GAO-13-317R Launch Services New Entrant Certification Guide

United States Government Accountability Office 

Washington, DC 20548

February 7, 2013

Congressional Committees

Subject: Launch Services New Entrant Certification Guide

This letter formally transmits the briefing slides we provided on February 1, 2013 in 

response to a House report accompanying the National Defense Authorization Act for Fiscal 

Year 2013 (Pub. L. No. 112-479 (2013)), which directed that we report to the congressional 

defense committees by February 1, 2013 with a review and analysis of the implementation 

of the Air Force Launch Services New Entrant Certification Guide (Guide). In 2011, the Air 

Force, National Aeronautics and Space Administration (NASA), and National 

Reconnaissance Office (NRO), implemented a coordinated strategy to certify new entrants 

to provide launch capability on Evolved Expendable Launch Vehicle (EELV)-class launch 

vehicles. New entrants are launch companies that are working toward certifying their launch 

vehicle capabilities so that they may be allowed to compete with the current sole-source 

contractor for government launches. Launch vehicle certification is necessary to ensure that

only proven, reliable launch vehicles will be used to launch government satellites. Currently 

only one provider is certified to provide EELV-class launch capability for government 

launches. To execute this strategy for national security space launches, the Air Force 

developed the Guide, which serves as a risk-based approach that the Air Force’s Space and 

Missile Systems Center is using to certify the launch vehicle capabilities of potential new

entrant launch providers. In response to the mandate, we addressed: (1) How the Air Force 

plans to implement its New Entrant Certification Guide, and (2) New entrant perspectives on 

becoming certified under the New Entrant Certification Guide. 

To conduct this work, we reviewed the Guide and other requirements documents, 

interviewed Air Force officials responsible for implementing the Guide, and spoke with all 

four potential new entrants identified by the Air Force to discuss their perspectives on 

becoming certified under the Guide. We conducted this performance audit from October 

2012 to February 2013 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.

In summary, the Air Force based its Guide on existing NASA policy and procedures with 

respect to payload risk classification and launch vehicle certification. Payloads are classified 

based in part on factors such as national significance, payload complexity and cost, and are 
Page 2 GAO-13-317R Launch Services New Entrant Certification Guide

assigned a risk tolerance level accordingly. The Air Force, NASA, and NRO are working to 

coordinate and share information to facilitate launch vehicle certification efforts; however, 

each agency will determine for itself when certification has been achieved. As a result, some 

duplication and overlap of efforts could occur. The Air Force has also added other

prerequisites to certification for new entrants that are not captured within the Guide, such as 

an approved implementation plan and a cooperative research and development agreement. 

According to the Air Force, these agreements are legal mechanisms intended to enable data 

sharing between the Air Force and new entrants, while protecting the interests of both. 

While potential new entrants stated that they are generally satisfied with the Air Force’s 

efforts to implement the Guide, they identified several challenges to certification, as well as 

perceived advantages afforded to the incumbent launch provider. For example, new 

entrants stated that they face difficulty in securing enough launch opportunities to become 

certified. The Under Secretary of Defense for Acquisition, Technology, and Logistics 

recently directed the Air Force to make available up to 14 launches for competition to new 

entrants, provided they demonstrate the required number of successful launches and 

provide the associated data in time to compete. If new entrants have not completed their 

final certification launch in time to compete, the newly-available launches will likely be 

awarded to the incumbent provider. New entrants stated they must also respond to changes 

in Air Force requirements that could impact their launch vehicle design and certification 

schedules. Air Force officials noted their intent to work with new entrants that may be 

affected by recent changes. Additionally, new entrants consider some Air Force 

requirements to be overly restrictive; for example, new entrants must be able to launch a 

minimum of 20,000 pounds to low earth orbit from specific Air Force launch facilities (versus 

facilities the new entrants currently use.) The Air Force stated that 20,000 pounds 

represents the low end of current EELV lift requirements, and that alternate launch sites are 

not equipped for the Air Force’s national security launches. Further, new entrants noted that 

the incumbent provider receives ongoing infrastructure and development funding from the 

government, an advantage not afforded to the new entrants, and that historical criteria for 

competition in the EELV program were more lenient. The Air Force acknowledged that 

criteria for competition are different, reflective of differences in the acquisition environment. 

