November 2, 2023

NASA’s Initial Assessment of Models For A Next Generation Microgravity National Laboratory 

In September 2022, the National Space Council directed NASA to “develop a plan for the next 

generation microgravity national lab in a commercial space station world.” NASA has been working 

to develop this strategy, with planning led by the Space Operations Mission Directorate (SOMD) and 

the Office of Technology, Policy, and Strategy (OTPS). The report below, titled “Models for 

Facilitating Government-Funded Activities in the Post-International Space Station (ISS) Low-Earth 

Orbit (LEO) Ecosystem” is one step in NASA’s effort to define and develop a comprehensive strategy.

The ISS National Laboratory (ISSNL) was created by the NASA Authorization Act of 2005 and has 

become an essential tool for users to fly research, technology demonstrations, and Science, 

Technology, Engineering, and Math (STEM) activities to the space station. As directed by the NASA 

Authorization Act, 50% of U.S. ISS resources are allocated for non-NASA, National Lab use. Under a 

cooperative agreement with NASA, the Center for the Advancement of Science in Space (CASIS) in 

Melbourne, FL, manages all non-NASA research for users such as other U.S. government agencies, 

universities, and commercial entities, administered through the ISSNL. NASA maintains 

responsibility for integrating and manifesting all research on the ISS U.S. On-Orbit Segment (USOS) 

which includes NASA, ISSNL, the Japan Aerospace Exploration Agency (JAXA), the European Space 

Agency (ESA), and the Canadian Space Agency (CSA). 

The ISSNL model has been successful in growing non-NASA interest in utilization of a platform for 

microgravity research and applications. To date, over 700 projects have flown, with over two-thirds 

developed by commercial users. In FY23, 35 publications were released bringing the total to 265 

publications since the National Lab first began. As in previous years, many of these publications 

were made possible by research collaborations with other U.S. Government agencies including the 

National Science Foundation and the National Institutes of Health which funded research in space to 

address national research priorities in their portfolios. In FY23, 9 additional flight projects were 

funded by the National Science Foundation in collaboration with CASIS, and the National Center for 

Advancing Translational Sciences at the National Institutes of Health committed to fund and relaunch the Tissue Chips in Space collaboration with CASIS in FY25. CASIS, in partnership with NASA’s 

Biological and Physical Sciences Division, announced the Igniting Innovations solicitation, seeking 

flight research to address the goals of the Cancer MoonshotSM initiative and accelerating the 

translation of stem cell and organoid-based disease models and advanced technologies for 

biomanufacturing. In response to this new solicitation, over 50 concept white papers were 

submitted and are currently in review.

Given this successful trajectory, continuity of a national lab in LEO is an important objective and 

consideration in NASA’s transition from the ISS to Commercial LEO Destinations (CLDs) at the end of 

the decade. Recognizing that the current ISSNL model needs to evolve as the infrastructure changes 

National Aeronautics and Space Administration

Mary W. Jackson NASA Headquarters

Washington, DC 20546-0001
from a government-owned platform to commercially-owned platforms from which the government 

will purchase services, NASA’s OTPS conducted a study of various candidate “models” of future 

operations between a National Laboratory and various Commercial LEO Destination (CLD), which is 

included and summarized below. The study answered two fundamental questions: 

1. What are potential models for an ISS National Lab facilitating government-funded or 

subsidized activities on a commercial LEO platform after the transition of the ISS to one or 

more private platforms? 

2. In light of these options, what modifications would be helpful to make in the current ISSNLCASIS partnership and the NASA management processes as NASA plans for the transition of 

the ISS by 2030?

As described in the study report, six models were identified ranging from high levels of government 

oversight to a low levels of government oversight; each model was assessed across three potential 

future economy growth scenarios. The models are illustrative and hold positive attributes designed 

to inform strategy development for a future national laboratory. The report concludes that no one 

model on its own represents a complete strategy for a future national laboratory. With the report, 

along with responses from a December 2022 White House Office of Science and Technology Policy 

(OSTP) Request for Information as inputs, NASA’s SOMD has been able to continually evaluate a 

combination of models that will best represent its recommended strategy. Some initial aspects of 

that strategy are included as follows. 

As outlined in the National LEO R&D Strategy released in March 2023, a national laboratory in LEO 

should enable the accomplishment of the following goals: 

1. Maintaining U.S. leadership in space for research, technology development and innovation; 

2. Coalescing additional U.S. government efforts to utilize space to achieve national objectives, 

solve the world’s greatest challenges, and improve lives; 

3. Supporting additional government funded scientists and engineers with access to expertise 

and in-space research facilities; 

4. Enabling international cooperation; and 

5. Creating opportunities for STEM and diverse workforce development.

An ideal national lab will: 

1. Represent all U.S. Government needs for space-based research;

2. Encourage collaboration;

3. Be scalable to demand;

4. Be platform agnostic, leveraging existing and new ground and space capabilities;

5. Provide equitable access for all and act as an honest broker; and

6. Foster workforce development.

By designing the future construct to represent all U.S. Government-sponsored research, 

collaboration between NASA and non-NASA users is increased and opportunities are consolidated 

into a single-entry portal for users. This approach will enhance the user experience, reduce 

overhead, encourage collaboration, and allow resource sharing between agencies. 

As NASA continues to define the details of a post-ISS national lab strategy, the following issues 

remain in development: 

1. Management structure of the national lab

2. Definition of roles and relationships including NASA, other U.S. government agencies, and 

commercial platform and service providers, ensuring a future national lab does not generate 

competition for, but rather supports and bolsters U. S. industry 

3. Pathways for international cooperation

4. Proposed changes to NASA’s national lab authorization legislation 
5. Development of a stepwise transition strategy to enable continuity between the ISSNL and 

the post-ISS national lab, including evolution as the LEO ecosystem matures

6. Consideration of whether the name “national lab” is the best descriptor for the future 

construct, particularly since it would leverage multiple commercial platforms and 

capabilities

As NASA develops these details, the agency is actively engaging stakeholders including NASA, other 

U.S. government agencies, commercial industry, and the user community. NASA looks forward to 

sharing updates as this work progresses and is committed to developing a comprehensive strategy 

that is an improvement on the incredible infrastructure that exists today to ensure that U.S. 

government research and technology development in LEO continues to improve life on Earth.
 

 

November 2, 2023 

Report ID: 20230005232 

NASA Headquarters 

300 E Street SW 

Washington, DC 20024 

Office of Technology, Policy, and Strategy 

Models for Facilitating 

Government-Funded 

Activities in the PostISS LEO Ecosystem 

Erica Rodgers, Patrick Craven, Jason Hay, Amanda 

Hernandez, Nikolai Joseph, Rachael Lussos, Maia Robakidze, 

Perri Thaler, Kenneth Wright, and Grace Wusk 

i 

Reviewers: Patrick Besha, Tom Colvin, Christie Cox, Robyn Gatens, 

Elaine Gresham, Ave Kludze, Emily Sylak-Glassman

This report is intended for informational purposes only, and does not 

indicate a commitment or intention, implied or otherwise, by the 

government to engage in any activity or to enter into any agreement, 

contract or other obligation. The inclusion of information in this report 

does not constitute endorsement of any entity, or any products, services, 

technologies, activities, or Agency policy.
 

 

 

 

Executive Summary 

Models for Facilitating Government-Funded 

Activities in the Post-ISS LEO Ecosystem 

November 2, 2023 Report ID: 20230005232 

Purpose of the Study 

This study helps elucidate NASA’s future options for facilitating government-funded activities 

in the post-International Space Station (ISS) low-Earth orbit (LEO) ecosystem. NASA is 

preparing for the retirement of the ISS and transition of LEO activities to one or more 

Commercial LEO Destinations (CLDs) by 2030. This transition necessitates new models for 

connecting NASA and other users of the LEO environment to platforms and opportunities. 

NASA’s current model for facilitating non-exploration activities is embodied in the 

International Space Station National Lab (ISSNL). ISSNL was established through congressional 

authority in 2005 and has been managed by a nonprofit called the Center for the Advancement 

of Science in Space (CASIS) since 2011. CASIS was created with a mission to foster scientific 

discovery and technological innovation in space, expand U.S. leadership in commercial space, 

and inspire the next generation. 

As the LEO ecosystem evolves through growth of the commercial space industry and as part of 

NASA’s strategic goal to support development of a robust LEO economy in which many 

stakeholders on Earth can participate, so must the current ISSNL model, to ensure taxpayers 

realize the highest return on their investment in LEO. 

The purpose of this study is to answer the following two questions: 

1. Potential Models: What are potential models for an ISS National Lab facilitating

government-funded or subsidized activities on a commercial LEO platform after the

transition of the ISS to one or more private platforms?

2. Near-Term Impact: In light of these options, what modifications would be helpful to make

in the current ISSNL-CASIS partnership and the NASA management processes as NASA plans

for the transition of the ISS by 2030?

To address these questions, we conducted over 40 discussions with stakeholders internal and 

external to NASA and reviewed over 35 documents related to legislation, governance, LEO 

commercialization, potential models, and activities performed in microgravity and LEO. 

For more information on the NASA Office of Technology, Policy, and Strategy to view this and other reports visit 

https://www.nasa.gov/offices/otps/home/index.html 
 

 

 

 

 

 

 

 

 

 

 

Key Findings 

Question 1: Potential Models 

This report describes for consideration six models for facilitating government-funded activities 

in the post-ISS LEO ecosystem, as shown in Table 1. The ISSNL model is included as a baseline 

to identify near term opportunities to improve NASA’s posture for success post-ISS. 

Table 1. Six differentiated models for facilitating government-funded activities in the post-ISS LEO ecosystem 

Model Differentiator Description 

ISSNL Reflection of 

current operations 

Third party agreement to manage 50% of ISS U.S. segment 

activities for a broad range of academic, government, and 

commercial users. 

1. Anchor 

Tenant 

Long-term 

agreement for 

leasing space on a 

commercial 

platform 

NASA as anchor tenant on CLD with dedicated destination 

for LEO activities. NASA program office is agent for all 

government-sponsored activities. Commercial users work 

directly with platform provider or respond to government 

proposal requests. 

2. Government 

Research 

Broker 

Customizable 

research using 

combinations of 

NASA program office guided by advisory committee brokers 

payloads to LEO, conducts mission planning, and negotiates 

end-to-end services. Flexible contract with CLDs based on 

transport vehicles 

and CLDs 

short term needs. Crewed and uncrewed missions for 

flexible government research needs. 

3. Innovation 

Campus 

Modern terrestrial 

campus with 

workforce focus 

Government-owned terrestrial campus operated by nongovernment entity. Dedicated to advancing research and 

development. Focused on innovation and building LEO 

workforce rather than connecting users to platforms. 

4. Matchmaker Neutral third party 

connecting users to 

platforms 

Nonprofit funded by NASA to match specific users to LEO 

opportunities based on mission and technical requirements. 

Provides clear entry point for users and providers. 

Aggregates and communicates user demand to industry. 

5. Institute 

Network 

Network of 

separate but related 

efforts to enable 

commercial scaling 

and U.S. leadership 

Government-sponsored consortia of distinct but related 

institutes within LEO and terrestrially. Institutes funded 

through public-private partnerships managed by nonprofits. 

CLD facilities leased from providers within institutes. 

6. Fee for 

Service 

Free market 

approach 

Industry-driven model focused on transactions for services. 

Users purchase goods and services from providers. NASA is 

one user and leverages grants and data buys to meet needs. 

MORE LESS Level of Government Oversight 

These six models represent a wide trade space of potential options, each relying on unique 

mechanisms for facilitating activities on one or more commercial LEO platforms. The models as 

shown generally range from more to less government oversight, including options for 

facilitation of activities within a NASA program office—Anchor Tenant and Government 

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Research Broker—or through a non-governmental organization—Innovation Campus, 

Matchmaker, and Institute Network. 

We assessed each model across three possible future scenarios varying in number and 

diversity of LEO activities and commercial offerings—dynamic growth, steady growth, and 

limited growth—and across five stakeholder-driven model evaluation criteria—ability to meet 

NASA’s needs; adaptability to infrastructure, service provider offerings, and user demands; 

opportunity for collaboration; market sustainability; and equity and accessibility. 

Model Insights 

The Government Research Broker model performs best across all future scenarios, followed by 

Innovation Campus, Anchor Tenant, and Fee for Service, as shown in Table 2. While 

Matchmaker and Institute Network exhibit positive aspects, these models perform most 

favorably in future scenarios with well-established communities and markets and we do not 

preclude their viability for consideration. We list the key considerations for each of the models 

below, starting with the best performing. 

