agreements to 

encourage the development of system concepts and capabilities that could enable 

commercial crew transportation services.

5

Modifying NASA’s Existing Safety and Human-Rating Requirements for

Commercially Developed Systems. On December 8, 2010, NASA issued a consolidated 

set of health and medical, engineering, and safety and mission assurance requirements 

that commercial partners will have to meet to obtain certification to transport astronauts 

to low Earth orbit titled, “Commercial Crew Transportation System Certification 

Requirements for NASA Low Earth Orbit Missions” (Certification Requirements). 

However, NASA has not finalized the processes Agency officials will use to verify that 

commercial partners have met these requirements and subsequently certify that a 

commercial partner’s vehicle can safely transport NASA personnel. In May 2011, the 

Agency released for industry review and comment six draft documents (the 1100-series)

that supplement the Certification Requirements relating to missions to the Space Station. 

These documents provide additional information to commercial partners regarding roles 

and responsibilities, technical management processes supporting certification, crew 

transportation system and Space Station services requirements, and the application of 

technical and operations standards.

 In April 2011, the Agency announced a 

second round of CCDev awards (CCDev 2) totaling $269.3 million to accelerate the 

availability of U.S. commercial crew transportation capabilities. However, even with the 

additional funding planned, NASA faces multiple challenges and risks as it expands its 

Commercial Crew Transportation program. These include:

6

 5 Pursuant to the National Aeronautics and Space Act of 1958 and NASA policy (NASA Policy Directive 

1050.1l, “Authority to Enter into Space Act Agreements,” December 23, 2008), NASA may enter into 

Space Act Agreements to meet mission and program objectives. The agreements, which represent a set 

of legally enforceable promises, are classified as reimbursable, non-reimbursable, or funded. NASA may 

only enter into funded Space Act Agreements with domestic agencies, persons, corporations, or 

educational institutions when the Agency’s objective cannot be accomplished through a contract, grant, 

or cooperative agreement.

 

6 NASA plans to issue the baseline 1100-series documents by the end of the year.
OVERVIEW

REPORT NO. IG-11-022 iii

Despite the absence of finalized requirements from NASA, the private sector is already 

designing and developing systems and vehicles to meet NASA’s crew transportation 

needs and interested companies have provided input on NASA’s commercial crew 

transportation requirements. Specifically, industry representatives have suggested that

NASA (1) modify existing requirements to the greatest extent possible and ensure they 

are achievable so that industry fully understands what is expected; (2) coordinate with the 

Federal Aviation Administration (FAA) – which has regulatory oversight of U.S.

companies providing commercial space transportation services – to ensure NASA 

requirements and FAA regulations are compatible; and (3) allow for flexibility so that 

changes in vehicle or system design are attainable within reasonable costs.

7

Additionally, in response to the CCDev 2 announcement for proposals, NASA received

multiple questions from industry representatives seeking clarification on the requirements

published to date, the timing of release of additional requirements, and NASA’s 

expectations for fulfilling the requirements. One industry representative questioned a 

draft requirement that commercial partner vehicles be able to provide a 95 percent abort 

effectiveness capability – a requirement NASA itself has never met.

 

8

Selecting an Acquisition Strategy for Commercial Crew Transportation Services. 

NASA is still developing its acquisition strategy and has not settled on the specific 

mechanisms it will use for procuring commercial crew transportation services. The 

Commercial Crew Program Planning Office (Commercial Crew Office) plans to present 

its proposed acquisition strategy to Congress by late summer 2011. Mindful of national 

policy to limit the use of high-risk contracting vehicles such as noncompetitive and costreimbursement contracts, among the options NASA may consider is an acquisition

strategy that relies on funded Space Act Agreements, competitive procurements, in 

particular fixed-price contracts, or a combination of both.

 NASA officials

said they hope to strike a balance that will enable innovation and flexibility yet prescribe 

the minimum number of requirements deemed essential to ensure the safety of NASA’s 

astronauts.

9

Each of these possible approaches poses financial and programmatic challenges to 

NASA’s efforts to procure crew transportation services. For example, the use of funded 

Space Act Agreements limits Government control compared to traditional procurement 

 

 7 In August 2010, the FAA sponsored a commercial human spaceflight workshop attended by a 

representative from NASA’s Commercial Crew Office and industry representatives. According to the 

FAA, the companies were selected for participation based on their demonstrated capabilities and interest 

in participating in the commercial human spaceflight transportation industry.

8 Requirement 3.3.1.6 in the draft version of “International Space Station Crew Transportation and 

Services Requirements Document” (CCT-REQ-1130) states, “The CTS [Commercial Transportation 

System] shall provide an overall abort effectiveness of 0.95 . . ..”

9 A procurement contract is defined by the Federal Acquisition Regulation (48 C.F.R. § 2.101), while the 

Federal Grants and Cooperative Agreements Act of 1977 (Chiles Act) (31 U.S.C. § 6303) establishes the 

general criteria that Federal agencies must follow when deciding which legal instrument to use when 

entering into a funding relationship. The principal purpose of a procurement contract is to obtain 

property or services for the direct benefit or use of the Government.
OVERVIEW

iv REPORT NO. IG-11-022

contracts based on the Federal Acquisition Regulation. Moreover, according to Agency 

policy, NASA may only enter into funded Space Act Agreements when its objective 

cannot be accomplished through a contract, grant, or cooperative agreement. Further, if 

the expected deliverables meet NASA’s transportation needs, a procurement contract is 

required. 

Consistent with these principles, the primary purpose of CCDev is to stimulate the private 

sector and aid in the development of commercial human spaceflight capabilities that 

NASA could use to transport astronauts to low Earth orbit and the Space Station. As one 

potential customer of this private sector market, NASA expects the CCDev Space Act 

Agreements to result in commercial capabilities that consider the Agency’s Certification 

Requirements. However, the Agency is not dictating specific system concepts or 

elements or mandating compliance with its requirements. Rather, CCDev participants are 

free to determine the system requirements and concepts they believe will best serve their

target markets. Since crew transportation for NASA is the most viable segment of the 

human spaceflight market in the short term, it is in the companies’ best interest to ensure 

compliance with NASA requirements if they hope to obtain NASA’s business. 

Nevertheless, the lack of mandatory compliance with NASA’s requirements presents 

some risk that differences between partner designs and Agency requirements could occur. 

Similarly, the potential use of fixed-price contracts for crew transportation services also 

presents challenges. Traditionally, cost-reimbursement rather than fixed-price contracts 

have been used on projects in which costs and risks are not clearly defined. While fixedprice contracts lock in the Government’s initial investment, proceeding in this manner 

would not eliminate cost risks. Some of NASA’s potential commercial crew partners are 

building spacecraft for the first time and design and development are under way without 

fully defined and finalized requirements. In this type of environment, there is a risk that 

during the period of contract performance NASA’s requirements may change so 

significantly that contractors can successfully argue that the Agency is changing the 

contract’s scope, in which case NASA could be required to pay the contractor to make 

necessary modifications. 

Finally, NASA must consider whether to continue purchasing additional seats on the 

Russian Soyuz vehicle as a contingency to possible delays in obtaining commercial crew 

transportation. Currently, NASA has purchased seats on the Soyuz vehicle to ensure 

continued U.S. access to the Space Station through June 2016. Because of the long leadtime required for procuring Soyuz seats and planning a mission to the Space Station, 

NASA would have to make the decision to purchase additional seats in 2013, 

approximately 3 years before commercial systems are expected to be ready.

Establishing the Appropriate Insight/Oversight Model for Commercial Partner 

Vehicle Development. In selecting the timing and appropriateness of potential

procurement mechanisms, NASA must balance its role as a supporter of commercial 

partners with its responsibility to ensure that U.S. commercially developed vehicles are 

safe for NASA astronauts, meet the Agency’s needs, and provide for a viable domestic 

alternative to the Soyuz vehicle. The Commercial Crew Office is developing the model 
OVERVIEW

REPORT NO. IG-11-022 v

for NASA’s insight and oversight of commercial companies.

10

While commercial partners are designing their launch systems, NASA will function in an 

insight role, forming partnerships with companies to increase the Agency’s understanding 

of their system designs. During this phase of the process, NASA may consider an 

approach that assigns a core team to follow a specific CCDev partner throughout the life

cycle of its launch system. Once the CCDev initiative has ended, NASA may award

contracts or continue to use funded Space Act Agreements for commercial vehicle 

development, test, and evaluation. The Agency would be both stimulating a commercial 

crew industry and assisting the commercial partners to develop safe, reliable, and costeffective vehicles that meet NASA’s Certification Requirements. While NASA will still 

need to maintain insight into the development of each vehicle, at this stage of the process 

the Agency may assume more of an oversight role in granting approval or direction to 

each partner on the path to certification. As of May 2011, NASA has not finalized the 

oversight model for this phase, including defining key decisions regarding what will be 

required of commercial partners to successfully pass each milestone. Selecting the 

appropriate level and mechanisms of insight and oversight is necessary to provide NASA 

with sufficient information to assess partners’ technical, schedule, and cost risks and 

certify that commercially developed vehicles are safe for NASA astronauts without

unduly affecting the commercial partners’ ability to operate in a cost-effective manner. 

According to NASA 

policy, “insight” means acquiring knowledge and an understanding of contractors’ 

actions by monitoring selected metrics and milestones. Methods of achieving insight 

include reviewing documents, attending meetings and tests, and conducting compliance 

evaluations. “Oversight” combines technical insight of contractor activities with 

approvals that provide the contractor with formally documented authority to proceed or 

formal acceptance of plans, tests, or other criteria. 

Because NASA is not dictating specific system concepts or elements or mandating

compliance with its requirements when using funded Space Act Agreements, companies 

may develop vehicles that deviate from Agency requirements. To mitigate this risk, 

NASA is considering an approach that would identify significant differences between 

design and requirements that may prevent a partner from obtaining NASA’s certification 

in the later phases of the acquisition process. However, conducting such an analysis for 

CCDev partners may be perceived as an unfair competitive advantage for non-CCDev 

companies. In fact, in response to its October 2010 CCDev 2 announcement, NASA

received at least one question on the possible relationship between CCDev awards and 

future contracts. An industry representative inquired whether NASA anticipates overlap 

between CCDev 2 and any future procurement, such as commercial crew demonstration 

or transportation services contracts. NASA responded that there is no relationship 

between the two phases of acquisition. Moreover, according to the Agency’s Space Act 

Agreements Guide, such a relationship or perceived relationship can lead to claims of a 

conflict of interest. If NASA fails to address such potential conflicts or develop 

 10 NASA Policy Directive 8610.23C, “Launch Vehicle Technical Oversight Policy,” August 18, 2006.
OVERVIEW

vi REPORT NO. IG-11-022

appropriate mitigation plans, the Agency could face a bid protest, which could cause 

delays and jeopardize the success of NASA’s commercial crew program. 