For additional information on the results of our work, see enclosure I: Briefing on the Air 

Force’s Launch Services New Entrant Certification Guide. 

In commenting on a draft of this report, the Department of Defense (DOD) raised a concern 

that we erroneously stated that DOD used a different certification standard for the incumbent 

provider than will be applied to new entrants. However, the slide in question (page 22 of this 

report) was correct as it reflects the new entrant perception that the criteria for competition, 

not certification, were more lenient for the incumbent provider. As a result, no change was 

made in response to this comment. DOD also provided other technical comments which 

were incorporated as appropriate. DOD’s comments are reproduced in enclosure II: 

Comments from the Department of Defense. 

We are sending copies of this report to the appropriate congressional committees. We are 

also sending copies to the Secretary of Defense, the Secretary of the Air Force, the NASA 

Administrator, and the Director of the NRO. This report will also be available at no charge on 

our website at http://www.gao.gov. Should you or your staff have questions concerning this 

report, please contact me at (202) 512-4841or on chaplainc@gao.gov. 
Page 3 GAO-13-317R Launch Services New Entrant Certification Guide

Contact points for our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report were Art Gallegos, Assistant 

Director; Pete Anderson, Nabajyoti Barkakati, Claire Buck, Desiree Cunningham, John 

Krump, Brian Lepore, Carrie Rogers, Mike Shanahan, and Hai Tran. 

Cristina Chaplain

Director

Acquisition and Sourcing Management

Enclosures - 2 
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List of Committees

The Honorable Carl Levin

Chairman

The Honorable James Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Chairman

The Honorable Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Buck McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable C.W. Bill Young

Chairman

The Honorable Pete Visclosky

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Page 5 GAO-13-317R Launch Services New Entrant Certification Guide

Enclosure I: Briefing on the Air Force’s Launch Services New Entrant Certification Guide

THIS PRELIMINARY WORK OF GAO IS SUBJECT TO REVISION AND SHOULD NOT BE 

REPRODUCED OR DISTRIBUTED. SOME GRAPHICS MAY BE ENTITLED TO COPYRIGHT.

Air Force Launch Services 

New Entrant Certification Guide

Briefing to the Defense Committees in response to 

House Report accompanying National Defense 

Authorization Act for Fiscal Year 2013 (Pub. L. No. 

112-479 (2013))

February 1, 2013

Page 1
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Contents

• Introduction

• Objectives

• Background

• Objective 1: Air Force Implementation of the Guide

• Objective 2: New Entrant Perspectives

• Continuing Issues

• Agency Comments and Our Evaluation

• Scope and Methodology

• Comments from the Department of Defense

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Introduction

The Air Force is working to reintroduce competition into its Evolved 

Expendable Launch Vehicle (EELV) program for the first time in 

almost 15 years. Reasons include:

• Significant price increases for launch services 

• Emergence of additional potential viable launch providers 

• Desire to bolster the U.S. launch industrial base and introduce 

competition

In coordination with the National Aeronautics and Space Administration 

(NASA), and the National Reconnaissance Office (NRO), the Air 

Force has developed a Launch Services New Entrant Certification 

Guide to inform how the Air Force will certify the capability of 

potential new entrant launch companies to provide launch services 

and potentially compete for national security space (NSS) missions

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Objectives

As agreed with your offices, this briefing satisfies the mandate 

language provided to GAO in the House Report and 

addresses the following questions: 

(1) How does the Air Force plan to implement its New Entrant 

Certification Guide? 

(2) What are new entrant perspectives on becoming certified 

under the New Entrant Certification Guide?

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Background

• The EELV program is the primary provider of launch vehicles and capability for 

U.S. military and intelligence satellites. The launch vehicles used by the EELV 

program are also used to launch civilian and commercial satellites.

• The most recent independent cost estimate projects the program will cost close to 

$70 billion through 2030.