Table 2. Evaluation criterion or criteria assessed as favorable across all future scenarios for each model 

Model Criterion or Criteria assessed as favorable across all scenarios 

Government Research Broker Ability to Meet NASA’s Needs, Opportunity for Collaboration, 

Adaptability, Equity & Accessibility 

Innovation Campus Ability to Meet NASA’s Needs, Opportunity for Collaboration

Anchor Tenant Ability to Meet NASA’s Needs, Opportunity for Collaboration 

Fee for Service Adaptability, Market Sustainability 

Matchmaker Adaptability 

Institute Network None 

ISSNL Equity & Accessibility, Market Sustainability 

Government Research Broker 

The Government Research Broker provides a reliable option for NASA to continue activities in 

LEO in any future scenario, meeting the needs of all but one of the stakeholder-driven 

performance criteria. The range of built-in flexibilities can buffer against changes in available 

infrastructure and against how capabilities across CLDs may develop. Shortcomings in market 

sustainability can be designed against by incentivizing port standardization and ensuring 

mutual government-industry benefits. The high level of government involvement, combined 

with the ability to optimize the government’s research space as needed, make this model a 

viable option for consideration. If using this model, NASA will need to address the Commercial 

LEO Development Program’s exclusion of sortie-style research options from CLD awards. 

iv 
 

 

Innovation Campus 

The Innovation Campus model is designed to augment efforts in LEO with ground-based 

resources and can best do so in a dynamic environment, where there are many stakeholders 

and enough funding to support activities. Assuming a separate model can connect users with 

commercial platforms, this model can help ensure the government maintains a skilled LEO 

workforce with the added benefit of scaling to account for mission needs beyond LEO. In future 

scenarios with less opportunity, however, resource limitations can hinder its benefit to some 

non-government users (and to government users in a very limited future scenario). The utility 

of this model could be enhanced by efforts to expand participation across the government, 

including adding other agencies as sponsors—similar to the Institute Network model—and by 

enabling pathways for industry to access campus resources. 

Anchor Tenant 

Anchor Tenant provides a long-term steady engagement with a CLD, which leads to reliable 

access for NASA to support a significant portion of its exploration needs. The model is best 

suited for a steady growth scenario, where markets and users may still rely on government 

involvement to advance interests. Reliable tenancy provides opportunities for collaboration, 

assuming they were identified when drafting the agreement. This model does not easily adapt 

to changing needs and can hinder long-term economic growth for some users. NASA can 

mitigate some of these weaknesses by leveraging flexible contracting pathways, establishing 

alternative pathways for international partners, expanding leased space to other platforms, and 

looking to the Government Research Broker model to conduct research in transient vehicles. 

Fee for Service 

The Fee for Service model embodies a flexible, free market and is particularly well suited to 

steady and dynamic growth scenarios in which the commercial potential of LEO is more fully 

realized. The model can generally adapt to activities, infrastructure, etc.; however, activities 

may skew towards those that generate the most revenue. NASA’s demands are clearly 

communicated through grants and service/data buys, and users whose interests align well with 

NASA’s interests may most benefit from these funding pathways. Barriers to entry may be 

prohibitive for some, including some international users. A free market approach somewhat 

limits NASA’s ability to strengthen the model’s limitations. However, economic policies may 

help channel commercial investment into areas that better meet NASA’s needs, enable 

collaboration across the government, and ensure accessibility. The U.S. government can also 

encourage practices that promote equity and accessibility and provide incubation support to 

businesses (similar to current ISSNL-CASIS efforts) to steer economic development. 

Matchmaker and Institute Network 

The Matchmaker is a third-party nonprofit funded by NASA that connects user activities 

directly with platform providers based on mission and technical requirements. This model is 

v 
 

 

 

adaptable across all future scenarios and generally performs well in a scenario with more 

opportunities but otherwise has limitations. Successful implementation of this model requires 

that the matchmaker understands the government’s needs, which might be best accomplished

through a close partnership with a government program office (such as in Anchor Tenant). 

The Institute Network is a multi-user network that advances mutually beneficial areas of 

interest to enable commercial scaling and advance U.S. interests. Due to the reliance of the 

network on existing capabilities, users, and market potential, this model performs well only in 

a dynamic growth scenario, where these factors are demonstrated. This model’s weakness can

be mitigated through efforts to grow and diversify the LEO economy in preparation for future 

gains. 

All models are illustrative and can be adjusted further to meet leadership priorities. 

The models presented in this study are illustrative examples of continuing government-funded 

activities post-ISS and represent a potential trade space. Further, each of the six models 

requires change to current legislation. NASA leadership can adjust models as desired to align 

closer to their priorities, using combinations of the unique model mechanisms provided in our 

analysis. The best performing model that meets leadership priorities is likely a combination of 

features from multiple models. 

Question 2: Near-Term Impact 

To identify opportunities for modifying the current ISSNL-CASIS partnership in the near term, 

we leverage strengths from the ISSNL model and from the top-performing models to improve 

NASA’s posture for success post-ISS. We identify four possible modifications to the ISSNL-CASIS 

partnership and NASA’s management of these activities. NASA should engage Congress early to 

propose legislative changes necessary to pursue these modifications. 

Create a pathway for ISSNL-CASIS to access commercial platforms as they come online 

prior to the ISS transition and determine NASA’s role in brokering relationships.

Prior to the ISS transition, commercial platforms may include private modules attached to the 

ISS, or private transport vehicles traveling to and from the ISS, private orbital capsules, and 

spacecraft with no platform destination. Extending ISSNL activities to these additional volumes 

may provide more flexibility, diversification of research, and amount of research conducted, for 

instance, by enabling research throughout a mission rather than just on the ISS. This may entail 

exploring the contractual and legal feasibility of creating a pathway, the ability for NASA to 

purchase space on behalf of CASIS, and NASA’s role in brokering relationships. 

vi 
 

 

 

 

 

 

Elevate the ISSNL incubation role to support increased movement towards industrialization. 

Focus on creating scalable and repeatable operations to support industrialization—on the path 

to commercialization—and sale of a product or service. An expanded incubation role, for 

example, might connect stakeholders and provide mentorship to address shared technological 

barriers related to in-space manufacturing. The incubator, possibly in partnership with NASA, 

might also explore ways to improve downmass capabilities. Building on this role may 

encourage market growth, improve processes and user experience, and mitigate risks to return 

on investment to platform providers. 

Establish a terrestrial innovation campus for microgravity research and development. 

A terrestrial campus provides a dedicated location for NASA to bring together LEO ecosystem 

stakeholders. This modification would allow NASA to prime the Innovation Campus model 

before the retirement of the ISS. Establishing a terrestrial campus now provides the additional 

opportunity for NASA to investigate the feasibility of using a Federally Funded Research and 

Development Center (FFRDC) or University Affiliated Research Center relationship in any of 

the models. For example, NASA may examine whether an FFRDC on a leased orbital commercial 

platform is possible and whether an FFRDC can have more than one government sponsor. 

Formulate a strategy for buying data from commercial providers. 

Buying data from commercial providers may provide an agile, alternative approach to meet 

research and development needs by augmenting or complementing NASA or other government 

agency (OGA) datasets. NASA can prepare now by investigating legal and regulatory concerns, 

such as navigating intellectual property and privacy protection and examining the ethics of 

selling human data. NASA can leverage lessons learned from the Science Mission Directorate’s

Commercial Smallsat Data Acquisition Program, such as establishing a pilot program to identify 

vendors and evaluate data and standardizing end-user license agreements across the 

government to facilitate collaboration. 

Conclusion 

The purpose of this study was to 1) identify potential models to continue government-funded 

activities in the post-ISS LEO ecosystem, and 2) determine near-term modifications to the 

ISSNL-CASIS partnership, given these models, to improve NASA’s posture for success post-ISS. 

Working with experts across NASA and in discussion with stakeholders internal and external to 

NASA, we identified a wide trade space of unique models, evaluated their performance 

according to stakeholder-driven criteria, and presented six models for consideration. We then 

looked to strengths of the top-performing models to suggest four near-term modifications to 

apply to the current ISSNL-CASIS partnership, which if implemented, would help enable the 

transition to one or more commercial LEO platforms. 

vii 
 

 

 

Table of Contents 

Executive Summary............................................................................................................ ii 

Purpose of the Study........................................................................................................................................ii 

Key Findings ......................................................................................................................................................iii 

Question 1: Potential Models ........................................................................................................................................................iii 

Question 2: Near-Term Impact..................................................................................................................................................... vi 

Conclusion .........................................................................................................................................................vii 

Table of Contents ............................................................................................................ viii 

Introduction....................................................................................................................... 12 

Background...................................................................................................................................................... 12 

Objectives ......................................................................................................................................................... 13 

Key Terms......................................................................................................................................................... 14 

Methods............................................................................................................................. 16 

Model Development...................................................................................................................................... 17 

Stakeholder-Driven Analysis..................................................................................................................... 19 

Model Evaluation Criteria..............................................................................................................................................................20 

Scenario-Driven Analysis............................................................................................................................ 22 

Future Scenarios ................................................................................................................................................................................22 

Limits in Study Scope.................................................................................................................................... 24 

Launch and Transportation Costs..............................................................................................................................................24 

Crewed Versus Uncrewed Activities.........................................................................................................................................25 

International Partnerships............................................................................................................................................................25 

Levels of Fidelity for Models.........................................................................................................................................................25 

Results .............................................................................................................................. 27 

Six Models + ISSNL Model............................................................................................................................ 27 

ISS National Laboratory Model ...................................................................................................................................................28 

Model 1: Anchor Tenant .................................................................................................................................................................33 

Model 2: Government Research Broker ..................................................................................................................................38 

Model 3: Innovation Campus........................................................................................................................................................44 

viii 
 

 

 

 

 

 

Model 4: Matchmaker......................................................................................................................................................................49 

Model 5: Institute Network ...........................................................................................................................................................54 

Model 6: Fee for Service .................................................................................................................................................................59 

Model Comparison ........................................................................................................................................ 64 

Mixing and Matching Models........................................................................................................................................................65 

Considerations to Guide Model Selection ...................................................................... 68 

Cost Considerations ...................................................................................................................................... 68 

Legislative Considerations ......................................................................................................................... 69 

ISSNL Management...........................................................................................................................................................................69 

Creation of an ISSNL Advisory Committee.............................................................................................................................71 

Preparing for the ISS Transition...................................................................................... 72 

1. Create a pathway for ISSNL-CASIS to access commercial platforms as they come online 

prior to the ISS transition and determine NASA’s role in brokering these relationships... 72 

2. Elevate the ISSNL incubation role to support increased movement towards 

industrialization. ........................................................................................................................................... 72 

3. Establish a terrestrial innovation campus for microgravity research and development. 

.............................................................................................................................................................................. 73 

4. Formulate a strategy for buying data from commercial providers. ....................................... 74 

Additional Insights ........................................................................................................... 75 

Consider the transportation ecosystem ................................................................................................ 75 

Provide clear goals ........................................................................................................................................ 75 

Consider the name......................................................................................................................................... 75 

Consider level of government oversight as the LEO ecosystem grows....................................... 75 

Consider how platforms may evolve to support fewer, specialized activities ........................ 76 

Consider conducting follow-on studies ................................................................................................. 76 

Summary ........................................................................................................................... 77 

Appendix A: Insights from Stakeholders........................................................................ 78 

Insights from NASA Stakeholders ............................................................................................................ 79 

Insights from OGA Stakeholders .............................................................................................................. 85 

Insights from Commercial Stakeholders............................................................................................... 91 

Insights from Academic and Nonprofit Stakeholders....................................................................... 99 

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Appendix B: Scenario Narratives .................................................................................. 106 

Dynamic Growth Scenario ........................................................................................................................107 

Key Characteristics ........................................................................................................................................................................107 

Overview ............................................................................................................................................................................................107 

Limitations.........................................................................................................................................................................................107 

Opportunities ...................................................................................................................................................................................107 

Outlook for User Communities.................................................................................................................................................108 

Steady Growth Scenario ............................................................................................................................109 

Key Characteristics ........................................................................................................................................................................109 

Overview ............................................................................................................................................................................................109 

Limitations.........................................................................................................................................................................................109 