Relying on an Emerging Industry and Uncertain Market Conditions to Achieve 

Cost Savings. In the NASA Authorization Act of 2010, Congress stated that commercial 

companies offer the potential of providing lower cost crew transportation services to 

support the Space Station. In fact, NASA’s acquisition strategy for procuring crew 

transportation services is premised on competition and a healthy commercial human 

spaceflight industry, which would allow NASA to solicit bids from a number of partners 

and make informed, competitive procurement decisions that meet individual mission 

requirements and provide the best value for the taxpayer. However, the commercial 

human spaceflight industry is in its infancy, and the market beyond NASA’s own crew 

transportation needs is uncertain. Many of the risks associated with achieving anticipated 

cost savings are largely out of NASA’s control, particularly in the area of creating nonGovernment demand for commercial human spaceflight services. The NASA 

Authorization Act of 2010 directs the Agency to work with the FAA’s Office of 

Commercial Space Transportation and assess the potential non-Government market for 

commercially developed crew and cargo transportation systems and capabilities. In April 

2011, NASA and the FAA reported that over time the market for commercial crew and 

cargo services may emerge and provide significantly more customers, more flights, and 

potentially lower prices to the U.S. Government. The continuing challenge will be to 

determine at what point the market can sustain a number of commercial partners, 

allowing NASA to transition to the role of consumer and ultimately realize cost-effective 

commercial crew transportation.

Managing the Relationship Among Commercial Partners, the FAA, and NASA. The 

FAA is responsible for regulatory oversight of companies seeking to provide commercial 

human space transportation. To date, the FAA has issued regulations pertaining to 

launch and reentry activities that could affect the public safety. However, in December 

2012 the FAA is authorized to begin proposing regulations concerning the safety of 

passengers and crew involved in commercial spaceflight. As previously discussed, 

NASA plans to impose its own set of requirements, standards, and processes that 

commercial partners must meet to obtain a certification before transporting Agency

personnel. Accordingly, NASA must coordinate with the FAA to avoid an environment 

of conflicting requirements and multiple sets of standards for commercial companies 

seeking to transport Government and non-Government passengers to low Earth orbit. 

Toward that end, the FAA and NASA have expressed a spirit of cooperation, and both 

groups have agreed that the goal is FAA licensing of commercially developed vehicles 

used to transport NASA personnel. Additionally, the agencies are co-locating personnel 

at NASA Headquarters, FAA field offices, and Johnson and Kennedy Space Centers to 

optimize Government oversight of commercial partners through compatible 

requirements, standards, and processes.
OVERVIEW

REPORT NO. IG-11-022 vii

Management Action

Separately managing each challenge associated with certifying and acquiring commercial 

crew transportation services is difficult enough, but because the challenges are inherently 

related this creates additional complications. For example, the degree and nature of 

requirements levied on commercial partners will have an impact on both NASA’s chosen 

acquisition strategy and the insight/oversight model the Agency will use to verify that the 

requirements are met. Also, to mitigate risks associated with relying on a single 

commercial partner and to help achieve anticipated costs savings, NASA’s acquisition 

strategy should encourage competition between multiple commercial partners. However, 

the viability of the commercial human spaceflight market is uncertain beyond NASA’s 

mission requirements, and the costs the industry must bear – such as those associated 

with operating in an environment of multiple standards and requirements established by 

NASA and the FAA – may deter companies from entering such an uncertain market. 

While we are not making specific recommendations for corrective action, we believe 

NASA must pay particular attention to the challenges highlighted in this report. 

Specifically, NASA should:

• clearly articulate to its commercial partners as soon as possible all requirements

for commercially developed systems and the processes NASA will use for 

certifying such systems; 

• maintain robust communication with the emerging commercial spaceflight 

industry to ensure that Agency contracting mechanisms include the appropriate 

balance between insight and oversight that will provide NASA with sufficient 

information to assess and certify commercial partners’ systems while providing 

companies the flexibility to innovate;

• clearly articulate how it will mitigate potential conflicts of interest that may arise 

as a result of any analysis that could provide an unfair competitive advantage to a 

NASA partner; and 

• expand coordination with the FAA to avoid the potentially serious business 

impacts that would result if commercial companies were required to operate in an 

environment that included inconsistent standards for NASA certification and 

FAA licensing of the same vehicle. 

In response to a draft of this report, the Associate Administrator for Exploration Systems 

Mission Directorate agreed that NASA should pay particular attention to the challenges 

highlighted in the report. The Associate Administrator also noted that NASA’s 

acquisition strategy for the Commercial Crew Program is still under consideration and 

subject to further change as the procurement process matures (see Appendix C for the 

Agency’s response). 

JUNE 30, 2011

REPORT NO. IG-11-022

CONTENTS

INTRODUCTION

Background _________________________________________ 1

Objectives __________________________________________ 6

RESULTS

Challenges Associated with Certifying and Acquiring

Commercial Crew Transportation Services _______________ 7

Modifying NASA’s Existing Safety and Human-Rating 

Requirements for Commercially Developed Systems ____ 7

Selecting an Acquisition Strategy for Commercial Crew 

Transportation Services __________________________ 11

Establishing the Appropriate Insight/Oversight Model for 

Commercial Partner Vehicle Development ____________ 15

Relying on an Emerging Industry and Uncertain Market 

Conditions to Achieve Cost Savings _________________ 18

Managing the Relationship Among Commercial Partners, 

the FAA, and NASA _____________________________ 20

Conclusion ________________________________________ 22

Management Action _________________________________ 23

APPENDIX A

Scope and Methodology_______________________________ 25

Review of Internal Controls ____________________________ 28

Prior Coverage ______________________________________ 28

APPENDIX B

Technical Authority Standards and Requirements ___________ 29

APPENDIX C

Management Comments ______________________________ 35
CONTENTS

REPORT NO. IG-11-022

APPENDIX D

Report Distribution___________________________________ 37
JUNE 30, 2011

REPORT NO. IG-11-022 1

INTRODUCTION

Background

The concept of human rating a spacecraft – that is, determining that a vehicle can safely

carry humans into space – has evolved based on the knowledge and technology available 

at the time and the experience accrued since inception of the nation’s human spaceflight 

program more than 50 years ago. As NASA looks to commercial companies to develop 

vehicles to transport its astronauts, human rating must be an integral part of all activities 

throughout the life-cycle of a system, including design, development, test and evaluation; 

program management and control; mission operations; sustaining engineering; and 

vehicle disposal.

What Is Human Rating? Human rating is the process of assuring that a spacecraft or 

launch vehicle is capable of safely transporting human beings. Human-rating concepts

developed over the past 60 years include:

• avoiding complex components by using simpler designs;

• using well-established and proven aerospace design standards;

• incorporating sufficient redundancy in all critical systems; and 

• avoiding untried or unproven technology. 

According to NASA, a human-rated system must accommodate human needs, effectively 

utilize human capabilities, control hazards, manage safety risks, and, to the maximum 

extent possible, provide the capability to safely recover the crew from hazardous 

situations.11

The Evolution of NASA’s Human Spaceflight Programs. Although NASA astronauts 

have ridden on vehicles deemed suitable for manned spaceflight for 50 years, all of 

NASA’s human spaceflight programs predate the Agency’s current human-rating 

requirements and certification process. NASA’s first three human spaceflight programs –

the Mercury, Gemini, and Apollo Programs – included 27 manned flights between 1961 

 Compliance with these requirements leads to a certification attesting that the 

system is suitable for manned spaceflight. 

 11 NASA Procedural Requirements (NPR) 8705.2B, “Human-Rating Requirements for Space Systems 

(with change 1 dated 12/7/2009).
INTRODUCTION

2 REPORT NO. IG-11-022

and 1972.12 These programs were considered “man-rated” in accordance with the 

requirements in place at the time.13

Initiated in 1972, NASA’s Space Shuttle Program generally followed the basic design 

philosophies and human safety criteria of its predecessor programs. These concepts 

included adding redundancies, placing a heavy emphasis on ground testing, and requiring 

close management review and control of all engineering and technical activities affecting 

the reliability and safety of flight hardware. In 2004, President Bush announced the 

planned retirement of the Shuttle Program, which was increasingly viewed as unsafe and 

too costly.

 

By 2006, NASA was conducting trade studies and selecting contractors for the Agency’s 

next human spaceflight program, Constellation. Like its predecessors, the Constellation 

Program was to be a Government-owned system built to NASA standards by contractors 

under cost-reimbursable contracts and with extensive Government oversight. However, 

in contrast to NASA’s previous human spaceflight programs, elements of the 

Constellation Program, including those intended to transport astronauts to low Earth 

orbit, were being designed as the first vehicles that would meet the human-rating 

requirements established in NPR 8705.2B.14

The chronology of NASA’s human spaceflight programs and human-rating requirements 

is illustrated in Figure 1. 

 12 Project Mercury included 6 manned flights between 1961 and 1963; Project Gemini resulted in 10 

manned flights between 1965 and 1966; and the Apollo Program successfully completed 11 manned 

flights between 1968 and 1972. 

13 See, for example, “System Safety Requirements for Manned Space Flight,” NASA Manned Flight Safety 

Office, January 1969.

14 Notably, the Russian Soyuz vehicle has not obtained a NASA human-rating certification even though it 

carries NASA astronauts. Due to its successful operational history and demonstrated level of reliability 

and safety, NASA deemed the Soyuz safe for U.S. crews.
INTRODUCTION

REPORT NO. IG-11-022 3

Figure 1. Selected Chronology of NASA’s Human Spaceflight Programs and HumanRating Requirements

Recent Policy Directives. In an October 2009 report, a committee established by the 

President to review the U.S. human spaceflight program concluded that “[t]he U.S. 

human spaceflight program appears to be on an unsustainable trajectory. . . . The United 

States needs a means of launching astronauts to low-Earth orbit, but it does not 

necessarily have to be provided by the government. . . . As we move from the complex, 

reusable Shuttle back to a simpler, smaller capsule, it is appropriate to consider turning 

this transport service over to the commercial sector.”15

 15 Known as the “Review of U.S. Human Spaceflight Plans Committee” or Augustine Committee, the 

Committee was charged with conducting an independent review of the nation’s human spaceflight 

program and providing alternatives that would ensure that the nation is pursuing the best trajectory for 

the future of human spaceflight – one that is safe, innovative, affordable, and sustainable. 

 In his fiscal year (FY) 2010 

budget released the following February, President Obama proposed cancelling the 

Constellation Program in favor of relying on the nation’s commercial companies to 

provide crew transportation services to the International Space Station and focusing 

NASA’s attention on exploration beyond low Earth orbit. However, that proposal ran 

into stiff opposition in Congress. A compromise embodied in the NASA Authorization 

Act of 2010 requires that NASA use, to the extent practicable, commercially developed 

vehicles for transporting cargo and crew to the Space Station. At the same time, the Act 
INTRODUCTION

4 REPORT NO. IG-11-022

directs NASA to develop a Space Launch System and multi-purpose crew vehicle using 

the Agency’s traditional approach of Government-owned systems built to Agency 

standards by contractors.

16

NASA’s Investments in the Commercial Space Transportation Industry. NASA has

funded aspects of the commercial space transportation industry since 2006, and over the 

past 5 years has initiated three activities to manage its investments: Commercial Orbital 

Transportation Services (COTS), Commercial Resupply Services (CRS), and 

Commercial Crew Development (CCDev). 