• The EELV program started in 1995 when the Air Force awarded contracts to four 

companies for preliminary launch vehicle system designs; at that time, the Air 

Force’s acquisition strategy was to select the one company with the most cost- effective design.

• Given commercial forecasts that predicted sufficient demand to support two 

launch vehicle providers, in 1997 the Secretary of Defense approved maintaining 

competition between the two top companies: Lockheed Martin, and what would 

become Boeing.

• Among other things, the new strategy was designed to 

• Promote competition, resulting in lower launch prices

• Encourage contractor investment in innovative technologies

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Background, cont.

• By the late 1990s, it was clear that the commercial market would not 

materialize, and in 2003 DOD’s cost estimate for the EELV program 

increased by 77 percent over the previous year

• The Air Force again revised its acquisition strategy for the program, this 

time to add program office oversight, focus on assured access to space, 

and reflect the lack of commercial demand and the government’s role as 

primary EELV customer

• DOD, NASA, and the NRO comprise the majority of EELV business

• In 2006, the two EELV contractors formed a single company under a joint 

venture, called the United Launch Alliance (ULA); consolidation of their 

launch businesses was expected to yield between $100 million and $150 

million in savings per year

• ULA has been successful in consolidating its operations and realizing 

significant savings, according to the Defense Contract Management 

Agency, but for various reasons, EELV program costs have continued to 

rise

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Background, cont.

• In late 2011, the Air Force revised its acquisition strategy for the EELV program; this 

strategy was designed to maintain mission success, stabilize the U.S. launch industrial 

base, reduce launch costs, and allow competition, among other things

• For the first time since the program began, new launch providers are emerging that 

could eventually meet EELV requirements and compete with the heretofore sole- source EELV contractor, ULA; we reported in 2011 that such competition could 

potentially yield cost savings to the government

• To that end, the Air Force, NASA, and the NRO embarked on a coordinated approach 

to encourage new entrants to compete for EELV-class missions

• In March 2011, the agencies signed a memorandum of understanding recognizing the need for additional launch vehicle providers

• In early October 2011, they developed a strategy to “provide a consistent path for new entrants to compete for [U.S. government] missions,” and agreed to adopt a framework consistent with NASA’s long-standing certification criteria, contained in NASA Policy Directive 8610.7D

• In late October 2011, the Air Force issued its Launch Services New Entrant 

Certification Guide (NECG), informed largely by NASA’s criteria, which outlines the 

risk-based approach the Air Force will use to certify the capabilities of new launch 

companies to compete for EELV-class missions

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Objective 1

Air Force Implementation of the NECG

• The Commander of the Air Force’s Space and Missile Systems Center is 

responsible for granting launch vehicle certification

• New entrants begin the process by issuing a Statement of Intent to certify 

a vehicle, which contains that vehicle’s planned capabilities

• Certification can occur following approval of milestones and completion of 

activities outlined in the NECG; new entrants submit a formal “certification 

plan,” which outlines the tailored certification approach through which a 

new entrant intends to achieve certification

• A separate certification plan and process is required for each launch 

vehicle configuration; additionally, if a certified launch vehicle undergoes 

changes that “substantially affect” certain factors outlined in the NECG, 

such as operating time or engine thrust profile, that vehicle must re-enter 

the certification process from the beginning

• Certification does not guarantee contract award

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Objective 1

Air Force Implementation of the NECG:

Interagency Coordination

• The coordinated certification strategy between the Air Force, NASA, and 

NRO provided that the agencies would use a common framework for 

launch vehicle certification, based on existing NASA policies; however, the 

strategy allows agency interpretation and certification requirements to 

differ. For example, each agency may determine for itself

• The number of launches a new entrant must complete prior to 

competing for contract award

• How terms such as “common vehicle configuration” are interpreted

• Which changes to a launch vehicle will “substantially affect” the 

configuration

• The sufficiency of data provided by the new entrant, and the format in 

which it will be accepted

• The order in which certification steps will take place

• Air Force officials acknowledged significant overlap in the certification 

process employed by each agency, and indicated they are working with 

NASA and the NRO to share data and avoid unnecessary duplication of 

efforts for new entrants

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Objective 1

Air Force Implementation of the NECG:

Launch Vehicle Risk Classification

• The NECG is closely based on NASA’s Policy Directive (NPD) 8610.7, 

which according to NASA officials was originally released in 1999, and 

provides a methodology for certifying launch vehicles based on payload 

risk classifications.