Opportunities ...................................................................................................................................................................................109 

Outlook for User Communities.................................................................................................................................................110 

Limited Growth Scenario ..........................................................................................................................111 

Key Characteristics ........................................................................................................................................................................111 

Overview ............................................................................................................................................................................................111 

Limitations.........................................................................................................................................................................................111 

Opportunities ...................................................................................................................................................................................111 

Outlook for User Communities.................................................................................................................................................112 

Appendix C: Future LEO Activities ............................................................................... 113 

Appendix D: Full Evaluation Criteria and Scores......................................................... 117 

Full Score for ISSNL .....................................................................................................................................117 

Dynamic Growth .............................................................................................................................................................................117 

Steady Growth..................................................................................................................................................................................118 

Limited Growth ...............................................................................................................................................................................118 

Full Score for Anchor Tenant...................................................................................................................119 

Dynamic Growth .............................................................................................................................................................................119 

Steady Growth..................................................................................................................................................................................120 

Limited Growth ...............................................................................................................................................................................120 

Full Score for Government Research Broker.....................................................................................121 

Dynamic Growth .............................................................................................................................................................................121 

Steady Growth..................................................................................................................................................................................122 

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Limited Growth ...............................................................................................................................................................................123 

Full Score for Innovation Campus..........................................................................................................124 

Dynamic Growth .............................................................................................................................................................................124 

Steady Growth..................................................................................................................................................................................124 

Limited Growth ...............................................................................................................................................................................125 

Full Score for Matchmaker .......................................................................................................................126 

Dynamic Growth .............................................................................................................................................................................126 

Steady Growth..................................................................................................................................................................................127 

Limited Growth ...............................................................................................................................................................................127 

Full Score for Institute Network .............................................................................................................128 

Dynamic Growth .............................................................................................................................................................................128 

Steady Growth..................................................................................................................................................................................129 

Limited Growth ...............................................................................................................................................................................130 

Full Score for Fee for Service ...................................................................................................................131 

Dynamic Growth .............................................................................................................................................................................131 

Steady Growth..................................................................................................................................................................................132 

Limited Growth ...............................................................................................................................................................................132 

Appendix E: Legislative Changes to Enable Models ................................................... 134 

Congressional Requirements for NASA’s Role in U.S. LEO Activities.........................................134 

Current Requirements by Theme............................................................................................................................................135 

Anticipated Future Requirements ..........................................................................................................................................138 

Impact of Authorization Acts on this Study........................................................................................139 

Conclusion ......................................................................................................................................................141 

Appendix F: Acronyms .................................................................................................. 142 

Appendix G: Stakeholder Discussants ......................................................................... 144 

NASA .................................................................................................................................................................144 

OGA ...................................................................................................................................................................144 

Commercial....................................................................................................................................................145 

Academic and Nonprofit Community ...................................................................................................146 

Appendix H: Acknowledgements .................................................................................. 148 

Appendix I: Endnotes..................................................................................................... 149 

xi 
 

Introduction 

This report describes for National Aeronautics and Space Administration (NASA) senior-level 

consideration six potential models for facilitating government-funded activities in the postInternational Space Station (ISS) low-Earth orbit (LEO) ecosystem. The current model for 

facilitating government-funded activities in LEO is included for comparison and analysis. To 

help guide decision-making, we score each model by its anticipated performance across three 

potential future scenarios—dynamic growth, steady growth, and limited growth—and across 

five model evaluation criteria derived from values echoed by the diverse stakeholder 

community: ability to meet NASA’s needs, adaptability, opportunity for collaboration, market

sustainability, and equity and accessibility. 

After an introduction to the study background and objectives, limits in scope, and key terms, 

we describe the study methods and then present the main results of the study: descriptions 

and scoring highlights of each of the models. We then provide an aggregated view comparing 

all the models by their performance across the evaluation criteria and future scenarios. We 

conclude the main report with considerations to guide model selection, potential near-term 

opportunities to prepare for facilitating government-funded activities in the post-ISS LEO 

ecosystem, and insights gleaned from the study that will be key for future decision-making. 

Finally, a set of appendices provides summaries from stakeholder discussions, full future 

scenario narratives, a description of potential future LEO activities, full results of the model 

assessments, details on legislative considerations, and the list of stakeholder discussants. 

Background 

For almost two decades, the model for facilitating government-funded activities in LEO has 

been through the cooperatively managed International Space Station National Laboratory 

(ISSNL). Congress established a National Laboratory on the U.S. segment of the ISS in 2005, and 

in 2010, Congress directed NASA to enter a cooperative agreement with a nonprofit to manage 

the ISSNL.1,2 The Center for the Advancement of Science in Space (CASIS) was created as a 

501(c)(3) nonprofit with the mission to foster scientific discovery and technological innovation 

in space, expand U.S. leadership in commercial space, and inspire the next generation.3 

However, over the years, the ISSNL-CASIS partnership model has faced challenges. In 2019, 

NASA commissioned an independent review team (IRT) to examine these challenges and 

propose recommendations to solve them, which the IRT released in 2020.4 Though NASA and 

CASIS have adopted all of the IRT’s recommendations, tensions remain between diverse user 

communities for limited resources. Some proposed solutions range from incremental (such as 

updating the cooperative agreement) to fundamentally changing the operation and 

management structure within NASA (for example, eliminating CASIS, creating a federally 

12 
 

 

funded research and development center [FFRDC] to manage the National Laboratory, or 

eliminating the concept of a National Laboratory). 

Ultimately, the primary mission of the ISSNL is not the same as it was in 2005. As the LEO user 

landscape evolved and NASA direction shifted in response, the ISSNL was functioning with an 

incongruent set of goals and priorities between peer-reviewed, decadal-driven science 

(including fundamental science, technology development, in-space manufacturing, and science, 

technology, engineering, and math [STEM]) and enabling commercial markets. Meanwhile, 

these growing commercial markets provide opportunities for new models for LEO activities 

after the retirement of the ISS in 2030.5,6,7 

Commercial platforms after the ISS may provide a venue for NASA-driven, exploration-enabling 

research and technology development, as well as Earth-focused academic and commercial 

pursuits. Namely, four NASA-sponsored Commercial LEO Destinations (CLDs) are currently in 

development, including free flying stations by Blue Origin, Nanoracks, and Northrop Grumman 

and an ISS-attached station by Axiom Space that plans to eventually detach.

8,9 Assuming that 

one or more commercial platforms replaces the ISS in the 2030s, NASA leadership is 

considering next steps to continue government-driven activities in LEO, both in the near term 

and in the post-2030 timeframe. This study will help NASA leadership with those 

considerations. 

Objectives 

This study responds to two overarching challenges: 1) NASA and other LEO stakeholder 

communities need a plan for conducting and performing LEO activities after the retirement of 

the ISS in 2030, and 2) the current model for facilitating government-funded LEO activities, 

through the ISSNL, is specified and constrained by legislation and will need to evolve as 

utilization transitions from the ISS to CLDs. Given the need to reassess the current model due to 

the changing LEO ecosystem, NASA has an opportunity to optimize how it prepares for the 

post-ISS future. NASA leadership requested this study to guide considerations of NASA’s next

steps for LEO activities through and beyond the ISS-CLD transition. 

Specifically, NASA senior leadership posed two questions: 

1. Potential Models: What are potential models for an ISS National Lab facilitating 

government-funded or subsidized activities on a commercial LEO platform after the 

transition of the ISS to one or more private platforms? 

2. Near-Term Impact: In light of these options, what modifications would be helpful to 

make in the current ISSNL-CASIS partnership and the NASA management processes as 

NASA plans for the transition of the ISS by 2030? 

In answering these questions, the study team acknowledges important limitations in study 

scope. For Question 1, the study team recognizes the importance of identifying potential LEO 

activities of interest before assessing how the models can enable and facilitate these activities. 

13 
 

 

 

While the study includes an initial characterization of potential LEO activities, further decisions 

are needed to guide the overarching goals and objectives of the future model and to provide a 

clear list of activities that will and will not receive government funding or subsidy in the future. 

This is further discussed at the end of this report. 

The team also acknowledges the limitation of referring to the future model as an “ISS National 

Laboratory.” The team chose to examine the trade space using the generic term “model” to 

allow for a more comprehensive and creative set of options. 

For Question 2, many previous reports, including the IRT and reviews from the Inspector 

General and Government Accountability Office (GAO), have detailed specific findings and 

recommendations for the ISSNL-CASIS management model.

4,10,11,12 Rather than repeating the 

results of these previous works, this study aims to answer Question 2 by identifying promising 

characteristics of potential future models and then applying these characteristics to strengthen 

the current ISSNL model in preparation for the transition of the ISS to CLDs. 

We discuss additional limits in study scope in Methods. 

Key Terms 

We define the following key terms to clarify how we use them in this report, while 

acknowledging that these terms can carry different meanings in other contexts. 

• Model: Collection of mechanisms and related organizational process and infrastructure 

that acts as a government touchpoint in the LEO ecosystem (the approach to connect users 

with providers). 

• Evaluation Criteria: Representation of stakeholder-identified needs, which we used to 

score and compare model performance to guide decision-making. 

• Future Scenarios: Representation of possible futures for the post-ISS LEO ecosystem used 

to frame the analysis and enable NASA leadership to compare models, their characteristics, 

and how they might differ with varying market dynamics. 

• LEO Activities: Any action pursued by a user or provider in LEO, including for education, 

science and research, technology development and demonstration, human and robotic 

operations, and market stimulation. 

• Platform: A facility that remains in orbit, providing space and equipment to enable 

different activities. 

• Commercial LEO Destination (CLD): Commercially owned and operated LEO 

destinations supported by NASA’s Commercial LEO Development Program.

13 

• Spacecraft or Vehicle: A volume that launches, returns, or enables LEO activities. 

Spacecraft and vehicles are defined as transitory, unlike the platforms that remain in orbit. 

• User: An entity that seeks access to LEO for conducting a LEO activity, such as commercial, 

academic, or government users. 

14 
• Provider: An entity, usually commercial, that provides users with access to LEO platforms 

or spacecraft, which the provider owns and operates. 

• Stakeholder: An entity with any stake in LEO activities, including users, providers, thirdparty operators, policymakers, students and educators, and beneficiaries of LEO activities, 

including the U.S. public at large. 

15 
 

 

Methods 

To answer the two questions posed by leadership, we conducted an extensive literature review 

followed by a dual stakeholder-driven and scenario-driven analysis that relied heavily on an 

iterative process of gathering feedback from over 40 stakeholders. Stakeholders were selected 

to cover a diverse set of interests in LEO activities and provided iterative feedback from 

November 2021 to June 2022. We engaged with stakeholders through targeted conversations, 

discussions at national conferences, and during a dedicated meeting of experts hosted by the 

National Academies of Sciences, Engineering, and Medicine (NASEM). This approach allowed 

for a strong customer focus while also considering potential outcomes in a range of uncertain 

future possibilities. We assembled six distinct models, inspired by the literature and insight 

from stakeholders. Further, the stakeholder community helped inform five model evaluation 

criteria and three future scenarios to evaluate the models. 

Once we developed these key analytical elements, a small study team independently scored (as 

Pro, Neutral, or Con) five model evaluation criteria for each of the six models and the existing 

ISSNL model. The team considered the evaluation criteria across the three scenarios as 

illustrated in Figure 1. 

Figure 1. Study Approach 

Generally, we used “Pro” to demonstrate the ability for the model to meet (or exceed) the 

criteria. We used “Neutral” to demonstrate that the model generally meets the criteria but with 

some limitations. Neutral was also used in situations where there was a mixture of favorable 

and unfavorable considerations. We used “Con” to note that the model did not perform well 

given the context of the future scenario. Because these scores are subjective, we then 

aggregated scores and met as a team to walk through any areas of disagreement. The scores 

16 
 

 

 

were then presented to the larger study team, including members of OTPS, ISS Division, and 

ISSNL, for review and discussion. The final scores are provided in this report along with the 

justifications and considerations. 

The Pro, Neutral, and Con scores were further aggregated across the future scenarios into 

overall model strengths and weaknesses, based on a model’s ability to score favorably (Pro)

across more than one future scenario. A model strength indicates a model evaluation criterion 

for which a model received at least two Pros across the three future scenarios. A model 

weakness, or area of possible improvement, indicates a model evaluation criterion for which a 

model received fewer than two Pros across the three future scenarios. 