In 2006, the Commercial Crew and Cargo Program Office announced the $500 million 

COTS Project with the purpose of helping industry develop space transportation 

capabilities for cargo. NASA structured the Project as a partnership with the commercial 

space industry, sharing the risks, costs, and rewards of developing new space 

transportation capabilities. NASA expected commercial partners participating in the 

project to develop their own technology solutions for an on-orbit cargo delivery 

capability that could potentially meet NASA’s cargo needs and to raise additional 

funding to demonstrate their solutions. Once the partners have demonstrated the 

capability, NASA and other customers would be able to purchase space transportation 

services directly from them. NASA entered into Space Act Agreements under the COTS 

Project with Space Exploration Technologies Corporation (SpaceX) in August 2006, and 

with Orbital Sciences Corporation (Orbital) in February 2008.

17

To stimulate the commercial human spaceflight industry, NASA initiated CCDev in 2009

to focus efforts on developing systems and concepts that will help establish an industry 

capable of transporting astronauts to low Earth orbit and the International Space Station. 

In 2010, NASA awarded the first round of funded Space Act Agreements under CCDev 

using $50 million in Recovery Act funds.

 In 2008, NASA awarded 

the two companies $3.5 billion in CRS contracts for 20 flights to provide cargo

transportation services to support the Space Station through 2016, a task previously 

handled primarily by the Space Shuttles. 

18

 16 Public Law 111-267. Congress had previously expressed support for the U.S. space transportation 

industry in the NASA Authorization Acts of 2005 (Public Law 109-155) and 2008 (Public Law 110-

422).

 These awards were intended to assist 

commercial entities in the development of system concepts, key technologies, and 

capabilities that could be used in commercial crew space transportation systems. Shortly 

17 On October 18, 2007, NASA terminated the $207 million COTS Space Act Agreement with Rocketplane 

Kistler due to the company’s failure to meet agreed-upon milestones. NASA had already awarded 

Kistler about $32 million in milestone payments. NASA reopened bidding later that year for the 

remaining $175 million, a competition Orbital won.

18 As stated in NASA Policy Directive (NPD) 1050.1l, “Authority to Enter into Space Act Agreements,” 

December 23, 2008, and pursuant to the National Aeronautics and Space Act of 1958, NASA may enter 

into Space Act Agreements with people and organizations to meet mission and program objectives. The 

agreements, which represent a set of legally enforceable promises, are classified as either reimbursable, 

non-reimbursable, or funded. NASA may only enter into funded Space Act Agreements with domestic 

agencies, persons, corporations, or educational institutions when the Agency’s objective cannot be 

accomplished through a contract, grant, or cooperative agreement. 
INTRODUCTION

REPORT NO. IG-11-022 5

after the 2010 Authorization Act became law, the Agency announced it was seeking 

proposals for a second round of funded Space Act Agreements (CCDev 2) to further 

mature commercial crew transportation system concepts and capabilities. On April 18, 

2011, NASA awarded $269.3 million in CCDev 2 awards to four companies (see 

Table 1). 

Finally, beginning in FY 2012 NASA plans to incorporate into follow-on awards the 

accomplishments and lessons learned from CCDev. Once commercial crew 

transportation capabilities have matured, NASA may award fixed-price contracts to 

commercial companies to purchase transportation services to meet its Space Station crew 

rotation and emergency return needs. Table 1 summarizes NASA’s COTS, CRS, and 

CCDev agreements. 
INTRODUCTION

6 REPORT NO. IG-11-022

Objectives

Our objective in this project was to review NASA’s efforts to modify its safety and

human-rating requirements for application to commercially developed space vehicles. 

We also examined the overarching challenges associated with some possible approaches 

NASA may take to certify and acquire commercial crew transportation services. 

Table 1. NASA’s COTS, CRS, and CCDev Agreements 

Space Act Agreements or Contracts

Activity

Award 

Year

Award Value

(millions) Company Vehicles/Technologies

COTS 2006 $ 278.0 SpaceX Dragon

COTS 2006 $ 207.0 Rocketplane Kistlera K-1

COTS 2007 $ 175.0 Orbital Cygnus

CRSb 2008 $1,600.0 SpaceX Dragon (12 flights)

CRSb 2008 $1,900.0 Orbital Cygnus (8 flights)

CCDev 2010 $ 20.0 Sierra Nevada Continued work on lifting body 

spacecraft design, Dream Chaser

CCDev 2010 $ 18.0 Boeing System concepts and technologies for 

CST-100

CCDev 2010 $ 6.7 United Launch

Alliance

Atlas V and Delta IV early emergency 

detection system

CCDev 2010 $ 3.7 Blue Origin Launch escape system and composite 

pressure vessel cabin

CCDev 2010 $ 1.4 Paragon Space Life support subsystem

CCDev2 2011 $ 92.3 Boeing System development and risk reduction 

demonstrations

CCDev2 2011 $ 80.0 Sierra Nevada Further mature the Dream Chaser Crew 

Transportation System concept

CCDev2 2011 $ 75.0 SpaceX Hardware demonstrations of the launch 

abort engine firings and cockpit 

prototype evaluations

CCDev2 2011 $ 22.0 Blue Origin Facilitate development of the vehicle 

design and escape system

a Terminated on October 18, 2007, due to the company’s failure to meet agreed-upon milestones. 

b CRS awards are fixed-price indefinite delivery, indefinite quantity contracts with a period of performance 

from January 1, 2009, through December 31, 2016.

Source: FAA “2011 U.S. Commercial Space Transportation Developments and Concepts: Vehicles, 

Technologies, and Spaceports;” January 2011 and NASA’s Selection Statement for Commercial Crew 

Development Round 2, April 18, 2011.
RESULTS

REPORT NO. IG-11-022 7

CHALLENGES ASSOCIATED WITH CERTIFYING AND 

ACQUIRING COMMERCIAL CREW 

TRANSPORTATION SERVICES

Over the past 2 years, NASA has made sustained progress toward its goal of 

obtaining commercial crew transportation services to low Earth orbit. For example, 

in 2009 the Agency initiated Commercial Crew Development (CCDev) investments 

and in 2010 awarded $50 million in funded Space Act Agreements to five companies 

to develop and demonstrate technologies and systems that could enable commercial 

human spaceflight capabilities. In April 2011, the Agency announced a second 

round of CCDev awards totaling $269.3 million. However, NASA’s effort to help 

develop a commercial space industry that could potentially meet the Agency’s 

transportation needs to low Earth orbit faces significant challenges, including:

• modifying NASA’s existing safety and human-rating requirements for

commercially developed systems; 

• selecting the acquisition strategy for commercial crew transportation 

services;

• establishing the appropriate insight/oversight model for commercial 

partner vehicle development;

• relying on an emerging industry and uncertain market conditions to 

achieve cost savings; and

• managing the relationship between commercial partners, the Federal 

Aviation Administration (FAA), and NASA.

The following sections examine each of these challenges in turn.

Modifying NASA’s Existing Safety and Human-Rating 

Requirements for Commercially Developed Systems

NASA has never procured transportation for its astronauts aboard a commercially 

developed vehicle. To manage the risk inherent in this process, NASA’s Commercial 

Crew Program Planning Office (Commercial Crew Office) is modifying a series of 

existing health and medical, engineering, and safety and mission assurance requirements 

for the commercial space industry. The Office is also developing but has not finalized 

the processes NASA will use to verify that these requirements have been met and to

certify that a commercial partner’s vehicle is capable of safely transporting Agency

personnel. 
RESULTS

8 REPORT NO. IG-11-022

Every requirement NASA imposes has a cost associated with it in time, money, or 

decreased innovation. Conversely, incurring these costs is often necessary to

appropriately manage risk. Many of the requirements NASA will impose on its 

commercial partners are the same as those that the Agency applies to its own spaceflight 

programs. However, NASA still needs to determine if, when, and how it will oversee 

commercial partners’ development efforts in order to ensure they meet Agency

requirements.

NASA’s goal is to maximize safety and reliability without burdening commercial 

partners with unnecessary demands that lead to higher development and operations costs. 

The challenge is achieving the appropriate balance of requirements and associated costs 

to meet the needs of all stakeholders. With sufficient industry feedback and input from 

NASA’s Technical Authorities and managers of the Space Station, Space Shuttle, and 

Commercial Crew Programs, the Agency hopes to strike a balance that will prescribe the 

minimum number of requirements essential to ensuring the safety of NASA’s astronauts 

while enabling innovation and flexibility on the part of the commercial providers.

19

Commercial Crew Transportation System Certification Requirements. NASA is in 

the process of modifying its existing safety and human-rating requirements for

commercially developed vehicles. In May 2010, the Agency released a draft version of

the Commercial Human-Rating Plan. After incorporating industry comments, NASA 

renamed the document and released it in December 2010 as the “Commercial Crew 

Transportation System Certification Requirements for NASA Low Earth Orbit Missions” 

(Certification Requirements). This document contains a consolidated set of technical 

requirements, standards, and processes that commercial partners must meet to obtain

NASA certification of their crew transportation systems.

 

20

The Certification Requirements describe NASA’s certification philosophy; the content 

and timing of the certification packages commercial companies will be required to deliver 

to NASA; and NASA’s expectations for system safety, human control of the vehicle, and

crew survival. In addition, the Requirements reference a set of 93 other documents, each 

containing additional requirements the companies must consider in order to obtain 

certification. NASA has categorized the underlying 93 documents into three types: 

Type 1 – mandatory, must be implemented as written; Type 2 – alternatives allowed with 

NASA approval; and Type 3 – suggested best practices. Each of the 93 documents 

 19 NASA’s Technical Authorities consist of Health and Medical, Engineering, and Safety and Mission 

Assurance personnel who provide independent oversight of programs and are responsible for the 

requirements associated with their discipline and all waivers to those requirements. 

20 NASA does not use the term “human rating” when referring to the Agency’s certification of commercial 

systems, but instead has reserved the term for use with the Agency’s own manned vehicles and systems. 

Instead, NASA will “certify” vehicles and systems produced by commercial partners when they are used 

to transport NASA astronauts. 
RESULTS

REPORT NO. IG-11-022 9

reference other documents that set forth additional requirements. According to one 

estimate, NASA’s Certification documents contain more than 4,000 requirements.

21

Of the 93 underlying documents, the Agency’s Health and Medical Technical Authority 

requires commercial partners to implement five Type 1 documents focusing on crew 

health and safety, human factors, and environmental standards; the Engineering and 

Safety and Mission Assurance Technical Authorities identify 70 Type 2 documents 

outlining requirements pertaining to design standards for space hardware and techniques 

for which substitutes are allowed with NASA approval; and the remaining 18 documents 

are considered best practices. We summarize the 93 documents in Table 2 below. 

 

Table 2. Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems

Document Type, Number in the Set, 

and Related Level of Enforcement Technical Authority Discipline

Number of 

Related 

Documents

Type 1 Documents (5) – Mandatory

Health and Medical 5

Engineering 0

Safety and Mission Assurance 0

Type 2 Documents (70) – Alternatives Allowed with NASA Approval

Health and Medical 0

Engineering 35

Safety and Mission Assurance 35

Type 3 Documents (18) – Best Practices Suggested 

Health and Medical 1

Engineering 7

Safety and Mission Assurance 10

 Total 93

For a list of the 93 Technical Authority standards and requirements documents, see Appendix B.