• There are three risk categories of launch vehicles: Categories 1, 2, and 3. 

Each category is based on the risk associated with that vehicle; Category 

1 launch vehicles are considered the highest-risk vehicles, and do not 

require any previous flights before launching a government payload. 

• In addition to the three vehicle risk categories, there are alternatives 

within the categories that require varying numbers of successful 

consecutive launches and levels of government technical evaluation, 

depending on the risk tolerance of the payload class a vehicle is 

intended to carry.

• The NECG requires all new entrants to develop a certification plan that will 

eventually bring their vehicle to a Category 3 certification, meaning it can 

launch the most-critical, least-risk tolerant payloads.

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Objective 1

Air Force Implementation of the NECG:

Payload Risk Classification

• The Air Force plans to use NASA’s payload risk evaluation approach, as outlined in NASA’s Procedural 

Requirements 8705.4, which among other things, provides a framework for assigning risk tolerance to 

payloads based on numerous factors, such as national significance, payload complexity, and cost. 

Under this framework, payloads can be assigned Class A-D; a payload’s class determines the risk 

category of the vehicle on which it will launch. 

• Payloads classified as more tolerant to risk—such as Classes B, C, or D—could provide an opportunity 

for new entrants to gain experience launching government payloads. However, at this time, according to 

Air Force officials: 

• Most NSS payloads are considered Class A, and therefore require the most proven launch 

vehicles, such as those in launch vehicle risk Category 3

• No Air Force process exists to reassess payload risk classification, potentially limiting opportunities 

for new entrants to prove their launch vehicle, and subsequently compete for launches. Air Force 

officials state that work is ongoing to develop a process by which to reassess NSS payload risk 

classification. 

Page 11

Payload Class Launch Vehicle Assignment

Class A This class represents the most critical payloads, thus Class A payloads must be 

launched on the most proven, least risky launch vehicles. Vehicles that launch 

Class A payloads are the most mature, demonstrated successful launch 

vehicles 

Class B, C, D Payloads outside Class A are considered more tolerant to risk, and can be flown 

on launch vehicles with a progressively higher risk rating
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Objective 1

Air Force Implementation of the NECG:

Prerequisites for Certification Outside the NECG

Some new entrant prerequisites have been added that are outside the NECG, and are likely to 

add time and potentially cost to the new entrant certification process. For example, 

• Prior to approval of a certification plan, new entrants must

• Develop an implementation plan with the Air Force that describes in greater detail 

the new entrant’s timeframes, to be approved by the Air Force.

• Sign an approved cooperative research and development agreement (CRADA) 

with the Air Force; Air Force officials said this was a legal mechanism that protects 

the Air Force and the company’s interests, but there are concerns the process 

could add time to their certification timeline.

• New entrants will be required to integrate payloads with the launch vehicle upright, or 

vertical, and the payload attached to the vehicle from above, as NSS payloads are 

currently designed to be vertically integrated. 

• Though not mentioned in the NECG, Air Force officials confirmed that new 

entrants will be required to vertically integrate payloads, even if the new entrant’s 

launch vehicle was designed to horizontally integrate payloads.

• Senior Air Force officials indicated that even if a payload could be retrofitted to be 

horizontally mated to the launch vehicle and significant cost savings could be 

realized by allowing horizontal integration, the requirement for vertical payload 

integration would stand, as NSS payloads are designed to be vertically mated to 

the launch vehicle.