Model Development 

To develop potential models, we first identified sixteen examples from the literature review 

and stakeholder discussions.

14,15,16 For example, we considered the National Science 

Foundation (NSF) FFRDC, the Department of Energy (DoE) FFRDC National Lab, and DoD 

Manufacturing Innovation Institute models, cited in the IRT, and the National Park and airport 

models, listed in the 2017 report by The Tauri Group.4,17 Discussions with stakeholders also 

provided examples of models to include. To compare and consolidate the various examples, we 

identified four key characteristics to define a more cohesive and comprehensive set of models: 

• Infrastructure: platforms, equipment, or systems required 

• Stakeholder roles: users, providers, operators, NASA’s role, other stakeholders involved

• Process for accessing LEO: how users get access to LEO, authorities needed, supply and 

demand considerations 

• Agreements between users and providers: agreement types and lengths, level of NASA 

commitment 

In the consolidation process, we also determined that the model should not entail any 

government-owned infrastructure (in space) and should not compete with commercial 

providers. Additionally, models should include some level of visible NASA presence, benefiting 

from the positive NASA brand. Taking these considerations into account and iterating based on 

feedback from stakeholder discussions resulted in the final six models (see descriptions listed 

in Table 3 along with the current ISSNL model). The model descriptions in terms of the four key 

model characteristics are further detailed in the Results section, along with the scores across 

the five model evaluation criteria and three future scenarios. The six models are meant to be 

illustrative and provide a broad trade-space of possible options. Model characteristics were 

specified for the purpose of making evaluations, however, options could be further adjusted 

and even mixed and matched. 

17 
Table 3. ISSNL and Six Differentiated Models for Facilitating Government-Funded Activities in LEO 

Model Differentiator Description Management & 

Oversight 

ISSNL 

Reflection of 

current operations 

Third-party agreement to manage 50% of ISS 

U.S. segment activities for a broad range of 

academic, government, and commercial users. 

Nonprofit (CASIS) 

1. Anchor 

Tenant 

Long-term 

agreement for 

leasing space on a 

commercial 

platform 

NASA as anchor tenant on CLD with dedicated 

destination for LEO activities. NASA program 

office is agent for all government-sponsored 

activities. Commercial users work directly 

with platform provider or respond to 

government proposal requests. 

Government 

(NASA Program 

Office) 

2. Government 

Research 

Broker 

Customizable 

research using 

combinations of 

transport vehicles 

and CLDs 

NASA program office guided by advisory 

committee brokers payloads to LEO, conducts 

mission planning, and negotiates end-to-end 

services. Flexible contract with CLDs based on 

short-term needs. Crewed and uncrewed 

missions for flexible government research 

needs. 

Government 

(NASA Program 

Office) 

3. Innovation 

Campus 

Modern terrestrial 

campus with 

workforce focus 

Government-owned terrestrial campus 

operated by non-government entity. 

Dedicated to advancing research and 

development. Focused on innovation and 

building LEO workforce rather than 

connecting users to platforms. 

3rd party with 

NASA as sponsor 

4. Matchmaker 

Neutral third party 

connecting users 

to platforms 

Nonprofit funded by NASA to match specific 

users to LEO opportunities based on mission 

and technical requirements. Provides clear 

entry point for users and providers. 

Aggregates and communicates user demand 

to industry. 

Nonprofit with 

NASA as sponsor 

5. Institute 

Network 

Network of 

separate but 

related efforts to 

enable commercial 

scaling and U.S. 

leadership 

Government-sponsored consortia of distinct 

but related institutes within LEO and 

terrestrially. Institutes funded through publicprivate partnerships managed by nonprofits. 

CLD facilities leased from providers within 

institutes. 

Nonprofit with 

NASA and OGAs as 

sponsors 

6. Fee for 

Service 

Free market 

approach 

18 

Industry-driven model focused on 

transactions for services. Users purchase 

goods and services from providers. NASA is 

one user and leverages grants and data buys 

to meet needs. 

Industry; NASA 

management and 

oversight of 

grants and data 

buys 
Stakeholder-Driven Analysis 

Integrating perspectives from diverse stakeholders is imperative for the successful 

development of a future model to facilitate government-funded activities in LEO. We define a 

stakeholder as an entity with any stake in LEO activities, including users, providers, third-party 

operators, policymakers, students and educators, and beneficiaries of LEO activities, including 

the U.S. public at large. 

We refined the models, model evaluation criteria, and future scenarios from 43 discussions 

with different stakeholder groups: 13 NASA, 10 other government agencies (OGAs), 10 

commercial, and 10 academic and nonprofit. These targeted discussions at times included more 

than one stakeholder participant. The topics of conversation spanned multiple areas depending 

on the stakeholder but in general involved the future of the LEO ecosystem, NASA’s future role,

potential activities to be conducted, models or mechanisms to enable such activities, and areas 

for concern. At times, the study team engaged stakeholders in follow-up discussions as the 

study progressed or when clarification was needed. From these 43 discussions, we heard how 

different stakeholders valued LEO activities for outcomes like creating and sharing knowledge, 

demonstrating technology, serving as a springboard to the Moon and Mars, fostering economic 

growth, and maintaining and building relationships. Summaries from the stakeholder 

discussions are provided in Appendix A: Insights from Stakeholders. A list of stakeholder 

discussants is provided in Appendix G. 

The study team also actively engaged the diverse LEO stakeholder community at multiple 

conferences, including the 2021 American Society for Gravitation and Space Research (ASGSR) 

meeting, the 2022 ASCENDx Texas summit, and the 2022 ISS R&D Conference. We also gained 

international perspectives, as members of the study team listened to the reflections of the ISS 

International Partner Working Group at approximately monthly virtual and in-person 

meetings. Additional insights came from reviewing literature following these 

engagements. 

18,19,20

Finally, the study included a NASEM Meeting of Experts on May 16, 2022, in which 11 experts 

with academic, policy, commercial, and international affiliations provided feedback on the 

primary study elements, including the models, model evaluation criteria, and future scenarios. 

Specifically, we posed two questions to the experts: 

1. Models: What mechanisms, models, or combinations have you seen work well in 

supporting national objectives (research, exploration, economic growth, international 

cooperation)? 

2. Model Evaluation Criteria: Do the model evaluation criteria appropriately characterize 

aspects that you find important? Are there additional criteria we should consider? What 

criteria is most relevant to your organization post-2030? 

19 
After briefly presenting our preliminary results, we asked each meeting participant to consider 

the two questions and provide five-minute responses for each question, with an additional 

three minutes of discussion among the participants. This resulted in a more refined analysis 

with clearer understandings of model strengths and weaknesses and other stakeholder 

considerations. 

Model Evaluation Criteria 

While we used stakeholder inputs to inform the development of the final six models and three 

future scenarios, their inputs were also directly applicable to the development and refinement 

of the five model evaluation criteria, listed in Table 4. These criteria are meant to represent the 

pertinent needs of the various communities and serve as a means to evaluate the effectiveness 

of models across future scenarios. As mentioned in the Introduction, the current model for 

facilitating activities in LEO is challenged by the incongruent set of goals and priorities of the 

diverse stakeholder community. A decision maker may view the following criteria as a set of 

priorities from various stakeholders and may look to assign values to each of the criteria to 

assist in decision-making. For example, we suggest that an academic researcher might highly 

value the equity and accessibility of a model over other criteria. If decision makers wish to 

optimize a model for the academic research community, they may value a model that performs 

well in terms of equity and accessibility. When comparing the different models, decision 

makers may consider not only overall scores, but also which models have the potential to 

benefit which stakeholder groups as needed. 

20 
Table 4. Five Model Evaluation Criteria 

Ability to Meet NASA’s Needs: Provides for and prioritizes NASA’s needs, including crew 

accommodation and training, human research, physical and biological research, technology 

demonstration, and science. 

Sub-Criteria and Clarifying Questions: 

Does the model help NASA meet its mission needs in LEO? 

Interested Stakeholder(s): 

NASA 

Adaptability: Involves priorities, processes, and parties that are easily adaptable to available 

infrastructure, offerings by the service providers, and user demands. 

Sub-Criteria and Clarifying Questions: 

Is the model restricted to an individual platform? 

Does the model provide flexibility? 

Does the model account for scalability? 

Does the model enable diverse activities? 

Does the model enable simultaneous activities? 

Interested Stakeholder(s): 

All users 

All providers 

Opportunity for Collaboration: Allows and encourages interagency, international, and 

commercial partnerships through open communication, clear cost -sharing mechanisms, or other 

means. 

Sub-Criteria and Clarifying Questions: 

Does the model facilitate coordination among NASA, OGAs, 

and international partners? 

Does the model align with non-NASA user groups? 

Interested Stakeholder(s): 

NASA 

OGAs 

International 

Market Sustainability: Stimulates supply and demand by providing for the industrialization and 

commercialization of products and services, by buying down risk for commercial entities, and by 

ensuring a positive user experience. 

Sub-Criteria and Clarifying Questions: 

Does the model help encourage market growth? 

Does the model result in a streamlined process and good user 

experience? 

Does the model mitigate risks to return on investment for 

platform providers? 

Interested Stakeholder(s): 

CLD providers 

U.S. industry 

U.S. investors 

Equity & Accessibility: Enables and empowers underrepresented groups and nonprofit -seeking 

ventures, such as fundamental research and education and outreach activities. 

Sub-Criteria and Clarifying Questions: 

Can user communities provide input into the activity selection 

process? 

Does the model provide an easy-to-identify point of access? 

Does the model include a low-cost pathway for research? 

Does the model proactively seek input and participation from 

diverse stakeholder groups? 

Interested Stakeholder(s): 

U.S. academic institutions 

U.S. students and educators 

U.S. nonprofits 

U.S. society 

New entrants 

 

21 
 

Scenario-Driven Analysis 

We used the scenario-driven analysis to consider model performance within a range of 

uncertain future possibilities. This approach enables NASA leadership to compare different 

models for the post-ISS LEO ecosystem by not only the models’ characteristics but also by how 

those characteristics respond to different future possibilities. The future scenarios are used as 

a tool to frame the analysis for the models rather than serving as a prediction of the future LEO 

ecosystem. To develop this tool, we incorporated stakeholder insight and considered 

assumptions about the future ecosystem, including launch and transportation costs (see Limits 

in Study Scope below). These assumptions have been corroborated through studies on this 

issue. 21 With this in mind, we defined three future scenarios—limited growth, steady growth, 

and dynamic growth—that provide a broad range for considering the strengths and 

weaknesses of each model. 

Future Scenarios 

To characterize future scenarios, we used stakeholder input to answer four questions: 

1. How might NASA’s priorities change in different futures?

2. Which activities will be available? 

3. How will NASA and other stakeholders prioritize the activities available? 

4. What platforms and other resources will be available? 

Answering these questions, we characterized three future scenarios, defined by the number of 

commercial offerings and by the amount and diversity of user activities in the LEO ecosystem: 

• In dynamic growth, successful commercial markets spur innovation and capital 

investment, providing numerous and more diverse activities. 

• In steady growth, one or more small commercial platforms are the center of LEO 

activity, but that activity is not diversified. 

• In limited growth, low demand or market disruption leads to a lack of mature 

commercial platforms and few activities. 

Overviews of the three future scenarios are provided below. The full scenario narratives are in 

Appendix B: Scenario Narratives. 

To inform the future scenarios, we identified and characterized potential future LEO activities, 

including education, science and research, technology development and demonstration, 

operations, and market stimulation. To various extents, these activities are in or out of scope 

for NASA as specified in the Quantifying Demand White Paper.22 Generally, activities in 

education, science and research, and technology development and demonstration, and 

operations are considered to be in scope for a future government-funded LEO model for all 

future scenarios. However, NASA’s demand of these activities and ability to purchase them 

from commercial providers may vary based on available market supply across the future 

22 
 

 

 

 

scenarios. Activities in market stimulation, such as private astronaut activities and commercial 

incubation and media, are considered to be in or out of scope depending on the future scenario. 

Further characterization of the anticipated future LEO activities is provided in Appendix C: 

Future LEO Activities. 

We developed the future scenarios based on feedback from stakeholders and an objective to 

explore the most plausible range of future scenarios. This did exclude edge cases that are 

unlikely, but possible. For example, the limited growth scenario does not assume that most 

efforts fail resulting in a lack of LEO activities. 