Source: “Commercial Crew Transportation System Certification Requirements for NASA Low Earth 

Orbit Missions” (ESMD-CCTSCR-12.10) and correction provided by the Office of Safety and 

Mission Assurance.

The 1100-Series Documents. The Commercial Crew Office also intends to publish 

documents referred to as the “1100-series,” which will tailor the Certification 

Requirements for crew transportation missions to the Space Station. In May 2011, the 

Commercial Crew Office publicly released in draft the following 1100-series documents

for comment:

 21 Remarks presented by Thomas Martin, Chief Systems Engineer, Special Aerospace Services, LLC, at the 

Commercial Human Spaceflight Technical Forum, January 12–14, 2011.
RESULTS

10 REPORT NO. IG-11-022

• Crew Transportation Plan establishes the roles and interfaces between NASA and 

the commercial space transportation industry and describes the necessary 

elements for achieving certification to transport NASA crew to the Space Station. 

• Crew Transportation System Design Reference Missions establishes the goals for 

the design of a system to transport humans to and from low Earth orbit. 

• Crew Transportation Technical Management Process provides commercial 

partners a summary of NASA’s expectations of the processes and products the 

Agency considers crucial to a successful development effort.

• ISS [International Space Station] Crew Transportation and Services Requirements 

Document provides the commercial space transportation industry with NASA’s 

requirements for development of commercial services to deliver crew and a 

limited amount of cargo to the Space Station. 

• Crew Transportation Technical Standards and Design Evaluation Criteria informs 

commercial partners of the specifications, standards, and processes that NASA 

considers critical to a successful design and provides guidance on the technical 

criteria NASA will use to assess the acceptability of proposed commercial 

designs. 

• Crew Transportation Operations Standards establishes the minimum criteria and 

practices for space flight operations process. 

NASA officials said they hope to issue the baseline 1100-series documents by December 

2011.

Industry Comments and Concerns. The private sector has been participating in and 

commenting on NASA’s certification requirements as they are being developed. For 

example, at an August 2010 commercial human spaceflight workshop hosted by the FAA 

and attended by representatives from industry and NASA, industry representatives 

suggested that NASA:

• modify existing requirements to the greatest extent possible and ensure they are 

achievable; 

• develop mature, stable requirements as soon as possible and in coordination with 

the FAA, which has regulatory oversight of U.S. companies providing 

commercial space transportation services; and

• allow for flexibility in requirements so that changes in vehicle or system design 

are attainable within reasonable costs.22

 22 The following companies participated in the workshop: Bigelow Aerospace; The Boeing Company; 

Lockheed Martin Corporation; Orbital; Sierra Nevada Corporation; SpaceX; and United Space Alliance.

According to the FAA, the companies were selected based on their demonstrated capabilities and interest 

in participating in the commercial human spaceflight transportation industry.
RESULTS

REPORT NO. IG-11-022 11

Additionally, NASA received numerous questions from industry representatives in 

response to its October 2010 CCDev 2 announcement, including questions about the 

requirements the Agency had published to date, the timing of the release of additional 

requirements, and NASA’s expectations for requirements fulfillment. One industry 

representative questioned a draft requirement that commercial partner vehicles provide a 

95 percent abort effectiveness capability, pointing out that this “seems to be a rather 

aggressive requirement given the fact that NASA’s own calculations for the 

[Constellation Program] Ares I (which was supposed to be one of the safest crew 

vehicles NASA had ever designed) showed that this vehicle had an abort effectiveness of 

about 80 percent to 85 percent.”23

Selecting an Acquisition Strategy for Commercial Crew 

Transportation Services 

 In response, NASA stated that it is not mandating 

compliance with requirements as part of CCDev 2 and, as discussed below, is simply 

informing industry as early as possible what may ultimately be required to obtain 

certification of a commercial system.

NASA’s Commercial Crew Office has not finalized the acquisition strategy it will use for 

procuring commercial crew transportation services, although NASA has stated that it 

plans to present its strategy to Congress by late summer 2011. Mindful of national policy 

to limit the use of high-risk contracting vehicles such as noncompetitive and costreimbursement contracts, among the options NASA may consider is an acquisition 

strategy that relies either on funded Space Act Agreements; competitive procurements

guided by the Federal Acquisition Regulation (FAR), in particular fixed-price contracts;

or some combination of both. 

Each of these possible approaches poses financial and programmatic challenges to 

NASA’s efforts to procure crew transportation services. In selecting procurement 

mechanisms, NASA must balance its role as a supporter of commercial partners with its 

responsibility to ensure that commercially developed vehicles are safe for NASA 

astronauts, meet the Agency’s needs, and provide a viable domestic alternative to the 

Soyuz vehicle. 

Challenges of Using Space Act Agreements. NASA may only enter into funded Space 

Act Agreements when it cannot accomplish its objective through a contract, grant, or 

cooperative agreement. Further, if the expected deliverables meet a NASA requirement, 

Federal policy states that a procurement contract is required.24

Consistent with these principles, the primary purpose of CCDev (which up to this point 

has been funded by Space Act Agreements) is to stimulate the private sector and aid in 

 

 23 Requirement 3.3.1.6 in the draft version of “International Space Station Crew Transportation and 

Services Requirements Document” (CCT-REQ-1130) states, “The CTS [Commercial Transportation 

System] shall provide an overall abort effectiveness of 0.95 [to be confirmed] . . ..”

24 The Federal Grant and Cooperative Agreement Act of 1977.
RESULTS

12 REPORT NO. IG-11-022

the development of commercial human spaceflight capabilities that NASA could 

ultimately use to transport astronauts to low Earth orbit and the International Space 

Station. As one potential customer of the private sector, NASA expects the CCDev 

Space Act Agreements to result in commercial capabilities that consider the Agency’s 

commercial crew transportation system certification requirements, but is not dictating 

specific system elements or mandating compliance with specific requirements. Rather, 

each participant operating under a CCDev Space Act Agreement is free to determine the 

system requirements and concepts that it believes best serve its target markets. 

Although NASA is the biggest and most viable customer for these companies in the near 

term, because compliance with NASA’s requirements is not mandatory it is possible that 

the companies’ designs will not track all of NASA’s requirements. To mitigate this risk, 

NASA may perform an analysis to identify shortfalls between the companies’ designs 

and the Agency’s requirements to improve the vehicle design or correct a known issue or 

defect. However, as discussed below, proceeding in this manner could create additional 

financial risks for the Agency.

Challenges of Using FAR-based Procurements, Specifically Fixed-Price Contracts. 

Cost increases associated with Government’s use of cost-reimbursement contracts has 

focused attention on other procurement vehicles such as fixed-price contracts that might 

better contain costs. If NASA chooses to award fixed-price contracts, it will realize 

certain benefits, most notably locking in the Government’s initial investment to a fixed 

amount. However, fixed-price contracts also create significant risks that the Commercial 

Crew Office will need to manage, including costs associated with unanticipated technical 

difficulties and yet-to-be-defined requirements.

The FAR lists several factors to consider when selecting and negotiating contract types. 

When the requirements are complex or unique, the Government usually assumes a greater 

portion of the risk by using contracting vehicles like cost-reimbursement contracts. This 

is especially true for complex research and development contracts where performance 

uncertainties or the likelihood of changes makes it difficult to accurately estimate 

performance costs in advance. Moreover, some of the companies that have shown 

interest in providing commercial crew services are building spacecraft for the first time 

and the requirements they will be expected to meet have not yet been fully defined. In 

this type of environment, there is a risk that during the period of contract performance 

NASA’s requirements may change so significantly that contractors may assert the 

Agency is going beyond the contract’s scope in which case NASA would be required to 

pay the contractor for necessary changes. 

In addition, although fixed-price contracts provide the maximum incentive for contractors

to perform effectively while controlling costs, they also place on the contractor the 

maximum risk of loss if it is unable to do so. This situation can create incentives for a 

contractor to “cut corners” to protect its profit margin. 

Another challenge in a fixed-price environment is determining the true costs companies 

will face in meeting NASA requirements. For example, NASA has established a long-
RESULTS

REPORT NO. IG-11-022 13

term safety requirement for all future crewed space transportation systems, mandating 

that each system must eventually become safer than when initially developed.25

Soyuz Buy Decision. Another challenge facing NASA is determining whether and when 

to purchase additional seats on the Russian Soyuz vehicle as a contingency to possible 

delays in obtaining commercial crew transportation capabilities. Since 2005, NASA has 

negotiated with Roscosmos – the Russian Federal Space Agency – to purchase crew 

transportation services aboard the Soyuz vehicle. These services included the launch, 

return, and possible rescue of astronauts from the Space Station. To date, NASA has 

purchased 46 seats aboard Soyuz vehicles for launches planned through 2015. Since 

2005, the average cost per seat has increased almost 175 percent, from $21.8 million for 

launches occurring in 2006, to $60 million for launches planned for 2015.

 Thus, 

each of NASA’s commercial partners will be required to invest additional funds to 

develop and maintain a proactive continuous improvement program. In the fixed-price 

environment, a company’s motivation to increase profit margins by cutting costs and 

creating efficiencies may conflict with the requirement to continually improve the safety 

of their system. Moreover, companies will need to account for the added costs of 

maintaining a continuous improvement program when contracting with NASA for Space

Station transportation missions. 

26

As shown in Figure 2, the largest increase occurred for launches planned for the latter 

portion of 2011, when retirement of the Space Shuttle and the lack of a U.S. domestic 

transportation capability increased NASA’s previous demand for Soyuz seats.

 

27

NASA has since agreed to three more contract modifications with Roscosmos for 

continued crew transportation, rescue, and related services for flights to and from the 

Space Station through 2015, with the cost per seat rising each year by an average of 

$4.34 million. The most recent contract modification purchased seats for launches in 

2014 and 2015 with the final crew return mission occurring in June 2016. The cost per 

seat for the 2014 and 2015 launches is $55.6 million and $60 million, respectively.

 

According to the Space Station External Integration Office, meeting this increased 

demand required upgrades to and modernization of Russia’s manufacturing 

infrastructure, which resulted in a 57 percent increase in the cost per seat – from 

$27.7 million for launches in the first half of 2011 to $43.4 million for launches in the 

latter half of 2011. NASA determined that the 57 percent increase was reasonable and 

accurately reflected inflation and the effort required to sustain Russia’s increased vehicle 

production rate to meet the Agency’s increased demand for an extended period of time 

beyond 2011. 

 25 The Agency will adopt safety goals and thresholds for crew transportation missions to the International 

Space Station. These goals and thresholds will be applied to acquisition programs involving commercial 

crew transportation capabilities and services as well as NASA Programs conducting such services. 

26 The costs cited are price per seat only and exclude any additional costs for cargo delivery, cargo return, 

and trash disposal capabilities. 

27 NASA purchased one Soyuz seat per year in 2007 and 2008 and six per year from 2009 to 2015.
RESULTS

14 REPORT NO. IG-11-022

The increases in the yearly cost per seat for U.S. crew transportation services aboard the 

Soyuz vehicle are shown in Figure 2.