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Objective 1

Air Force Implementation of the NECG:

New Entrants In the Certification Process 

Company Launch vehicle 

to be certified

Statement of 

Intent to certify 

submitted

Certification 

plan

Planned 

certification date

Alliant Techsystems, 

Incorporated (ATK)

Liberty II Expected March 

2013

TBD Late 2016

Lockheed Martin Athena III May 2012 Under 

development

Under 

development

Orbital Sciences 

Corporation (Orbital)

Antares June 2012 In negotiation 2017-2018

Space Exploration 

Technologies 

(SpaceX)

Falcon 9 February 2012 In negotiation Late 2013

SpaceX Falcon Heavy June 2012 In negotiation Late 2015

Page 13

Source: Company data 
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New entrant-identified challenges to certification

1 Lack of launch opportunities to foster certification

2 Unanticipated requirements changes

3 Minimum 20,000 lb lift requirement to low earth orbit (LEO)

4 Inflexibility of launch and range site options

Objective 2

New Entrant Perspectives on Certification

We spoke with the four potential new entrants pursuing launch vehicle 

certification under the NECG. All four companies said they were satisfied with 

the NECG and the Air Force’s efforts to facilitate launch vehicle certification.

Each noted potential challenges, however, in becoming certified under the NECG 

to compete for NSS missions. They also perceived advantages afforded to the 

current sole-source EELV provider. Below are the challenges identified by one 

or more new entrant, each of which is explained in greater detail on the 

following slides.

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Objective 2

New Entrant Perspectives on Certification:

Identified Challenges

Page 15

Identified challenge #1: Lack of new entrant launch opportunities on the path to certification poses risk to 

launch vehicle certification schedule

Issues to 

overcome

•Because nearly all NSS missions are Class A, they may not provide an opportunity for new entrants 

to gain experience on the path to certification; new entrants must meet the most stringent 

requirements prior to competing for Class A missions.

•The Air Force made two research missions available to help enable new entrant certification, but the 

alternatives for a Category 3 launch vehicle require between 2 and 14 successful consecutive flights.

The wide range is due to the variable technical oversight required for each alternative; an alternative 

requiring fewer consecutive flights typically necessitates greater government oversight and technical 

reviews.

•Additionally, the Air Force recently made 14 launches available for competition beginning in 2015, 

but to be eligible to compete for these launches, new entrants must successfully execute the 

requisite number of non-NSS launches and submit data from their final certification launch.

Air Force 

action

•Air Force officials told GAO that they are currently developing a process to reassess payload risk

classifications for NSS payloads, but state that reclassification of NSS missions to reflect increased 

payload risk tolerance is unlikely for several reasons, including the inherent national significance of 

NSS missions, and the unintended stigma attached to rendering one mission “less critical” than 

another.

•Air Force officials indicate commercial launches will count toward certification, provided the launch 

vehicle configuration used is identical to the vehicle for which the new entrant is pursuing 

certification.
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Identified challenge #2: Unanticipated requirements changes could impact new entrant vehicle design and 

certification schedule

Issues to 

overcome

•In July 2012, the Air Force revised the Standard Interface Specification document (SIS). The SIS provides 

technical requirements for integration between the payload and the launch vehicle. New entrants were not 

invited to comment on draft revisions, or the impact those revisions might have on their launch vehicle 

designs. New entrants are now determining the significance of the SIS revisions to their vehicle design, 

and the likely effect on their certification schedule. Further, new entrants told us ULA, the current EELV 

contractor, was involved in developing the SIS revisions, which in some cases reflect current ULA 

capabilities.

• New entrants expressed concern that other requirements documents could change without notice, and 

additional requirements could be added to the certification process, increasing the schedule and 

potentially adding to the cost of launch vehicle certification.

Air Force 

action

•Air Force officials told us the SIS revisions would not have a significant impact on new entrants, although 

they acknowledged that they did not ask or assess what the impact on new entrants would be. Air Force 

and ULA officials confirmed their joint development of SIS revisions, which in some cases reflect current 

ULA capabilities. 

•Air Force officials said the System Performance Requirements Document, which governs minimum 

launch system performance requirements, is currently undergoing revision. They indicated revisions will be 

made available to new entrants prior to finalization, and that the new entrants will be invited to comment 

on the changes. 