When developing the future scenarios, we had the following key factors in mind: number of 

available platforms; availability and diversity of activities; contributing factors to market 

dynamics; and impacts to user communities. We heard other factors in stakeholder discussion 

that might be important to readers but are outside the analysis. For example, geopolitical 

dynamics and how they might change in the 2030 timeframe are not directly incorporated into 

this analysis but may be useful insight for the decision-making process in combination with this 

analysis. We also heard that as market dynamics shift over time, the government may wish to 

consider how models may evolve to support changing needs. 

Scenario 1: Dynamic Growth 

Two or more CLDs in operation. NASA’s investments in the CLD Space Act Agreement have 

ignited new LEO markets and investments. Early successes resulted in increased venture 

capital investment and accelerated interest in using and visiting LEO. Multiple, diversified 

services and activities span multiple providers. Possibly one single exquisite facility supports 

the activities, but more likely, several CLDs and reusable vehicles compete for user demand, 

which has expanded in both number of users and variety of demand. In addition to science, 

human exploration research, and technology demonstration, space tourism has grown 

significantly, and on-orbit manufacturing is an established market. Lower launch costs and 

greater accessibility enable new business models with new and improved offerings available 

every few years. These new business models increase flexibility and enable providers to tailor 

LEO platform services to specific users. 

Scenario 2: Steady Growth 

One or several small CLDs in operation. With moderate development of the LEO ecosystem, 

both users and providers continue to increase, though at a slow pace. Whether one platform or 

multiple small platforms are available, the range of services and activities is not diversified. 

NASA has sufficient access to LEO infrastructure to meet its primary needs. Other user 

communities are somewhat more limited, since commercial services remain generalized. 

Companies lack sufficient development and private investment to offer specialization. Despite 

these limitations, LEO continues to be a symbol of collaboration and an international 

environment. 

23 
 

 

 

Scenario 3: Limited Growth 

One CLD in operation, though with limited capacity. Despite NASA’s efforts to develop the 

U.S. LEO commercial market, commercial providers have not been able to survive the costs of 

entry, and expected markets failed to materialize. Investors have pulled out, leaving providers 

unable to buy down risks and mature technologies. One CLD is operational and can host 

research but in a much more limited capacity than on the ISS. Therefore, after the retirement of 

the ISS, the United States has limited access to a LEO platform. Users, including NASA, fly only 

their highest priority needs. Other users seek means of continuing activities in microgravity 

without using a LEO platform. Geopolitical dynamics are also shifting. Other nations likely have 

operational stations and are interested in new partnerships. As the United States shifts 

attention to the Moon and Mars, it cedes some geopolitical benefit of LEO to others. 

Limits in Study Scope 

In both stakeholder discussions and at the NASEM Meeting of Experts, at least three topics rose 

repeatedly as important considerations but ultimately fell outside the scope of this study. 

Launch and Transportation Costs 

This study was a scenario-driven analysis that built assumptions into each future scenario for 

the purpose of evaluating model performance within different contexts. As part of this 

approach, we considered launch costs an enabling factor for each future scenario. For example, 

we assumed launch costs were reduced when compared to today to enable the robust market 

dynamics in the dynamic growth scenario. If the reader does not agree with this assumption, 

we encourage the reader to consider model performance under the steady growth scenario, 

where transportation costs are not assumed to deviate much from today. For the limited 

growth scenario, launch costs are likely not the primary limitation, as in-space opportunities 

will be more limited than launch vehicles, which continue to benefit from the satellite launch 

market. 

We heard from many stakeholders, including those at the NASEM Meeting of Experts, that if 

transportation costs don’t reduce significantly, markets will not be able to materialize. Several 

stakeholders noted transportation was a major issue for consideration when identifying and 

selecting a model for the post-ISS ecosystem. 

While we make assumptions on the cost of transportation in the 2030 timeframe, 

transportation itself was not a major focus of this study. Future potential models should 

consider transportation mechanisms as a major component, which will require further 

analysis. Overall, the effects of cost should not be underestimated. The likelihood of a future 

scenario could completely change based on launch and transportation costs. 

24 
 

Crewed Versus Uncrewed Activities 

The scenario narratives do not differentiate between crewed and uncrewed platforms. Several 

stakeholders mentioned that future activities can be conducted on uncrewed platforms and 

recommended that future models take this into account in follow-on analyses. Additionally, 

certain activities in LEO (such as remote sensing and manufacturing) may be better suited to 

autonomous, robotic uncrewed operations. 

International Partnerships 

The scenario and model narratives do include sections on their impacts to international 

stakeholders’ involvement, but the complexities of these relationships and future implications 

cannot be addressed in this study alone. Several stakeholders noted the importance of 

determining NASA’s position towards international partnerships in a post-ISS ecosystem. 

Doing so requires additional analysis and thoughtful legal consideration, both for current ISS 

partners and for governments and agencies not in the current ISS partnership, such as 

emerging space agencies and Artemis Accords signatories. A separate working group led by 

NASA’s Space Operations Mission Directorate has been established to begin discussions with 

the current ISS partners regarding the future LEO ecosystem. 

In the context of our limited growth scenario, with just one operational CLD, we may assume 

that both U.S. and international users might use international providers for their LEO access 

needs. This could create a situation in which U.S. users, including NASA users, are more reliant 

on international partnerships, analogous to when after the retirement of the Shuttle program 

and prior to the Commercial Crew program, the U.S. relied on crew transportation to and from 

the ISS via the Russian Soyuz spacecraft. 

Recent events in international policy, especially the U.S.-Russia integrated crew agreement that 

was reached in June 2022, will be important to consider in the post-ISS LEO ecosystem. The 

agreement specifies that U.S. astronauts and Russian cosmonauts can ride as integrated crews 

to and from the ISS on both U.S. crew spacecraft and the Russian Soyuz with a no-exchange-offunds basis.

23 While not fully explored in this work, international partnerships and agreements, 

such as this example, are likely to impact a model’s potential performance in the possible 

future scenarios, and their implications should be more intentionally assessed. 

Levels of Fidelity for Models 

We relied on literature reviews and stakeholder discussions to develop the models. Those we 

developed are largely notional and conceptual, representing a wide trade space of potential 

options. If decision makers select one or more models to iterate on, we suggest doing future 

work to address the other limits in study scope identified in this section, conducting follow-on 

analyses outlined at the end of this report, and giving more consideration to cost and legislative 

25 
changes needed to specify the exact operations, management, and business details of each of 

the models we present. 

26 
Results 

This section describes the six assembled models and the existing ISSNL model; highlights their 

scores; and provides an aggregate view of the model scores and considerations for senior 

leadership based on this aggregate view. 

Six Models + ISSNL Model 

Each model description includes the following information to guide senior leadership 

decisions: 

1. An overview description of the model in practice, as envisioned in the post-ISS LEO 

ecosystem, including a “National Laboratory” characterization. 

2. Assumptions about the physical infrastructure providing user access to LEO, including 

LEO platforms, facilities and equipment on platforms, spacecraft functioning as research 

vessels, and terrestrial facilities. 

3. Assumptions about the roles of different stakeholders in this model, as users, providers, 

third-party operators or managers, or members of advisory committees or consortia. 

4. Assumptions about the process in which providers provide access to LEO, users seek and 

acquire access, and other parties facilitate user-provider coordination, user-user 

partnership, or determination of supply and demand needs for LEO access. A flow 

diagram illustrates this process, which is defined by three major steps for connecting 

users (demand) with providers (supply): 

Step 1: “getting in the door” shows the path for users to follow if they wish to conduct an 

activity in LEO through the model, such as proposing to the identified stakeholder for 

activity selection. Users may engage with identified stakeholders regarding activity 

selection or to influence activity selection priorities. 

Step 2: “once in the door” refers to the stakeholder who allocates resources for the 

selected activities, such as integration, crew time, and mass to orbit, and facilitates the 

process for users to prepare flight-ready payloads. 

Step 3: “getting out the door” notes who then decides which flight-ready payloads will be 

manifested on a flight to the platform. 

5. Assumptions about the types of agreements that users, providers, and other parties 

might use to receive, provide, or otherwise facilitate access to LEO. 

6. A summary list of the anticipated impacts of this model on four non-NASA user 

communities: academic, international, OGA, and commercial. 

7. Highlights of the model’s scores, including a summary table of Pros, Neutrals, and Cons 

per future scenario, key takeaways, and lists of the model’s main strengths and 

weaknesses in meeting the five evaluation criteria across multiple future scenarios. 

27 
ISS National Laboratory Model 

The ISS National Laboratory (ISSNL) is a NASA-funded 

nonprofit National Laboratory established through the 

2005 NASA Authorization Act. It is responsible for 

managing all non-NASA research. Investigations must 

utilize space for Earth benefits. These areas include 

but are not limited to physical sciences, life sciences, 

remote sensing, technology development, and education. 

Key Discriminators 

• The ISSNL is an honest broker 

for flying non-NASA science and 

provides significant support to 

the user community. 

Infrastructure 

By law, NASA is required to allocate 50% of the U.S. allocation of ISS utilization resources 

(upmass, downmass, crew time, etc.) for sole use of the ISSNL. 

Stakeholder Roles 

NASA maintains final responsibility for what is flown and operated. The ISS Program and CASIS 

integrate all hardware and investigations to fly and operate. 

CASIS manages all investigations conducted under the ISSNL allocation. It is responsible for 

selection of these investigations through a peer review process designed to fly the highest 

rated proposals. CASIS creates and enables many partnerships between users, Implementation 

Partners (IPs), and Commercial Service Providers (CSPs). They provide some funding for 

investigations and integration costs but also encourage projects to be self-funded (CASIS 

provides on average 10% of project costs). 

IPs support and facilitate investigations to be flown through the ISSNL. They may be selected 

by the users, but that is not required to successfully conduct science in space. 

CSPs have flown and operated facilities on the platform and may sell services that their 

facilities provide to users they have brought to the ISSNL through their own business 

development. This can range from facilities in a rack to a commercially available airlock. 

Users include anyone submitting investigations to be flown through the ISSNL. They include 

but are not limited to government agencies (other than NASA), academic institutions, and 

companies. 

Process for Accessing LEO 

Figure 2 illustrates the process this model takes for connecting user activities with platforms. 

28 
 

 

Figure 2. Process for Accessing LEO through the ISSNL Model 

Step 1: There are many opportunities to apply and conduct research in space through the 

ISSNL that include but are not limited to: National Laboratory Research Announcements, 

public-private partnership challenges, solicitations, and CSPs who may request resources for 

their customers. Through a formal peer review process, the ISSNL and external reviewers read 

and rate all proposals. Only the best investigations are flown, and the ones that are not flown 

are given feedback to make their proposal better. Investigations can also be flown through 

CSPs, which are still evaluated by the ISSNL but in a less rigorous selection process, since other 

companies own their facilities. 

Step 2: Once selected, ISSNL works with the user and any IP or CSP involved to prepare 

experiments for flight and translate ground-based experiments into flight-ready payloads. The 

ISSNL allocates resources such as integration, crew time, and mass to orbit. 

Step 3: The ISSNL works with a NASA Program Office, the ISS Utilization Office, to provide 

payload manifestation priorities and to provide input to payload integration. The ISS Utilization 

Office integrates ISSNL selected payloads and NASA selected non-ISSNL payloads into missions 

on the ISS. 

Agreements Between Users and Providers 

CASIS manages the ISSNL through a cooperative agreement with NASA and with NASA funds. 

NASA provides ISS resources and transportation free of charge to ISSNL users. Users (including 

IPs and CSPs) operate under user agreements or a grant agreement. 

29 
 

 

 

Impacts to User Communities 

This model is designed to benefit the user community and none of NASA’s exploration goals, as 

designated by law. For the purpose of this analysis, we assume that the ISSNL model always 

maintains 50% of NASA’s ISS utilization allocation, but future resources depend on how much 

access NASA has on a future platform. 

• Academic users may fly science through the ISSNL through the processes described above 

or partner with NASA if the investigation meets the agency’s exploration and research 

goals. 

• International users may fly through the ISSNL only if flying through a U.S. company, like 

with a CSP, or they may fly with any other international partner using the platform. 

• OGA users primarily fly science through the ISSNL through the processes described above 

but may also partner with NASA using NASA sponsorship if the investigation meets the 

agency’s exploration and research goals.

• Commercial users fly through the ISSNL unless they are working through a NASA 

solicitation that meets the agency’s exploration and research goals or have a commercial 

product that is not eligible for the ISSNL but can be flown through NASA Interim Directive 

8600.121 on Use of ISS for Commercial and Marketing Activities and be willing to pay for 

all government services used (upmass, downmass, crew time, etc.).