Figure 2. Yearly Cost (per Seat) for U.S. Crew Transportation Services Aboard the Soyuz 

Vehicle for Launches through 2015

Source: NASA International Space Station External Integration Office, Johnson Space Center, 

May 2011.

Procurement of these additional Soyuz seats is intended to bridge the gap between the 

end of the Space Shuttle Program and the availability of U.S. commercially developed 

vehicles, which is planned for late 2016. However, if the commercial partners incur

schedule slippage, technical or financial delays, or significant difficulty in the early 

stages of obtaining NASA’s certification of their vehicles, NASA may have to purchase 

additional Soyuz seats to ensure continued U.S. access to the Space Station beyond June 

2016. Because of the long lead-time required for procuring Soyuz seats and planning a 

mission to the Space Station, NASA would have to make the decision to purchase 

additional Soyuz seats for flights in 2016 and beyond by spring 2013, at least 3 years 

before commercial partners are expected to be ready to provide transportation services. 

Alternatively, NASA may decide not to purchase additional Soyuz seats and risk having 

no crew transportation capabilities to the Space Station after June 2016 if its partners 

encounter unexpected delays.

$21.8 $21.8 $21.8

$25.2 $26.4 $27.7

$43.4

$47.0

$51.5

$55.6

$60.0

$10 million

$20 million

$30 million

$40 million

$50 million

$60 million

$70 million

2006 2007 2008 2009 2010 First 

half of 

2011

Second 

half of 

2011

2012 2013 2014 2015
RESULTS

REPORT NO. IG-11-022 15

Establishing the Appropriate Insight/Oversight Model for 

Commercial Partner Vehicle Development

The Commercial Crew Office is developing the model for NASA’s insight and oversight 

of commercial companies’ efforts to develop crew transportation systems.28

The primary difference between models of insight versus oversight is that insight 

provides NASA with knowledge without having the authority for decision-making and 

approval, whereas oversight provides for knowledge and authority to make approval 

decisions. Selecting the appropriate level and mechanisms of insight and oversight is 

necessary to provide NASA with information sufficient to assess commercial partners’ 

technical, schedule, and cost risks and certify that commercially developed vehicles are 

safe for NASA astronauts without unduly affecting the commercial partners’ ability to 

operate in a cost-effective manner. As discussed above, because NASA is not dictating 

specific system concepts or elements or mandating compliance with its requirements in 

funded Space Act Agreements, companies may develop vehicles that deviate from 

Agency requirements. To mitigate this risk, NASA’s insight/oversight approach could 

include an analysis to identify significant differences between design and requirements 

that would potentially prevent a partner from obtaining NASA’s certification in the later 

phases of the acquisition process. 

As defined 

by NASA, “insight” means acquiring knowledge and understanding of contractors’ 

actions by monitoring selected metrics or milestones. Methods of achieving insight 

include review of documentation, attendance at meetings, tests, and compliance 

evaluations. In contrast, “oversight” combines technical insight of contractor activities 

with approvals that provide the contractor with formally documented authority to proceed 

or formal acceptance of plans, tests, or success criteria. 

Spectrum of Insight/Oversight Models. Throughout its history, NASA has utilized a 

wide spectrum of insight/oversight models. One method of measuring the Government’s 

level of insight versus oversight is a program’s ratio of civil service employees to 

contractor employees. As shown in Figure 3, insight/oversight models for NASA 

programs range from low (1 civil service employee to every 250 contractor employees 

for development of scientific and commercial spacecraft) to intense (1 civil service 

employee to every 4 contractor employees for the development and operation of human 

spaceflight programs). 

 28 NPD 8610.23C, “Launch Vehicle Technical Oversight Policy,” August 18, 2006. 
RESULTS

16 REPORT NO. IG-11-022 

Figure 3. Spectrum of Insight/Oversight Models

Low/No Insight/Oversight Medium Insight/Oversight

Intense Insight/

Oversight

Scientific and Commercial 

Spacecraft—Contracted COTS and CRS

Launch Services 

Program

Human 

Spaceflight

1 CSE/10-250 CE 1 CSE/

20-80 CE

1 CSE/17 CE 1 CSE/4-10 

CE

Genesis MRO GPS III Falcon/

Dragon

Taurus II Delta II Atlas V Space Shuttle

 

Spacecraft shown are only examples of multiple spacecraft in the category. 

CE – contractor employee; CSE – civil service employee; GPS – Global Positioning Satellite

MRO – Mars Reconnaissance Orbiter 

Source: Adapted from Hale, W., and F. Bauer, “Government Insight/Oversight for Commercial Crew 

Transportation,” Rev. N, March 10, 2010. At 

http://www.nasa.gov/pdf/469245main GovernmentInsightForCommercialCrewTransportation.pdf

(accessed June 17, 2011). 

Government insight/oversight also includes the mechanisms by which civil service 

employees (1) assess commercial partners’ technical, schedule, and cost risks; 

(2) establish, apply, and modify technical requirements; and (3) evaluate the competency 

and adequacy of the technical work performed by commercial partners. Examples of 

NASA oversight are requiring Government approval of partners’ documents and 

drawings; mission-unique hardware design, analysis, manufacture, and testing; spacecraft 

handling procedures; and launch go/no-go decisions. NASA insight could include 

Government monitoring and review but not approval of commercial partners’ work 

practices and documentation; vehicle walk-down inspections; failure analysis; and 

anomaly resolutions. Whichever methodology it adopts, NASA must tread a delicate 

balance between insight/oversight activities that will provide sufficient evidence that 

partners have met the Certification Requirements to ensure that commercially developed 

vehicles are safe for NASA astronauts without unnecessarily driving up costs. 

Insight in the Design Phase. While commercial partners are designing their launch 

systems as part of CCDev, NASA is considering the appropriate level of insight to 

increase its understanding of the companies’ system design. The depth of this insight 

could be critical for accurately assessing technical, schedule, and cost risks, and for 
RESULTS

REPORT NO. IG-11-022 17

establishing an analytical approach NASA may use to monitor and assess each partner’s 

designs. 

NASA is considering an approach that assigns a core team to follow a specific CCDev

partner throughout the life-cycle of its launch system. To gain the best possible 

understanding of a partner’s system, one or more of the team members may acquire an 

office at the commercial partner’s production facility. NASA may augment the team 

when needed with subject matter experts to help resolve major issues and provide 

additional support for key milestone reviews such as design reviews and flight readiness 

reviews. NASA could also assign additional experts to support the more challenging, 

higher risk areas such as launch abort systems. This type of solution would require 

coordination between the Commercial Crew Office and NASA’s institutional pool of 

experts. 

Each insight team may be tasked with performing an independent analysis of the 

partner’s design in order to assess differences between that design and NASA’s 

Certification Requirements. These findings could enable NASA to assess the ability of 

each design to meet the Agency’s Certification Requirements prior to the actual awarding 

of contracts for transportation services. 

Oversight in the Development, Test, and Evaluation Phase. Once the design phase

has ended, NASA may award contracts, Space Act Agreements, or both for commercial

vehicle development, test, and evaluation. At that point, the Agency will be both

stimulating a commercial crew industry and assisting with the development of safe, 

reliable, and cost-effective commercial vehicles that meet NASA’s Certification 

Requirements. While NASA would still need to maintain insight into the development of 

each vehicle, at that stage in the process the Agency may assume more of an oversight 

role in granting approval or direction to companies as they move toward certification. As 

of May 2011, NASA had not finalized the oversight model for this phase, including 

defining key milestones regarding what will be required of commercial companies.

Establishing an insight/oversight model, however, is not without risks, particularly with 

respect to ensuring fair and open competition if, for example, the Agency were to 

transition from Space Act Agreements in the design phase to fixed-price contracts in the 

development, test, and evaluation phase. NASA would need to ensure it structured its 

insight during the design phase of CCDev so as not to give participants an unfair 

competitive advantage over non-participants. For example, although NASA’s solicitation 

for vehicle development and crew transportation services would be open to nonparticipants, if NASA identifies differences in partners’ designs and NASA requirements, 

only CCDev partners would have received that analysis, which could increase the 

likelihood that their vehicles will meet contract requirements. 

NASA has received at least one question in response to the CCDev 2 announcement for

proposals regarding the relationship between CCDev awards and future contracts. An 

industry representative inquired whether NASA anticipates overlap between CCDev 2 

and any future procurement of commercial crew demonstration or transportation services. 
RESULTS

18 REPORT NO. IG-11-022

NASA responded that there is no relationship between the two phases of acquisition. 

However, if NASA provides its CCDev partners information relevant to the differences 

between their designs and NASA requirements, non-CCDev companies may perceive 

that as an unfair competitive advantage. According to the Agency’s Space Act 

Agreements Guide, such a relationship or perceived relationship could raise conflict of 

interest concerns. If NASA fails to address such potential conflicts or develop 

appropriate mitigation plans, the Agency could be faced with a bid protest, which could 

cause delays in the procurement. 

Relying on an Emerging Industry and Uncertain Market 

Conditions to Achieve Cost Savings 

NASA’s acquisition strategy to procure safe, reliable, and cost-effective crew 

transportation services is premised on competition in the near term and a healthy 

commercial human spaceflight industry in the longer term. Competition will both 

incentivize performance and mitigate the risk that reliance on a single provider may pose. 

Engaging with multiple companies lessens the impact should any one company fail to 

meet NASA’s Certification Requirements or secure the funds necessary to continue in the 

industry. A healthy commercial space transportation industry will allow NASA to solicit 

bids from a number of companies and make competitive procurement decisions that meet 

individual mission requirements while providing the best value for the taxpayer. 

However, the commercial space industry is in its infancy and, according to a 2010 FAA

report, there is currently insufficient demand to support a viable commercial human 

spaceflight market.

29

• Act as the anchor tenant customer for the foreseeable future, including 

guaranteeing a market greater than 5 years of Space Station support; 

 The report highlighted a number of steps that NASA and the FAA 

need to take to develop a commercial crew transportation market, including: 

• Provide mature, stable requirements, including human-rating certification

requirements, as soon as possible; and

• Ensure that NASA and the FAA agree on a coherent set of requirements and 

regulations that enable commercial crew transportation systems to serve both 

Government and non-Government customers.

The Importance of Government Investments. Creating an environment where 

competition exists in the development of commercial crew transportation services will 

require a large investment and support from the Federal Government on both the supply 

and demand sides of the business model. Although there appears to be a great deal of 

speculation and excitement surrounding commercial spaceflight, in the near term the

market for non-Government commercial human spaceflight services is limited and the 

 29 FAA, “Report of the Commercial Human Spaceflight Workshop,” August 4-6, 2010. 
RESULTS

REPORT NO. IG-11-022 19

future market is largely unknown. Similarly, NASA’s need for crew transportation to the 

Space Station, as currently defined, is relatively limited and could potentially result in 

only two flights per year. Therefore, because of the large initial investment required by 

industry to enter into the commercial crew transportation business, NASA will most 

likely be a significant financial partner and supporter of those companies for some time to 

come. 

Lessons Learned from the Evolved Expendable Launch Vehicle Program. 