•Air Force officials acknowledge that certification criteria could change while a new entrant is undertaking 

certification. For example, the implementation plan and CRADA requirements were recently added, but 

officials say they will work with new entrants for whom requirements changes may have an impact.

Objective 2

New Entrant Perspectives on Certification:

Identified Challenges 

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Objective 2

New Entrant Perspectives on Certification:

Identified Challenges 

Page 17

Identified challenge #3: Minimum 20,000 lb lift requirement to low earth orbit is overly restrictive

Issues to 

overcome

New entrants indicate that this requirement is overly restrictive to their business plans, noting that 

commercial customers typically do not require this much lift capability; new entrants with no 

commercial demand for larger launch vehicles would prefer to compete for small and medium NSS 

payloads, leaving larger NSS payloads to other providers.

Air Force 

action

No action expected; Air Force officials indicated that 20,000 lbs is the low end of current EELV lift 

capability, and that most NSS payloads for the foreseeable future require this level of lift. Air Force 

officials acknowledged, however, the possibility that future missions could tend toward smaller 

satellites that could require less lift capability to launch.

Identified challenge #4: Inflexibility of launch and range site options could add cost to new entrant 

baselines

Issues to 

overcome

The NECG requires new entrants to be able to launch from both the Cape Canaveral Air Force 

Station in Florida (Cape), and Vandenberg Air Force Base in California (Vandenberg), even if a new 

entrant has existing alternate East- and West-Coast launch sites. New entrants indicated that building 

or refurbishing additional launch facilities at the required sites could be costly. It is unclear whether 

new entrants can wait to invest in new launch sites until they establish a business case for the site.

Air Force 

action

No action expected; Air Force officials indicated that existing sites at locations other than the Cape 

and Vandenberg were not comparably equipped for NSS launches; for example, they lack the 

necessary payload integration facilities. 
Page 22 GAO-13-317R Launch Services New Entrant Certification Guide

Objective 2

New Entrant Perspectives on Certification:

Advantages to ULA

In addition to the challenges noted, new entrants identified perceived 

advantages given to ULA through the EELV program. For example, 

• DOD provides about $1 billion a year to ULA to support its national launch infrastructure, and provides funding to ULA for ongoing engine and other technology development. 

• The recent SIS revisions were developed with ULA, and in some 

cases are tailored to current ULA launch vehicle capabilities. These revisions resulted in minimal impact on ULA vehicle design, but the 

impact on new entrant vehicles is still unknown. Air Force officials 

indicate that the SIS revisions were developed over several years, 

and reflect current NSS mission needs.

• New entrants note that historical criteria for competition in the EELV program were more lenient than those applied to new entrants under the NECG. For example, Boeing and Lockheed 

Martin were allowed to compete for launch contracts prior to 

completion of final vehicle designs. Air Force officials acknowledge 

that criteria to compete for launches were different in the 1990s, noting that the acquisition environment was also different.

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Continuing Issues

• In late 2012, the Undersecretary of Defense for Acquisition, Technology, and 

Logistics signed an Acquisition Decision Memorandum outlining the parameters of 

an upcoming block buy of launch vehicles from ULA and setting forth 

opportunities for new entrants to compete for upcoming missions. The Air Force 

continues to work toward implementing the decisions.

• The Air Force is currently negotiating a contract with ULA that is expected to 

cover 5 years of launch services and procure up to 36 launch vehicles. 

• The Air Force has made up to 14 EELV missions available for competition, 

which represent nearly all NSS launches that could potentially be performed 

by new entrants, based on capability and readiness assessments. However, if 

new entrants have not completed all certification launches in time to compete, 

those launches would also likely be awarded to ULA. 

• Some certification decisions that could affect new entrant competition have yet to 

be finalized. For example, the Air Force is planning to

• Develop a payload risk classification process over the next year. Though Air 

Force officials stated that NSS payloads will most likely remain in Class A, 

there may be science and technology missions that could be classified as 

more tolerant to risk, thereby providing opportunities for new entrants to gain 

launch experience and build toward vehicle certification.