24 

Scoring Highlights 

When scoring the ISSNL model, we considered the current underlying model “as is,” including

existing legislation and use of one platform. Therefore, we recommend against directly 

comparing the ISSNL scores to the scores of the other six models. The scoring may provide 

insight into potential improvements to the existing model. 

The current ISSNL model cannot be evaluated in reference to meeting NASA’s needs given the 

split detailed in legislation, specifying the ISSNL focus on non-exploration (non-NASA) 

activities. However, we do assess the ISSNL model across the other evaluation criteria in the 

future scenarios, as it may be possible to extend all the current processes, parties involved, and 

agreement types characterizing the current ISSNL model to a leased portion of a CLD. 

Table 5 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

30 
 

 

Table 5. ISSNL Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

Ability to Meet NASA’s Needs N/A N/A N/A 

Adaptability Con Con Neutral 

Collaboration Neutral Neutral Neutral 

✓ Market Sustainability Neutral Pro Pro 

✓ Equity & Accessibility Pro Pro Pro 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The ISSNL model provides equity and accessibility across all future scenarios as an honest 

broker to diverse users by engaging the private sector through research and cost-sharing 

arrangements while leveraging a network of IPs and CSPs, incubator partnerships, publicprivate sponsorships, and sponsored research. This model encourages market growth by 

covering costs for payload integration and by helping users in the form of grants and subsidies. 

The legislative authority implemented in the cooperative agreement limits NASA’s flexibility in

adjusting the relationship over time. The cooperative agreement also prevents CASIS from 

engaging in any non-ISSNL activities, constraining CASIS’s business model. The cooperative 

agreement hinders the model’s adaptability to offerings by providers and demands of users. 

Collaboration is a weakness because NASA, OGAs, and international users cannot easily 

collaborate among each other through ISSNL. This is because the 50% allocation is for nonNASA activities and international partners can fly only if going through a U.S. company. 

Overall Strengths Across the Future Scenarios 

The ISSNL model scores positively across multiple future scenarios, demonstrating 

robustness, in terms of: 

✓ Market Sustainability: Encourages market growth by covering costs for payload 

integration and by helping users in the form of grants and subsidies. Concerns 

regarding limited visibility into planned resource allocations and changes to these 

allocations, as reported by the GAO, are actively being addressed and have improved 

with the continued input of the User Advisory Committee.

12 Accommodating further 

31 
 

 

incubation and acceleration of technologies and startups is important but depends on 

updates to legislation. 

✓ Equity and Accessibility: Enables outreach to new, diverse users through 

partnerships, challenges, and solicitations. Managed by a third-party nonprofit 

organization in a cooperative agreement with NASA, the ISSNL also acts as an honest 

broker and provides significant support to users, including matching with IPs, grant 

funding, introductions to an investor community, and customer service from proposal 

through flight and post-flight. Users are primarily responsible for bringing their 

research, but all other resources—launch, crew time, integration, etc.—are provided by 

NASA and ISSNL funding. 

Overall Weaknesses Across the Future Scenarios 

The ISSNL model does not score positively across multiple future scenarios, demonstrating a 

lack of robustness, in terms of: 

• Adaptability: Hinders exchange of funds, constrained by the cooperative agreement in 

place and legislation in terms of exclusivity of operations, infrastructure, and allocation of 

platform resources. This reduces ability to leverage new opportunities and LEO activities. 

• Opportunity for Collaboration: Enables civil government agency collaborations (such as 

NIH and NSF) but complicates options for DoD and international collaborations, due to 

intellectual property concerns and other competitive concerns. 

32 
Model 1: Anchor Tenant 

NASA is an “anchor tenant” for one commercially

available LEO platform. As an anchor customer, NASA 

provides a reliable source of revenue for a specified 

amount of time. NASA and other user communities 

have some degree of autonomy over activities 

conducted in dedicated areas or even individual 

segments of the platform. An estimated 30% to 90% of 

total activities on the platform are governmentsponsored. The dedicated areas and individual 

segments or portions of these areas are designated a 

National Laboratory. 

Key Discriminators 

• NASA has a long-term, 

contracted relationship with the 

platform provider. 

• NASA has direct input into 

platform requirements and a 

dedicated destination for 

conducting LEO activities. 

Infrastructure 

One platform is privately owned, with NASA as its main, and potentially only, long-term 

customer. As such, NASA might own specialized equipment or other facilities on the platform. 

However, NASA does not own competing platforms or have an ownership stake in the platform. 

NASA has dedicated space and time on the platform. Other users might have dedicated space 

and time on the platform as well. A dedicated space can be an area within a segment of the 

platform or an entire segment itself. 

Stakeholder Roles 

The CLD provider owns and operates the platform and leases space to the anchor tenant. The 

CLD provider has final authority over activities performed on the platform, including the 

authority to veto activities to ensure safety or avoid interoperation issues. However, as the 

anchor tenant, NASA has operational autonomy over its dedicated area of the platform, as 

stipulated in its contract. NASA can also provide input to help the CLD provider decide which 

activities to allow on the platform. 

A dedicated NASA program office prioritizes, selects, and awards activities that use NASA’s area

of the platform. NASA acts as the agent and portal for all government-sponsored user activities. 

The program office can contract out some tasks for coordinating user community activities, but 

NASA maintains primary oversight of the activity selection process and execution. To offer 

their perspective on activity selection, user communities can provide input to the program 

office through a board of directors, user advisory committee, or decadal surveys. 

Process for Accessing LEO 

Figure 3 illustrates the process this model takes for connecting user activities with platforms. 

33 
 

 

Figure 3. Process for Accessing LEO through the Anchor Tenant Model 

Step1: The dedicated NASA program office provides a clearly identified point of entry for users 

seeking to use NASA’s area of the platform. In addition to submitting white papers proposing

activities for the platform, users can respond to open calls for proposals, which the NASA 

program office uses to communicate NASA’s priorities for activities. Through a formal review 

process, which includes input from a user advisory committee, the NASA program office selects 

activities among those proposed. 

Step 2: After selecting an activity, the NASA program office (or contracted delegate) helps users 

define requirements and facilitates the process of ensuring flight-ready activities. The program 

office also allocates integration, crew time, and mass to orbit. In addition, the program office 

aggregates the demand of international partners and coordinates their involvement, as 

stipulated in NASA’s overarching contract with the commercial platform provider (note that 

international partners may also seek other pathways with CLD providers). 

Step 3: The NASA program office then works with the commercial provider, who decides which 

activities to allow on the platform. 

Agreements Between Users and Providers 

The agreement between NASA and the CLD provider is a long-term contract with a high level of 

commitment between parties. The contract details jointly identified requirements for NASA’s

area of the platform and lists potential activities. Although the contract might include options 

for built-in flexibility over the long period, and few options for scalability, these options will be 

for only preconceived activities and circumstances outlined in the contract. The contract 

authorizes NASA to perform safety certification/human rating. 

34 
 

 

 

For individual activities, the NASA program office can coordinate memoranda of understanding 

(MOUs), grants, barter agreements, government contracts, and other agreements with or 

between different stakeholders. 

Impacts to User Communities 

Although mostly NASA-focused, with activities frequently aligning with academic user needs, 

this model also provides support to international, OGA, and commercial users when excess 

capacity allows. 

• Academic users can submit grant proposals through the NASA program office’s formal 

review process, or potentially through a consortium that includes NASA and OGAs. The 

priorities of the NASA program office likely guide research activities. 

• Assuming early identification of demand and priorities, international users might access 

the platform through bilateral agreements. 

• OGA users coordinate directly with the NASA program office and might consolidate 

funding for academic grants or contracts with industry where interests align. 

• Commercial users work directly through the CLD provider for most needs but can also 

respond to NASA or OGA requests for proposals. 

Scoring Highlights 

Table 6 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

Table 6. Anchor Tenant Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

✓ Ability to Meet NASA’s Needs Pro Pro Neutral 

Adaptability Con Neutral Neutral 

✓ Opportunity for Collaboration Pro Pro Neutral 

Market Sustainability Neutral Pro Neutral 

Equity & Accessibility Neutral Neutral Neutral 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

35 
 

 

Key Takeaways 

The Anchor Tenant model provides a long-term steady engagement with a CLD. This leads to 

reliable access for NASA to support a significant portion of its exploration needs and for more 

collaborative opportunities, assuming they were identified when drafting the agreement. 

Substantially supporting a CLD also increases the probability of market sustainability. 

However, the model does not respond well to changing needs or to users with additional 

requirements that were not considered early in the process. Moreover, it may dampen longterm economic growth by reducing competition and increasing barriers to entry for non-NASA 

supported anchor tenants as well as users who are not well-established. NASA can try to 

mitigate some of these weaknesses by leveraging flexible contracting pathways, establishing 

alternative pathways for international partners, and increasing leased space to support future 

growth or support to underrepresented communities. 

Overall Strengths Across the Future Scenarios 

The Anchor Tenant model scores positively across multiple future scenarios, demonstrating 

robustness, in terms of: 

✓ Ability to Meet NASA’s Needs: Focuses largely on NASA’s needs, although addressing

changing NASA needs might be more difficult under an inflexible contract with the CLD 

provider. NASA has the ability to jointly (with the CLD provider) develop requirements and 

maintain some degree of autonomy over its area of the platform. NASA can continue its 

LEO activities without any gaps. 

✓ Opportunity for Collaboration: Allows for a continuation of familiar ISS-era operations 

and relationships, given that entry through a NASA program office is familiar to OGA and 

international users. However, NASA likely continues to prioritize mission work over nonmission work, making areas of potential alignment between NASA, OGA, and international 

partner activities somewhat limited. 

Overall Weaknesses Across the Future Scenarios 

The Anchor Tenant model does not score positively across multiple future scenarios, 

demonstrating a lack of robustness, in terms of: 

• Adaptability: Requires long-term agreements and large investments that lock NASA into a 

relationship with one CLD provider. These restrictions can hinder market dynamics in the 

dynamic growth scenario, but present less of a challenge in the steady growth scenario. If 

NASA were to expand its tenancy to more than one platform, it would improve diversity of 

activities, their simultaneous operations, and ability to scale. 

• Equity and Accessibility: Enables NASA to engage underrepresented groups, although the 

focus remains largely on NASA’s needs. Academic and educational activities that do not tie 

directly to NASA objectives must find funding elsewhere. Equity and accessibility is the 

only criterion that neither improves nor worsens by future scenario. 

36 
 

• Market Sustainability: Provides a reliable, consistent customer to the CLD provider, 

helping build their business case and mitigate risks to their return on investment, but if 

considered as is (on only one platform), might not support other operational CLDs. Anchor 

Tenant can help build the market in early stages and can help sustain the market in future 

scenarios with less opportunity but does not help the ecosystem become sustainable 

without NASA. Additionally, an early, significant investment by NASA might preclude 

interactions between platform providers and other potential customers, stifling a free 

market economy. 

37 
 

 

 

Model 2: Government Research Broker 

Reconfigurable missions to CLD platforms maximize 

flexibility for government needs. The research space is 

an orbital transport spacecraft (like Dragon, Dream 

Chaser, or other) that docks at one or more CLDs. 

Users can conduct research on the orbital transport 

spacecraft itself or in combination with the CLD 

platform facilities. Each research space is designated a 

National Laboratory, or a collection of research spaces 

is named a National Laboratory. 

Key Discriminators 

• Building off the success of 

previous NASA programs for 

LEO access, all potential 

research platforms for the 

government become more 

flexible. 

• The research space, or orbital 

transport spacecraft, offers 

shorter missions with 

reconfigurable sorties, tailored 

to user mission requirements. 

A new NASA program, similar to the Launch Services 

Program, but with an expanded role, conducts mission 

planning and negotiates end-to-end services.15,16 

Acting as a broker bringing payloads to LEO, the 

program follows payload requirements, finds the launch provider and orbital transport 

spacecraft, and uses knowledge of the CLD platform (such as interfaces) to determine the best 

destination for payloads. This program may have evolved from earlier programs with similar 

capabilities, such as the Launch Services Program, Commercial Crew Program, and Commercial 

Resupply Services. In the limited growth scenario, where just one CLD is in development, the 

program office still acts as broker for the orbital transport spacecraft but to the one destination 

only. 