Historically, past predictions of the demand for commercial launch vehicles have been

overly optimistic. Moreover, competition in a demand-constrained environment can have 

unintended consequences. For example, Lockheed Martin and the Boeing Company 

were rival launch vehicle service providers in the Department of Defense’s Evolved 

Expendable Launch Vehicle (EELV) Program.30

Impacts of Near-Term Limited Demand. Because of the near-term limited demand for 

commercial crew transportation services, it is likely that NASA’s commercial partners 

will attempt to augment their business with commercial and Government satellite 

launches. For example, SpaceX is developing rockets that can transport satellites to orbit, 

including a rocket to compete with United Launch Alliance in the EELV market. 

However, FAA predictions for satellite launch vehicle demand through 2019 remain flat 

or slightly decline, although the FAA points out that opportunities for growth in the 

overall launch vehicle market could occur if a viable, commercial human spaceflight 

market emerges.

 When expected demand for EELV 

launch vehicles did not materialize, estimated prices for launch services increased 

77 percent in 1 year. In an effort to provide more cost-effective and reliable launch 

vehicles in the face of limited demand for their services, the companies combined their 

EELV operations in December 2006 to form United Launch Alliance, LLC. The 

formation of United Launch Alliance eliminated competition and forced the Government 

to rely on a single provider of launch services to meet its intermediate- and heavy-class 

launch vehicle requirements. Consequently, near-term limited demand can stifle 

competition – a cornerstone of NASA’s commercial crew services goals. 

31

In the NASA Authorization Act of 2010, Congress stated that commercial space 

transportation services have the potential of broadening availability and access to space 

travel while lowering costs. However, many of the risks associated with achieving the 

anticipated cost savings are largely out of NASA’s control, particularly in the area of 

creating demand for non-Governmental commercial human spaceflight services. The Act 

directed the Agency to work with the FAA’s Office of Commercial Space Transportation 

and assess the potential non-Government market for commercially developed crew and 

cargo transportation systems and capabilities. In April 2011, NASA and the FAA 

In spite of the current limited market demand, new companies have 

entered or expressed interest in the commercial crew industry. 

 30 The Department of Defense initiated the Evolved Expendable Launch Vehicle Program in 1995. The 

Program consists of the Atlas V (formerly provided by Lockheed) and Delta IV (formerly provided by 

Boeing) families of launch vehicles.

31 FAA “2010 Commercial Space Transportation Forecasts,” May 2010.
RESULTS

20 REPORT NO. IG-11-022

reported that over time the non-Government market for commercial crew and cargo 

services may emerge and provide significantly more customers, more flights, and 

potentially lower prices to the U.S. Government. 32

Managing the Relationship Among Commercial Partners, the FAA, 

and NASA 

 For example, the clearly identifiable 

market for regular Space Station cargo delivery and crew rotation provides a foundation 

for private sector development efforts to succeed. However, without a successful 

Commercial Crew Program, the prospects for a stable commercial non-Government 

market are lessened considerably. The continuing challenge will be determining at what 

point the market can sustain a number of commercial companies, allowing NASA to 

transition from the role of partner in the development of commercial services to one of a

consumer benefitting from cost-effective commercial crew transportation services.

Although U.S. human space travel has historically been managed by NASA, the FAA is 

responsible for providing regulatory oversight of companies seeking to provide 

commercial human space transportation. To date, the FAA has issued regulations 

pertaining to launch and reentry activities that could affect public safety. However, in 

December 2012 the FAA is authorized to begin proposing regulations concerning the 

safety of passengers and crew involved in commercial spaceflight. As previously 

discussed, NASA plans to impose its own set of requirements, standards, and processes 

that commercial partners must meet to obtain a certification before transporting Agency 

personnel. Accordingly, NASA must coordinate with the FAA to avoid creating multiple 

sets of standards and requirements for commercial companies seeking NASA 

certification and FAA licensing on the same vehicle. 

History of FAA Regulating Commercial Spaceflight. In accordance with the 

Commercial Space Launch Act of 1984, the FAA is responsible for overseeing, licensing, 

and regulating launch and reentry activities undertaken by U.S. commercial space 

companies. The FAA also has authority over launch and reentry sites operated by U.S. 

business entities. The FAA’s primary role is to ensure the safety of the public. Its 

regulatory oversight includes developing and issuing regulations; granting licenses, 

permits, and safety approvals; and conducting safety inspections during every licensed 

launch. 

The Commercial Space Launch Amendments Act of 2004 expanded the FAA’s role by 

establishing a regulatory framework for commercial human spaceflight. This law 

established an “informed consent” protocol for carrying spaceflight passengers. 

Informed consent is the process of notifying spaceflight passengers in writing of the risks 

associated with spaceflight, and passengers will be required to agree in writing to accept 

those risks. Before granting a launch license, the FAA must also approve the commercial 

operator’s vehicle hardware and software. Additionally, the operator must assess critical 

 32 “Commercial Market Assessment for Crew and Cargo Systems Pursuant to Section 403 of the NASA 

Authorization Act of 2010 (P.L. 111-267),” April 27, 2011.
RESULTS

REPORT NO. IG-11-022 21

hazards and risks posed by its launch operations and propose to the FAA how they will 

mitigate them. 

Except for informed consent, the 2004 Commercial Space Act specifically prohibited the 

FAA from imposing regulations related to crew and passenger safety on commercial 

spaceflights for a period of 8 years after enactment.33

Before taking effect, any proposed FAA regulations must undergo an official Notice of 

Proposed Rulemaking process, which allows the public, industry, and other Government 

agencies to comment on the proposed regulation. This rulemaking process can take many 

months to complete, which in turn could delay the enactment of any new FAA 

regulations until sometime in 2013. In anticipation of this time lag, the FAA plans to 

begin an introductory dialogue with the commercial space industry in the spring of 2012

to conceptualize the regulatory environment as soon as possible so that industry may 

consider this information when designing vehicles. 

 Therefore, beginning in December 

2012 (unless specifically prohibited by new legislation), the FAA will be able to begin 

proposing regulations concerning the safety of passengers and crew involved in 

commercial spaceflight. The FAA has indicated that it anticipates issuing regulations 

establishing requirements for launch vehicle maintenance; crew rest and safety; 

spaceflight participant safety and training; and vehicle re-entry. FAA officials foresee 

establishing a minimum set of requirements to help ensure safety of the crew and the 

public. 

Need for Timely NASA and FAA Coordination. The FAA and NASA have already 

demonstrated that they can collectively provide Government reviews for cargo transport 

demonstration missions to the Space Station. In December 2010, SpaceX was the first 

commercial entity to use an FAA-issued reentry permit for a test flight of its Dragon 

capsule as part of NASA’s COTS Project. Similarly, all future commercial resupply 

flights to the Space Station conducted by SpaceX or Orbital will require FAA licenses. 

What remains unclear is the extent of the Government oversight – either FAA, NASA, or 

a combination of both – that will be imposed for commercial crew missions to the Space 

Station. Industry officials have expressed concern that there may be two inconsistent 

Government environments: one encompassing FAA regulations for any non-NASA 

related flights and a different set of requirements imposed through NASA certification.

To illustrate the difficulty this could pose to a commercial company, consider the 

following scenario: a company launching space tourists to low Earth orbit falls under 

FAA regulations and restrictions. However, if the company uses the same vehicle to 

carry NASA personnel to the Space Station it may be required to meet different and 

possibly inconsistent NASA standards. To avoid this scenario, timely coordination 

among NASA, the FAA, and commercial spaceflight companies is essential. 

 33 The exception would be if there was a high-risk incident, serious injury, or fatality, at which point the 

FAA could react accordingly and enact additional regulations. 
RESULTS

22 REPORT NO. IG-11-022

Some of these discussions are already taking place. For example, NASA has agreed that 

the goal is for FAA to license commercially developed vehicles used to transport NASA 

personnel. In addition, the agencies are co-locating personnel at NASA Headquarters, 

FAA field offices, and the Johnson and Kennedy Space Centers, and this co-location 

should assist in coordination. Most notably, at Kennedy, the FAA has co-located 

personnel with NASA’s Commercial Crew Planning Office until its Technical Center for 

Commercial Spaceflight is established. As expressed by the two agencies, the goal of 

these and other actions is to optimize Government oversight of commercial spaceflight 

companies through compatible requirements, standards, and processes.

Conclusion

NASA is making progress toward its goal of stimulating a commercial space 

transportation industry that will enable the Agency to acquire safe, reliable, and costeffective astronaut transportation to low Earth orbit. However, the challenges to 

successful completion of this process are numerous, interrelated, and ongoing. For 

example, establishing the appropriate level and mechanisms for Government insight and 

oversight of commercial partners’ operations will be influenced by the acquisition 

strategy NASA chooses. In addition, establishing cost-effective transportation and a

price point relative to what transportation might cost on a NASA-developed or Soyuz 

vehicle is reliant upon a market that is currently under development. Furthermore, how 

successfully NASA and the FAA coordinate their respective roles in this process will 

impact the speed of development and the ultimate cost to NASA for commercial transport 

of its astronauts. 

Following retirement of the Space Shuttle Program in summer 2011, the United States

will no longer have its own capability to access low Earth orbit and the International 

Space Station, and instead will depend upon Russia to provide crew transportation 

services. Currently, the only other option in development is the Government-owned and 

-operated Multi-Purpose Crew Vehicle and Space Launch System that the 2010 

Authorization Act set as a goal to be fully operational by December 31, 2016.34

 34 The Authorization Act requires NASA to design the Multi-Purpose Crew Vehicle and the Space Launch 

System for beyond-earth-orbit exploration missions, and to be available as an alternate means of 

transporting crew and cargo to the International Space Station in the event that commercial crew and 

international partners are unable to do so. 

 

However, NASA has indicated that this system is unlikely to be ready by that date. 

Consequently, NASA faces an imperative to nurture development of a U.S. commercial 

transportation service to reestablish the nation’s ability to access low Earth orbit and the 

Space Station as soon as possible. 
RESULTS

REPORT NO. IG-11-022 23

Management Action

While we are not making specific recommendations for corrective action, we believe 

NASA must pay particular attention to the challenges highlighted in this report. 

Specifically, NASA should:

• clearly articulate to its commercial partners as soon as possible all requirements

for commercially developed systems and the processes NASA will use for 

certifying such systems;

• maintain robust communication with the emerging commercial spaceflight 

industry to ensure that Agency contracting mechanisms include the appropriate 

balance between insight and oversight that will provide NASA with sufficient 

information to assess and certify commercial partners’ systems while providing 

companies the flexibility to be innovative;

• clearly articulate how it will mitigate potential conflicts of interest that may arise 

as a result of analysis that could provide an unfair competitive advantage to a 

NASA partner; and 

• expand coordination with the FAA to avoid the potentially serious business 

impacts that would result if commercial companies were required to operate in an 

environment that included inconsistent sets of standards for NASA certification 

and FAA licensing of the same vehicle.

In response to a draft of this report, the Associate Administrator for Exploration Systems 

Mission Directorate agreed that NASA should pay particular attention to the challenges 

highlighted in the report and stated that the Agency will be making progress in each of 

the areas as the Commercial Crew Program matures. The Associate Administrator also 

reiterated that the Agency’s acquisition strategy for the Commercial Crew Program has 

not been decided and is subject to further change as the procurement process matures. 