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Agency Comments and Our Evaluation

We provided a draft copy of this briefing to the Secretary of 

Defense for comment in December 2012. In written comments 

on the draft briefing, DOD raised a concern that we 

erroneously stated that DOD used a different certification 

standard for the incumbent provider than will be applied to 

new entrants. However, the slide in question (slide 18) was 

correct as it reflects the new entrant perception that the 

criteria for competition, not certification, were more lenient for 

the incumbent provider. As a result, no change was made in 

response to this comment. DOD also provided other technical 

comments, which were incorporated, as appropriate.

DOD comments are reprinted following the Scope and 

Methodology section.

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Scope and Methodology

Site visits, interviews, and information obtained from:

• Air Force Space Command headquarters, Peterson Air Force Base, Colorado Springs, Colorado

• Air Force Space and Missile Systems Center, Launch and Range Directorate, Los Angeles Air Force Base, El 

Segundo, California

• Defense Contract Management Agency, various locations

• Department of Defense, Under Secretary for Acquisition, Technology and Logistics, Space and Intelligence 

Office, Arlington, Virginia

• Department of Defense, Office of Inspector General, Alexandria, Virginia

• National Aeronautics and Space Administration headquarters, Washington, District of Columbia

• National Reconnaissance Office, Chantilly, Virginia

• Office of the Secretary of Defense, Cost Assessment and Program Evaluation, Washington, District of Columbia

• Program Executive Officer for Space Launch, Washington, District of Columbia

• Secretary of the Air Force, Acquisition Directorate of Space Programs, Arlington, Virginia

• The Aerospace Corporation, El Segundo, California

• United Launch Alliance, Centennial, Colorado

Site visits and interviews with potential new entrants:

• Alliant Techsystems, Incorporated, Aerospace Systems Division, Magna, Utah

• Lockheed Martin Commercial Launch Services, Denver, Colorado

• Orbital Sciences Corporation, Huntington Beach, California

• Space Exploration Technologies Corporation, Hawthorne, California

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Scope and methodology, cont.

To determine how the Air Force plans to implement its New Entrant Certification Guide (NECG):

• We reviewed relevant documents, including the NECG; EELV Acquisition Strategy; 

Coordinated Strategy Among the Air Force, NASA, and the NRO; NASA policy documents 

referenced in the NECG; and Air Force documentation germane to implementation plans. 

• We identified and reviewed current EELV requirements, including the Standard Interface 

Specification and Operational Requirements Document, to identify additional launch vehicle 

requirements with which new entrants must comply in order to achieve certification.

• We interviewed top Air Force and industry officials to discuss implementation plans and 

preliminary observations.

• We interviewed NASA officials on their launch vehicle certification and payload classification 

policies to determine key differences between Air Force and NASA processes.

• We assessed the extent to which coordination is occurring among the Air Force, NASA, and 

NRO, through interviews with officials at the three agencies.

• We compared current and historical requirements to determine the extent to which current 

requirements are more stringent or flexible.

• We reviewed future launch manifests to determine if the requirements contained within the 

Guide are reasonable given the expected needs of future NSS payloads. 

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Scope and methodology, cont.

To determine new entrant perspectives in becoming certified under the 

NECG:

• We interviewed all four companies identified by the Air Force as 

potential new entrants to obtain perspectives on certification 

challenges and discuss questions they had on the NECG and the 

launch vehicle certification process. In order to properly safeguard 

proprietary data, we summarized their responses and reflected an 

aggregate response in our briefing. 

• We also analyzed current EELV requirements documents to identify 

potential issues for the new entrants, and discussed these 

observations with representatives from each company and relevant Air 

Force officials. 

• We provided a draft copy of this briefing to each new entrant. They 

submitted technical comments, which were incorporated as 

appropriate.

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Page 28 GAO-13-317R Launch Services New Entrant Certification Guide

Scope and methodology, cont.

We conducted this performance audit from October 2012 to 

February 2013 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.

Page 24
Page 29 GAO-13-317R Launch Services New Entrant Certification Guide

Enclosure II: Comments from the Department of Defense
Page 30 GAO-13-317R Launch Services New Entrant Certification Guide

(121094) 
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