NASA and other user communities identify priorities through a user advisory committee, but 

NASA has a guaranteed minimum amount of space per flight. This guarantee ensures NASA can 

prioritize mission needs, but because the guarantee is flexible, NASA can modify the terms of 

the guarantee over time. Funding for non-NASA activities can come from NASA or a consortium 

of departments and agencies that includes NASA. 

Infrastructure 

One or more orbital transport spacecraft, owned by a commercial provider, and at least one 

CLD platform are available. The reconfigurable missions of the Government Research Broker 

model may include a combination of owned and leased hardware and equipment hosted on the 

permanent platforms and spacecraft vehicles, as the specific missions require. Signature 

capabilities may necessitate NASA owning hardware, on the other hand, to meet sortie 

objectives. The LEO hardware on orbital transport spacecraft may change mission to mission 

and be owned by an entity other than NASA. The CLD platform might provide an exclusive port 

to government users to ensure availability. 

Reconfigurable aspects of the orbital transport spacecraft provide flexibility to users. These 

aspects include the spacecraft itself (within limitations), instrumentation, and other equipment 

38 
 

that changes between research-focused missions. Reconfigurable aspects of the spacecraft can 

work in tandem with the facilities or crew on the CLD platform. 

Stakeholder Roles 

The NASA program office serving as the broker has final decision-making authority for 

selecting payloads and finding the best launch service provider and CLD platform to host the 

payloads. This is an expansion of previous NASA programs that includes a diverse set of 

stakeholders with varying priorities. The CLD provider has final authority over activities that 

use their platforms or ports. 

NASA prioritizes activities through a user advisory committee, which includes both NASA and 

non-NASA users. Although NASA maintains control over the activity selection process, user 

communities can provide their input and perspective through the user advisory committee and 

through decadal surveys. The user advisory committee also sets research priorities, in a 

process similar to the decadal survey. 

Process for Accessing LEO 

Figure 4 illustrates the process this model takes for connecting user activities with platforms. 

Figure 4. Process for Accessing LEO through the Government Research Broker Model 

Step 1: The NASA program office leads the process for users’ LEO access. A user advisory 

committee within the program office identifies user priorities. The program office uses grants 

and other funding mechanisms to enable LEO access for academic, OGA, and commercial users. 

The program office then selects which activities can be supported through the model. 

39 
 

 

Step 2: The program office facilitates the user process to achieve flight-ready payloads and also 

allocates integration, crew time, and mass to orbit. The program office determines payload 

priorities and, as broker, aggregates the payloads and finds the best launch provider, orbital 

transport spacecraft, and CLD platform for hosting the mission (if the mission will dock), given 

payload requirements. 

Step 3: Finally, the program office guides the mission from pre-planning to post-launch if the 

mission does not dock to a CLD. If the mission docks to a CLD, then the commercial provider 

decides which missions are allowed to dock to the platform. 

Agreements Between Users and Providers 

The agreement between NASA and other orbital transport providers is a long-term contract, 

with built-in flexibilities. The agreement between the NASA program office and CLD providers 

is more flexible and based on shorter term mission needs. The NASA program office 

coordinates individual activities of user communities for various services. This includes 

transportation services to and from the CLD, which requires different contract terms and 

liability waivers. 

Users who receive grant funding through the formal proposal and review process enter formal 

agreements with the granting agencies, whether NASA or others. 

Impacts to User Communities 

Although predominantly researched-focused, with activities frequently aligning with NASA, 

OGA, and academic user needs, this model provides some opportunity for international and 

commercial users. All user communities can have representation through a multi-user advisory 

committee. Users generally have research needs met, and NASA can prioritize mission-related 

research. 

• Academic users can submit grant proposals to a formal review process by NASA or by a 

consortium that includes NASA and one or more OGAs. 

• International users can interface directly with the NASA program office. When interests 

align, a bilateral agreement can enable activities on the research vessel. 

• OGA users participate in the process through grants or contracts with NASA where 

interests align. NASA and OGAs can coordinate resources to fund research grants in areas 

of mutual interest. 

• Commercial users work directly through the NASA program office. Companies may also 

partner with non-NASA researchers. NASA may provide a means to reduce costs for 

commercial users, particularly where interests align. 

40 
 

 

 

 

Scoring Highlights 

Table 7 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

Table 7. Government Research Broker Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

✓ Ability to Meet NASA’s Needs Pro Pro Neutral 

✓ Adaptability Pro Pro Neutral 

✓ Opportunity for Collaboration Pro Pro Neutral 

Market Sustainability Neutral Neutral Neutral 

✓ Equity & Accessibility Pro Pro Neutral 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The Government Research Broker model provides a reliable option for NASA to continue 

activities in LEO in any future scenario, especially if the ecosystem does not develop as desired 

or expected. The range of built-in flexibilities can buffer against major changes in available 

infrastructure and against how capabilities within CLD platforms may develop. The 

Government Research Broker model meets the needs of all but one of the stakeholder-driven 

performance criteria. The model falls short in terms of market sustainability, as there is 

potential for competition to arise between the CLD platforms and the orbital transport 

spacecrafts. However, this can be designed against if considered early on by incentivizing port 

standardization and ensuring mutual government-industry benefits, for example. The high 

level of government involvement, combined with the ability to optimize the government’s

research space as needed, make this model a viable option for consideration. Note that NASA’s

Commercial LEO Program has precluded sortie-style research options from CLD awards. 

Should this model be considered, that should be taken into consideration. 

Overall Strengths Across the Future Scenarios 

The Government Research Broker model scores positively across multiple future scenarios, 

demonstrating robustness, in terms of: 

41 
 

 

✓ Ability to Meet NASA’s Needs: Allows for NASA’s exploration and research needs to be 

met, assuming the larger volume on a platform is available when the more confined 

volume on a research vessel is insufficient. NASA, and any users operating through NASA, 

benefit from the ability to optimize the research space in any future scenario. In a more 

limited future scenario, the model can account for NASA’s needs, with some need to 

prioritize efforts due to platform limitations, however. 

✓ Adaptability: Combines orbital transport vehicle capabilities with platform capabilities to 

optimize available infrastructure and to buffer against major uncertainties in the future 

ecosystem. With providers encouraged to build interoperability into ports, vehicles, and 

platforms, users can mix and match objectives over time and space. This model can 

provide flexibility in at least six ways: 1) the choice of crewed or uncrewed orbital 

transport spacecraft (Dragon, Crew Dragon, Starliner, Dream Chaser, or other); 2) ability to 

dock at one or more ports within a CLD platform; 3) ability to dock at multiple CLD 

platforms; 4) ability to conduct activities within the orbital transport spacecraft, within the 

CLD, or a combination of the two; 5) potential to undock from one port and move to a port 

on another CLD; and 6) tailorable contract durations for CLD port use. Ensuring access to 

an orbital transport vehicle capable of moving between commercial platforms (e.g., Dream 

Chaser) is a key component for flexibility in future scenarios where more than one 

commercial platform exists. 

✓ Opportunity for Collaboration: Promotes collaboration by aggregating and brokering 

opportunities for themed missions, spanning different user bases. For example, payloads 

from government, international, academic, and commercial users may be strategically 

coalesced on a single mission to optimize resource and knowledge sharing. The user 

advisory committee helps to ensure collaboration among non-NASA partners. However, as 

opportunities on orbit decrease in the case of a limited growth future scenario, the user 

advisory committee may shift from championing collaboration to prioritizing research 

needs, as stronger ties to NASA’s mission are needed in a more limited environment.

✓ Equity and Accessibility: Generally seeks input from a diversity of users, who are wellserved in future scenarios with more opportunity. The NASA program office, user advisory 

committee, and grant opportunities promote widespread access. However, these benefits 

are more constrained in a more limited growth scenario, since opportunities may need 

higher alignment with NASA needs. 

Overall Weaknesses Across the Future Scenarios 

The Government Research Broker model does not score positively across multiple future 

scenarios, demonstrating a lack of robustness, in terms of: 

• Market Sustainability: Has the potential to compete with industry, especially with CLD 

providers. Key aspects would help ensure that this model works with industry, benefitting 

both industry and NASA. Ensuring the orbital research vessel is designed to work in 

42 
 

tandem with CLDs is one such consideration. Another is ensuring the orbital transport 

vehicle has NASA-specific hardware that will not be on the CLD. This aside, the model can 

accommodate some market growth either directly (i.e., ensuring access for industry) or 

indirectly (i.e., benefitting the orbital transport vehicle business). Some degree of access is 

also guaranteed to CLD providers, though this is intended to be flexible and would alter as 

market dynamics shift. 

43 
 

 

 

 

 

 

Model 3: Innovation Campus 

A terrestrial innovation campus is the center for 

microgravity research, operations, and innovation, 

similar to a NASA concept called Sally Ride National 

Laboratory.25 The concept details the creation of a new 

FFRDC or University Affiliated Research Center 

(UARC),

26 including a new government-owned campus 

(or center or lab) operated by a non-government 

entity. This campus is dedicated to conducting 

advanced science and R&D projects of benefit to the 

nation through the use of human spaceflight platforms. 

Key Discriminators 

• A terrestrial innovation campus 

focuses on spurring innovation, 

developing skillsets, and building 

the LEO workforce, rather than 

matching supply (platforms) to 

demand (payloads). 

• While unique to this model, the 

innovation campus concept can 

work in concert with other models. 

With participation open to all user communities, the 

campus promotes partnership, innovation, developmental R&D, and mission planning efforts 

for LEO. The campus attracts high-quality candidates, uses expertise from key sectors 

(academic, commercial, and others), facilitates academic exchanges, and promotes education 

and training in STEM and other disciplines. The campus is designated a National Laboratory. 

With NASA as the sponsor agency, a third party operates and maintains the government-owned 

campus using a standard FFRDC or UARC model.14 The third party can be a nonprofit, an 

academic institution, or a commercial contractor. 

As visualized in this model, the campus does not connect payloads to platform providers. It can, 

however, be used in combination with another model that does connect with platform 

providers. Similarly, the campus in this model is limited to LEO efforts, but the model can be 

expanded in scope to incorporate other human spaceflight efforts related to lunar and other 

domains. 

Infrastructure 

A terrestrial innovation campus attracts, aggregates, and develops a skilled workforce from 

academic institutions, industry, or other organizations. The campus hosts specialized facilities, 

equipment, and other infrastructure that various users can access for advanced research, 

development, testing, and evaluation.27 NASA owns this physical infrastructure as a sponsor, 

but a third-party organization (nonprofit, academic institution, or commercial contractor) 

operates and maintains it. 

Stakeholder Roles 

NASA is the government sponsor that owns the campus and has final decision-making 

authority. As designated by NASA, a third-party operator conducts and manages day-to-day 

activities. 

44 
 

 

Other user communities contribute through academic exchanges, multi-user partnerships 

(including international partnerships), and other projects hosted at the campus as the NASA 

budget allows. 

The campus provides a clearly identifiable point of entry for new users, which the third-party 

operator guides through the process. 

Process for Accessing LEO 

Figure 5 illustrates the process this model takes for connecting user activities with platforms. 

Figure 5. Process for Accessing LEO through the Innovation Campus Model 

Step 1: The campus maintains an open-door policy for OGA, commercial, international, and 

other users. The campus supports users through design and development of missions and 

projects. The campus may also conduct outreach to solicit partnership opportunities. NASA 

provides strategic priorities and funds specialized divisions. For new divisions or projects, 

NASA must approve additional funding requests, which likely require authorization by 

Congress as well. The third-party operator manages activities and day-to-day operations. 

Step 2: For all approved activities, the third-party operator allocates resources and facilitates 

processes—for ground resources only, such as lab space and lab equipment. Ground resources 

can include use of facilities and pre- or post-flight operations. 

Step 3: This model does not include a process to connect users to platform providers for LEO 

activities. The concept for the model emerged from stakeholder discussions and has been 

included in this list of models as a major differentiator. This model benefits from being able to 

work in concert with any of the other models presented in this report to connect users to LEO 

platforms. 

45 
 

 

 

 

Agreements Between Users and Providers 

The agreement with the third-party operator is likely a long-term management and operations 

(M&O) contract. Agreements required for other campus activities, such as establishing 

partnerships or using specialized equipment and facilities, may involve other flexible types of 

agreements, such as SAAs, CRADAs, contracts, and grants. While the agreements for campus 

activities remain both targeted and flexible, the campus relies on long-term investments to 

build and maintain its workforce. 