 

APPENDIXES

REPORT NO. IG-11-022 25

APPENDIX A

Scope and Methodology

We performed this audit from June 2010 through May 2011 in accordance with generally 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objectives. 

Our overall audit objective was to review the development and implementation of 

NASA’s safety and human-rating standards for the commercial space industry. In 

particular, we focused on NASA’s development of the human-rating standards for 

commercial vehicles. We also evaluated how commercial space transportation providers 

intend to implement NASA’s safety and human-rating requirements. We met with 

representatives of a commercial space transportation company and officials from 

NASA’s Office of Safety and Mission Assurance Commercial Crew and Cargo Program 

Office. We identified and reviewed relevant Federal laws and regulations, NASA 

policies, procedures, plans, and guidance, and other criteria (see detailed list of items 

reviewed below). 

During much of our audit field work, NASA was in a “blackout period” with industry 

between October 25, 2010, when the Agency released the Announcement for Proposals

for the second round of CCDev proposals until NASA announced final awards on April 

18, 2011. To avoid jeopardizing this procurement activity, the OIG did not communicate 

with the 42 companies that NASA had identified as Interested Parties during the blackout 

period. 

As part of the audit, we:

• attended commercial crew planning checkpoint meetings;

• acquired transcripts of congressional testimony by NASA’s Administrator and 

FAA’s Commercial Space official;

• interviewed key personnel within NASA’s Office of Safety and Mission 

Assurance;

• interviewed NASA’s Chief Engineer;

• coordinated with the NASA Advisory Council’s Commercial Space Committee;
APPENDIX A

26 REPORT NO. IG-11-022

• interviewed members of the Aerospace Safety Advisory Panel;

• interviewed personnel at SpaceX and toured their facility; and

• interviewed Air Force Chief Engineer for Wing Safety at Patrick Air Force Base

in Florida;

In addition, we reviewed information on the FAA website related to the commercial 

space industry. 

We identified and reviewed the following as applicable to our audit objectives: 

Federal Laws, Regulations, Policies, and Guidance

• Public Law (P.L), 85 - 568; 72 Stat. 426, “The National Aeronautics and Space 

Act of 1958” as Amended (Space Act), July 29, 1958

• P.L. 108 – 492, “Commercial Space Launch Amendments Act of 2004,” 

December 23, 2004

• P.L. 109 - 155, “NASA Authorization Act of 2005,” December 30, 2005

• P.L. 110 - 422, “NASA Authorization Act of 2008,” October 15, 2008

• P.L. 111 - 267, “NASA Authorization Act of 2010,” October 11, 2010

NASA Policy and Procedures

• NASA Advisory Implementing Instruction 1050 – 1A, “Space Act Agreements 

Guide,” August 15, 2008 

• NASA Advisory Implementing Instruction 1050 – 1B, “Space Act Agreements 

Guide,” June 10, 2011 

• NPD 1050.1I, “Authority to Enter into Space Act Agreements“, December 23, 

2008 

• NPD 8610.23C, “Launch Vehicle Technical Oversight Policy,” August 18, 2006 

• NPD 8700.1E, “NASA Policy for Safety and Mission Success,” October 28, 2008

• NPD 8700.3B, “Safety and Mission Assurance (SMA) Policy for NASA 

Spacecraft, Instruments, and Launch Services,” October 28, 2008

• NPR 8705.5, “Probabilistic Risk Assessment (PRA) Procedures for NASA 

Programs and Projects,” July 12, 2004
APPENDIX A

REPORT NO. IG-11-022 27

• NPR 8705.2B “Human-Rating Requirements for Space Systems (w/change 1 

dated 12/7/2009),” May 6, 2008

• “Commercial Crew Transportation System Certification Requirements for NASA 

Low Earth Orbit Missions,” ESMD-CCTSCR-12.10, Revision Basic, December 

8, 2010

• CCT-1001, Commercial Human-Rating Plan (Draft), May 21, 2010

We also reviewed the following documents and presentations:

• “Commercial Market Assessment for Crew and Cargo Systems Pursuant to 

Section 403 of the NASA Authorization Act of 2010 (P.L. 111-267),” April 27, 

2011

• The Vision for Space Exploration, NASA, February 2004

• FY 2012 NASA Proposed Budget, 

• Congressional Testimonies on Human Spaceflight from the NASA Administrator, 

Chairman of the Review of US Spaceflight Plans Committee; the Chairman of the 

Aerospace Safety Advisory Panel; the Director, Office of Science and 

Technology Policy for the Executive Office of the President of the United States; 

and Former Astronauts to the United States Senate Committee on Commerce, 

Science, and Transportation and/or to the United States House of Representatives 

Committee on Science and Technology

• Commercial Human Rating Plan Overview 

• Briefing to the Aerospace Safety Advisory Panel, “NPR 8705.2B, Human-Rating 

Requirements for Space Systems,” October 22, 2008 

• Government Insight/Oversight for Commercial Crew Transportation

• Commercial Crew Insight/Oversight Model Recommendations

• Briefing to the Agency Program Management Council, “Safety Risk Tolerance 

for the Human Spaceflight,” August 27, 2010

• FAA 2010 Commercial Space Transportation Forecasts, May 2010

• Letter from Former Columbia Accident Investigation Board Members to US 

Senator, Regarding Crew Safety

• Space Act Agreements and articles discussing the agreements regarding the 

commercial crew space industry
APPENDIX A

28 REPORT NO. IG-11-022

• Various articles from various space industry websites, addressing commercial 

space industry issues

Use of Computer-Processed Data. We did not rely upon computer-processed data to 

perform this review.

Review of Internal Controls

We reviewed internal controls related to the development and implementation of NASA’s 

safety and human-rating standards for the commercial space industry. Generally, we 

concluded that the internal controls related to the commercial space industry were 

adequate.

Prior Coverage

During the last 5 years, the NASA Office of Inspector General (OIG) and the 

Government Accountability Office (GAO) issued three reports of particular relevance to 

the subject of this report. Unrestricted reports can be accessed over the Internet at 

http://oig.nasa.gov/audits/reports/FY11 (NASA OIG) and http://www.gao.gov (GAO). 

NASA Office of Inspector General

“NASA’s Management of Ares I Human-Rating Requirements” (IG-09-016, May 21, 

2009).” 

Government Accountability Office

GAO Report GAO-09-618, “NASA: Commercial Partners are Making Progress, But Face 

Aggressive Schedules to Demonstrate Critical Space Station Cargo Transport 

Capabilities,” June 16, 2009. 

GAO Report GAO-10-286T, “Commercial Space Transportation: Development of the 

Commercial Space Launch Industry Presents Safety Oversight Challenges for FAA and 

Raises Issues Affecting Federal Roles,” December 2, 2009.
APPENDIX B

REPORT NO. IG-11-022 29

TECHNICAL AUTHORITY 

STANDARDS AND 

REQUIREMENTS

Type 1 - Mandatory Technical Authority Standards and Requirements Documents 

for Commercial Crew Transportation Systems

Technical 

Authority

Document Number Document Name

Health and Medical 

(1)

NASA-Standard-3001 

Volume 1

NASA Space Flight Human System Standard Volume 1: 

Crew Health

(2) NASA-Standard-3001 

Volume 2

NASA Space Flight Human System Standard Volume 2: 

Human Factors, Habitability, and Environmental Health

(3) FAA HFDS Human Factors Design Standard

(4) MIL-STD-1472 Human Engineering, Design Criteria for Military Systems, 

Equipment, and Facilities

(5) NASA-Standard-3000 

Volume I – II

Man-Systems Integration Standards.

Engineering (0) None

Safety and Mission 

Assurance (0)

None

Type 2 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Alternatives Allowed 

with NASA Approval

Technical 

Authority

Document Number Document Name

Health and Medical (0) None

Engineering (1) NASA-STD-0005 NASA Configuration Management (CM) Standard

(2) NASA-STD-4003 Electrical Bonding For NASA Launch Vehicles, 

Spacecraft, Payloads, And Flight Equipment

(3) NASA-STD-4005 Low Earth Orbit Spacecraft Charging Design 

Standard

(4) NASA-STD-5005 Standard for the Design and Fabrication of Ground 

Support Equipment

(5) NASA-STD-5017 Design and Development Requirements for 

Mechanisms
APPENDIX B

30 REPORT NO. IG-11-022

Type 2 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Alternatives Allowed 

with NASA Approval

Technical 

Authority

Document Number Document Name

(6) NASA-STD-5019 Fracture Control Requirements For Spaceflight 

Hardware

(7) NASA-STD-6016 Standard Manned Spacecraft Requirements for 

Materials and Processes

(8) NPR 2810.1 Security of Information Technology

(9) NPR 7120.5 NASA Space Flight Program and Project 

Management Requirements

(10) NPR 7123.1 NASA Systems Engineering Processes and 

Requirements

(11) NPR 7150.2 NASA Software Engineering Requirements

(12) JSC 65828 Structural Design Requirements and Factors of Safety 

for Spaceflight Hardware

(13) JSC 65829 Loads and Structural Dynamics Requirements for 

Spaceflight Hardware

(14) JSC 62809 Human Rated Spacecraft Pyrotechnic Specification

(15) JSC 65827 Thermal Protection System Design Standard for 

Spacecraft

(16) JSC 20793 Crewed Space Vehicle Battery Safety Requirements

(17)

JSC 62550

Strength Design and Verification Criteria for Glass, 

Ceramics, and Windows in Human Spaceflight 

Applications

(18)

JSC 65830

Interim Requirements and Standard Practices for 

Mechanical Joints with Threaded Fasteners in 

Spaceflight Hardware

(19)

JSC 65985 Deployable Aerodynamic Decelerator Requirements 

for Human Spaceflight

(20)

MIL-STD-461

Requirements for the Control of Electromagnetic 

Interference Characteristics of Subsystems and 

Equipment

(21) MIL-STD-464 Electromagnetic Environmental Effects Requirements 

for Systems

(22)

MIL-STD-981

Design, Manufacturing and Quality Standards for 

Custom Electromagnetic Devices for Space 

Applications

(23) MIL-STD-1540E/ 

Aerospace Report No. 

TR-2004 (8583) -1 Rev. A

Test Requirements for Launch, Upper-Stage, and 

Space Vehicles
APPENDIX B

REPORT NO. IG-11-022 31

Type 2 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Alternatives Allowed 

with NASA Approval

Technical 

Authority

Document Number Document Name

(24) AIAA S-111-2005 Qualification and Quality Requirements for Space 

Solar Cells

(25) AIAA-S-112-2005 Qualification and Quality Requirements for Space 

Solar Panels

(26)

ANSI/ESD S20.20-1999

ESD Association Standard for the Development of an 

Electrostatic Discharge Control Program for 

Protection of Electrical and Electronic Parts, 

Assemblies

(27) IPC-2221 Generic Standard on Printed Board Design

(28) IPC-2222 Sectional Design Standard for Rigid Organic Printed 

Boards

(29) IPC-6011 1996 Generic Performance Specification for Rigid Printed 

Boards

(30) IPC-6012 Qualification and Performance Specification for Rigid 

Printed Boards 

(31) IPC-CM-770E Component Mounting Guidelines for Printed Boards

(32) SAE ARP 5412A Aircraft Lightning Environment and Related Test 

Waveforms

(33) SAE ARP 5413 Certification of Aircraft Electrical/Electronic Systems 

for the Indirect Effects of Lightning

(34) SAE ARP 5414A Aircraft Lightning Zoning

(35) SAE ARP 5577 Aircraft Lightning Direct Effects Certification

Safety and Mission 

Assurance (1) NPD 8700.1 NASA Policy for Safety and Mission Success

(2) NPD 8710.5 Policy for Pressure Vessels and Pressurized Systems

(3) NPD 8730.1 Metrology and Calibration

(4) NPD 8730.2 NASA Parts Policy

(5) NPR 8000.4 Risk Management Procedures and Guidelines

(6) NPR 8621.1 NASA Procedural Requirements for Mishap and 

Close Call Reporting, Investigating, and 

Recordkeeping

(7) NPR 8705.5 Probabilistic Risk Assessment (PRA) Procedures for 

NASA Programs and Projects

(8) NPR 8705.6 Safety and Mission Assurance Audits, Reviews, and 

Assessments

(9) NPR 8715.3 NASA General Safety Program Requirements

(10) NPR 8715.5 Range Safety Program

(11) NPR 8715.6 NASA Procedural Requirements for Limiting Orbital 

Debris
APPENDIX B

32 REPORT NO. IG-11-022

Type 2 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Alternatives Allowed 

with NASA Approval

Technical 

Authority

Document Number Document Name

(12) NPR 8735.1 Procedures for Exchanging Parts, Materials, and 

Safety Problem Data Utilizing the GovernmentIndustry Data Exchange Program (GIDEP) and NASA 

Advisories

(13) NPR 8735.2 Management of Government Quality Assurance 

Functions for NASA Contracts

(14) NASA-STD 8709.20 Management of Safety and Mission Assurance 

Technical Authority (SMA TA) Requirements

(15) NASA-STD 8719.12 Safety Standard for Explosives, Propellants, and 

Pyrotechnics

(16) NASA-STD 8719.13 NASA Software Safety Standard

(17) NASA-STD 8719.14 Process for Limiting Orbital Debris

(18) NASA-STD 8719.17 NASA Requirements for Ground-Based Pressure 

Vessels and Pressurized Systems (PV/S)

(19) NASA-STD 8739.1 Workmanship Standard for Staking and Conformal 

Coating of Printed Wiring Boards and Electronic 

Assemblies

(20) NASA-STD 8739.4 Crimping, Interconnecting Cables, Harnesses, and 

Wiring

(21) NASA-STD 8739.5 Fiber Optic Terminations, Cable Assemblies, and 

Installation

(22) NASA-STD 8739.8 Software Assurance Standard

(23) ANSI Z117.1 Safety Requirements for Confined Spaces

(24) ANSI Z136.2 Safe Use of Optical Fiber Communication Systems 

Utilizing Laser Diode and LED Sources

(25) ANSI/AIAA S-080 Space Systems-Metallic Pressure Vessels, Pressurized 

Structures, and Pressure Components

(26) ANSI/AIAA S-081 Space Systems – Composite Overwrapped Pressure 

Vessels (COPV)

(27) ANSI/ESD S20.20 Protection of Electrical and Electronic Parts, 

Assemblies and Equipment (Excluding Electrically 

Initiated Explosive Devices)

(28) ANSI/NCSL Z540.3-2006 Requirements for the Calibration of Measuring and 

Test Equipment

(29) ASTM Manual 36 Safe Use of Oxygen and Oxygen Systems: 

Guidelines for Oxygen System Design, Materials 

Selection, Operations, Storage, and Transportation

(30) GEIA-STD-005-1 Performance Standard for Aerospace and High 

Performance Electronic Systems Containing LeadFree Solder

(31) IEEE 730-2002 IEEE Standard for Software Quality Assurance Plans
APPENDIX B

REPORT NO. IG-11-022 33

Type 2 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Alternatives Allowed 

with NASA Approval

Technical 

Authority

Document Number Document Name

(32) IPC J-STD-001D J-STD 001D, Requirements for Soldered Electrical 

and Electronic Assemblies

(33) IPC J-STD-001DS

Amendment 1

Space Applications Electronic Hardware Addendum 

to J-STD 001D, Requirements for Soldered Electrical 

and Electronic Assemblies

(34) SAE/AS5553 Counterfeit Electronic Parts; Avoidance, Detection, 

Mitigation, and Disposition

(35) SAE/AS9100 Quality Management Systems – AerospaceRequirements

Type 3 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Best Practices

Technical 

Authority

Document Number Document Name

Health and Medical (1) NASA/SP-2010-3407 Human Integration Design Handbook

Engineering(1)

GSFC-STD-1000

Goddard Space Flight Center Rules for the Design, 

Development, Verification, and Operation of Flight 

Systems

(2) JPR 8080.5 JSC Design and Procedural Standards

(3) KSC-DE-512 Facility, System, and Equipment General Design 

Requirements

(4) KSC-NE-9439 KSC Design Engineering Handbook for Design and 

Development of Ground Systems

(5)

NESC-RP-06-108/05-173-E

Design, Development Test and Evaluation 

(DDT&E) Considerations for Safe and Reliable 

Human Rated Spacecraft Systems

(6) RTCA DO-160E Environmental Conditions and Test Procedures for 

Airborne Equipment

(7) SAE ARP 5416 Aircraft Lightning Test Methods

Safety and Mission 

Assurance (1) NPD 8700.3 SMA Policy for NASA Spacecraft, Instruments, and 

Launch Services

(2) NPD 8720.1 NASA Reliability and Maintainability (R&M) 

Program Policy

(3) NPR 8715.3 NASA General Safety Program Requirements

(4) ANSI/ISO/IEC 17025-2000 General Requirements for Competence of Testing 

and Calibration Laboratories
APPENDIX B

34 REPORT NO. IG-11-022

Type 3 - Technical Authority Standards and Requirements Documents for 

Commercial Crew Transportation Systems - Best Practices

Technical 

Authority

Document Number Document Name

(5) ANSI/NCSL Z540.1-1994 

(R2002)

General Requirements for Calibration Laboratories 

and Measuring and Test Equipment

(6) AS 9003 Inspection and Test Quality System

(7) NASA-STD 2202-93 Software Formal Inspections Standard

(8) GIDEP S0300-BT-PRO-010 GIDEP Operations Manual

(9) GIDEP S0300-BU-GYD-010 Government-Industry Data Exchange (GIDEP) 

Requirements Guide

(10)

GSFC-STD-1000

Goddard Space Flight Center Rules for the Design, 

Development, Verification, and Operation of Flight 

Systems

Acronyms:

AIAA American Institute of Aeronautics and 

Astronautics

ANSI American National Standards Institute

ARP Aerospace Recommended Practice

AS Aerospace Standards

ASTM American Society for Testing and 

Materials

CM Component Mounting

ESD Electrostatic Discharge

FAA Federal Aviation Administration

GEIA Government Electronics and Information

Technology Association

GIDEP Government Industry Data Exchange 

Program

GSFC Goddard Space Flight Center

HFDS Human Factors Design Standard

IEEE Institute of Electrical and Electronics

Engineers

IEC International Electrotechnical 

Commission 

IPC Association Connecting Electronics 

Industries

ISO International Organization for 

Standardization

JPR Johnson Procedural Requirements

JSC Johnson Space Center

KSC Kennedy Space Center

MIL Military

NCSL National Conference of Standards 

Laboratories

NESC NASA Engineering and Safety Center

NPD NASA Policy Directive

NPR NASA Procedural Requirements

RTCA Radio Technical Committee for 

Aeronautics 

SAE SAE International

STD Standard
APPENDIX C

REPORT NO. IG-11-022 35

MANAGEMENT COMMENTS
APPENDIX C

36 REPORT NO. IG-11-022
APPENDIX D

REPORT NO. IG-11-022 37

REPORT DISTRIBUTION

National Aeronautics and Space Administration

Administrator

Deputy Administrator

Chief of Staff

Chief Engineer

Chief Safety and Mission Assurance Officer

General Counsel

Assistant Administrator for Procurement

Associate Administrator for Exploration Systems Mission Directorate

Associate Administrator for Space Operations Mission Directorate

Acting Director, Commercial Spaceflight Development 

Manager, Commercial Crew Program, Kennedy Space Center

NASA Advisory Council’s Audit, Finance, and Analysis Committee

Non-NASA Organizations and Individuals

Office of Management and Budget

Deputy Associate Director, Energy and Science Division

Branch Chief, Science and Space Programs Branch

Government Accountability Office

Director, NASA Financial Management, Office of Financial Management and 

Assurance

Director, NASA Issues, Office of Acquisition and Sourcing Management

Congressional Committees and Subcommittees, Chairman and 

Ranking Member

Senate Committee on Appropriations

Subcommittee on Commerce, Justice, Science, and Related Agencies

Senate Committee on Commerce, Science, and Transportation

Subcommittee on Science and Space

Senate Committee on Homeland Security and Governmental Affairs

House Committee on Appropriations

Subcommittee on Commerce, Justice, Science, and Related Agencies

House Committee on Oversight and Government Reform

Subcommittee on Government Organization, Efficiency, and Financial Management

House Committee on Science, Space, and Technology

Subcommittee on Investigations and Oversight

Subcommittee on Space and Aeronautics

REPORT NO. IG-11-022 39

Major Contributors to the Report:

Rebecca Sharek, Director, Space Operations Directorate

Raymond Tolomeo, Director, Science and Aeronautics Research Directorate

Loretta Atkinson, Project Manager

Frank Martin, Aerospace Technologist

Larry Neu, Aerospace Technologist

Eugene Bauer, Auditor
JUNE 30, 2011

REPORT No. IG-11-022

OFFICE OF AUDITS

OFFICE OF INSPECTOR GENERAL

ADDITIONAL COPIES

Visit http://oig.nasa.gov/audits/reports/FY10/ to obtain additional copies of this report, or contact the 

Assistant Inspector General for Audits at 202-358-1232.

COMMENTS ON THIS REPORT

In order to help us improve the quality of our products, if you wish to comment on the quality or 

usefulness of this report, please send your comments to Mr. Laurence Hawkins, Audit Operations and 

Quality Assurance Director, at Laurence.B.Hawkins@nasa.gov or call 202-358-1543.

SUGGESTIONS FOR FUTURE AUDITS

To suggest ideas for or to request future audits, contact the Assistant Inspector General for Audits. 

Ideas and requests can also be mailed to:

Assistant Inspector General for Audits

NASA Headquarters

Washington, DC 20546-0001

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To report fraud, waste, abuse, or mismanagement, contact the NASA OIG Hotline at 800-424-9183 or 

800-535-8134 (TDD). You may also write to the NASA Inspector General, P.O. Box 23089, L’Enfant 

Plaza Station, Washington, DC 20026, or use http://oig.nasa.gov/hotline.html#form. The identity of 

each writer and caller can be kept confidential, upon request, to the extent permitted by law.