Impacts to User Communities 

The campus’s open-door policy in this model allows all users to participate. 

• Academic users can lend faculty expertise, initiate or join in multi-user projects, and 

participate in student programs that promote STEM education and build workforce skills. 

• International partners and firms can participate in exchanges, projects, and other 

activities at the campus. The campus invites countries with small or new space programs 

to participate in projects. 

• OGA users can participate in exchanges, projects, and other activities at the campus. Their 

participation in the campus ensures OGAs have access to high-quality talent from industry 

and academic institutions. 

• Commercial users can participate in exchanges, projects, and other activities at the 

campus. Close proximity to academic users may facilitate better technology transfer 

opportunities. Commercial users can also access specialized equipment and facilities for 

testing, evaluation, and demonstrations. 

Scoring Highlights 

Table 8 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

46 
 

 

 

Table 8. Innovation Campus Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

✓ Ability to Meet NASA’s Needs Pro Pro Neutral 

Adaptability Pro Neutral Neutral 

✓ Opportunity for Collaboration Pro Pro Neutral 

Market Sustainability Neutral Neutral Neutral 

Equity & Accessibility Pro Neutral Neutral 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The Innovation Campus model is designed to augment efforts in LEO with ground-based 

resources and can best do so in a dynamic environment, where there are many stakeholders 

and enough funding to support activities. Assuming a separate model can connect users with 

CLDs, this model can help ensure the government maintains a skilled LEO workforce, with the 

added benefit of scaling to account for mission needs beyond LEO. These benefits significantly 

drop off however, as opportunities in LEO decrease. In future scenarios with less opportunity, 

the sponsoring agency typically must focus efforts on mission priorities. Tangential activities 

and non-government users or partners would most feel the effects of these prioritizations. The 

model can potentially support a steady growth scenario, but with limited resources. 

Considerations such as expanding the government sponsor to include multiple agencies may 

alleviate some resource-related restrictions seen in the steady and limited growth future 

scenarios. Additionally, creating a pathway for industry to access campus resources may 

augment some weaknesses in market growth seen in all future scenarios. 

Overall Strengths Across the Future Scenarios 

The Innovation Campus model scores positively across multiple future scenarios, 

demonstrating robustness, in terms of: 

✓ Ability to Meet NASA’s Needs: Supplements LEO-based activities with terrestrial 

activities focused on developing and testing technologies and building and maintaining 

skills for the LEO workforce. Assuming another mechanism to connect with CLDs, this 

model’s ability to grow a LEO workforce positively contributes to meeting NASA’s research 

and exploration needs. Built-in flexibilities to ensure that research focus areas can adjust 

to shifting needs will help ensure the model can meet NASA’s needs in any future scenario. 

47 
 

 

 

 

 

✓ Opportunity for Collaboration: Generally supports a collaborative environment largely 

due to its open-door policy, allowing OGAs, international, and other users a physical space 

for collaboration. However, the activities and programs available for collaboration may be 

limited by NASA’s budget and need for alignment with NASA’s priorities. This becomes 

more evident in a more limited future scenario. 

Overall Weaknesses Across the Future Scenarios 

The Innovation Campus model does not score positively across multiple future scenarios, 

demonstrating a lack of robustness, in terms of: 

• Adaptability: Might not move at the speed needed to adjust to shifts in the market. That 

said, the model’s focus on NASA’s mission and related activities may serve the government 

well. Activities identified as needing inclusion in the model can scale as needed. Activities 

can also scale beyond the LEO focus, adapting to NASA’s mission needs as they evolve to 

Moon and Mars. Overall, activities can be limited across future scenarios, but their focus 

may serve the government well. 

• Market Sustainability: Could be at odds with market growth given its heavy mission 

focus, unless there is a strong tie to identified mission needs. Generally, this model can 

provide some assurances to platform providers by developing and testing technologies 

terrestrially, increasing their probability for mission success. However, market growth 

related to companies wishing to purchase services in LEO may be strained if there are 

fewer opportunities to fly non-NASA payloads, as with the more limited future scenarios. 

• Equity and Accessibility: Provides access to campus resources for many, with low-cost 

pathways for research (e.g., grants, exchanges, academic partnerships), but with lower 

impact in the limited and steady growth scenarios given fewer opportunities (and likely 

less funding). A focus on learning and on building skillsets within the NASA workforce 

while involving many non-NASA users promotes equity and accessibility. 

48 
Model 4: Matchmaker 

A “matchmaker” connects user community activities 

directly with CLD providers based on mission and 

technical requirements. The matchmaker is a neutral 

third-party nonprofit organization funded by NASA. 

The matchmaker provides a clearly identified point of 

access to LEO for both users and providers. 

Throughout the process, the matchmaker supports 

current and prospective users to ensure mission 

success. Meanwhile, CLD providers benefit from the 

dedicated marketplace made possible by the 

matchmaker, making their services accessible to 

customers. The suite of services provided by the matchmaker to coordinate, facilitate, foster, 

support, and aggregate is designated a National Laboratory. 

Key Discriminators 

• A neutral third party directly 

and objectively connects users 

to platform providers based on 

mission and technical 

requirements. 

• The matchmaker aggregates and 

communicates user demand to 

industry to inform future 

services. 

Infrastructure 

Facilities, hardware, and other infrastructure are available from CLD providers. 

The matchmaker has no direct connection to infrastructure but must remain knowledgeable of 

existing platform and infrastructure capabilities to offer effective matchmaking. 

Stakeholder Roles 

NASA is the sponsor agency for the matchmaker, which is a third-party nonprofit organization. 

The matchmaker oversees day-to-day matching of user activities to platform options. 

In addition to objective matchmaking and communicating user demand to industry, the 

matchmaker may coordinate research activities, facilitate technology transfer, foster emerging 

companies, and support multi-agency programs. NASA oversight and feedback is incorporated 

into matchmaking decisions and activities. 

Both platform providers and users across all communities participate through the matchmaker. 

New users have a clearly identified point of access that assists them throughout the process, 

answers their questions, and provides guidance to ensure mission success. 

Process for Accessing LEO 

Figure 6 illustrates the process this model takes for connecting user activities with platforms. 

49 
 

 

Figure 6. Process for Accessing LEO through the Matchmaker Model 

Step 1: NASA sponsored users approach NASA directly to seek funding for activities and may 

approach the matchmaker first to gain technical expertise. Non-NASA funded users can 

approach the matchmaker directly with an idea or a need. 

Step 2: The matchmaker provides users with mission and technical expertise, analyzes 

available options, supports user-provider coordination based on available services and 

demand, and facilitates the process to prepare activities for flight. Providers can also approach 

the matchmaker with requests for support. The matchmaker can help providers enter the 

market or help make prospective customers aware of new goods and services. In some cases, 

the matchmaker can serve as a mechanism on behalf of government users to facilitate joint 

projects and accelerate technology transfer between labs and companies. 

Step 3: The matchmaker connects selected user activities directly with the commercial 

provider, who then decides which flight-ready activities will go to a commercial platform. 

Agreements Between Users and Providers 

Typically involving flexible contracting mechanisms, agreements are based on need, customer 

affiliation, and service provided. 

Impacts to User Communities 

Despite the focus on meeting supply with demand, this model does not provide the means to 

ensure all user needs are met. 

• Academic users can enter into agreements to gain access to platforms, systems, and other 

infrastructure, but at a significant cost. Participation may require grants from NASA or 

OGAs to cover the high cost. 

50 
 

 

 

 

• International users can continue partnering with NASA, but with activities coordinated 

through the matchmaker. 

• OGA users can enter into agreements to gain access to platforms, systems, and other 

infrastructure, to have their needs met. 

• Commercial platform providers can access the marketplace and communicate available 

goods and services through the matchmaker. Although commercial users can work directly 

with platform providers (business-to-business), going through the matchmaker might 

ensure a better match for their technical and mission needs. 

Scoring Highlights 

Table 9 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

Table 9. Matchmaker Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

Ability to Meet NASA’s Needs Pro Neutral Neutral 

✓ Adaptability Pro Pro Pro 

Opportunity for Collaboration Pro Neutral Con 

Market Sustainability Neutral Neutral Neutral 

Equity & Accessibility Neutral Neutral Neutral 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The Matchmaker model generally is better served in future scenarios with an abundance of 

opportunities, allowing for NASA’s needs to more easily be met and for more collaborative 

opportunities. The model’s performance does not stand out in any evaluation criteria except for 

adaptability. Given this, the model’s performance may be more dictated by limitations from the 

future scenario, rather than inherent limitations of the model itself. Given the adaptable nature 

of the matchmaker, this may mean that limitations can be designed against if considered early 

on. 

51 
 

 

 

Overall Strengths Across the Future Scenarios 

The Matchmaker model scored positively across multiple future scenarios, demonstrating 

robustness, in terms of: 

✓ Adaptability: Generally works within scenario-driven limitations and can therefore adapt 

to any of the future scenarios in terms of its ability to cater to different platforms and 

support activities in a number of ways. The matchmaker guides and optimizes the 

execution of activities, with full awareness of past, current, and upcoming missions, and 

can do so given the variety of ways the future scenarios may play out. 

Overall Weaknesses Across the Future Scenarios 

The Matchmaker model did not score positively across multiple future scenarios, 

demonstrating a lack of robustness, in terms of: 

• Ability to Meet NASA’s Needs: Steady growth and more restricted future scenarios may 

generally meet NASA’s needs, but with a need to prioritize missions. Future scenarios with 

an abundance of opportunities, especially platform options, are best suited for NASA’s

needs. The matchmaker’s incorporation of NASA oversight and feedback would increase 

NASA’s ability to meet its needs in any future scenario.

• Opportunity for Collaboration: Furthers cooperation and collaboration through 

influence and by exhibiting trust as a third-party broker, but can lose that trust if a user 

receives a poor match. To form and maintain these trusted relationships, the matchmaker 

must use knowledge of and experience with the different players in the LEO ecosystem to 

match users with providers who meet mission and technical requirements. More options 

for connecting users and providers in a dynamic growth scenario may strengthen 

collaborations (though would increase the complexity of the matchmaker role), while 

having few users in a limited growth scenario reduces the opportunity for collaborations. 

• Market Sustainability: Must prioritize objectivity to ensure it does not show favoritism, 

which could interfere with the market. The matchmaker can accommodate some market 

growth, boosted by the early communication of demand. It can reduce some risk for CLD 

providers but may need to proactively encourage this early on (e.g., by improving 

efficiencies and providing incentives). Assurances to CLD providers might decrease with 

less opportunity. Less opportunity combined with less overall support may also increase 

barriers to entry, affecting market development. 

• Equity and Accessibility: Guides new entrants but lacks low-cost pathways for research 

(i.e., grants), and flights may still be cost-prohibitive to certain users. While the model does 

not feature a formal grants process, and instead seeks to match users to platform options 

as a neutral third party based on mission and technical requirements, low-cost pathways 

for research can be adopted to overcome this limitation. Similarly, ISSNL stakeholders 

noted that the model can replicate the ISSNL’s approach of using a centralized LEO services 

52 
budget from NASA and allowing CLDs to bid on opportunities to accommodate user needs 

to avoid appearing to show favoritism and act as an honest broker. 

53 
Model 5: Institute Network 

The Institute Network is a network of individual but 

related efforts with a focus on commercial scaling and 

maintaining U.S. leadership. Designed after the 

Manufacturing USA manufacturing innovation 

institutes (MIIs),28,29 NASA and OGAs form a 

consortium to identify and jointly fund newly 

proposed institutes, which are considered publicprivate partnerships. Institutes can involve multiple 

user communities (commercial, academic, 

international) and include co-investment from 

commercial participants and potentially other 

participants. A third-party nonprofit organization 

manages each institute, coordinating the activities of 

its members and the use of infrastructure. The capabilities provided through the networked 

institutes are designated a National Laboratory. 

Key Discriminators 

• A multi-user network connects 

separate but related efforts to 

enable commercial scaling and 

advance U.S. interests. 

• Individual or joint funding from 

government agencies funds the 

network, with co-investment 

from commercial participants 

and potentially others increasing 

over time. 

NASA and OGAs benefit from cost-sharing and participant co-investment for new institutes 

while agreeing to fund new institutes that are designed to meet their needs. Other participants 

benefit from access to the network, infrastructure, and other capabilities to advance research 

and scalable commercialization activities. 

Infrastructure 

Participants in the network include CLD providers and other providers of platforms, hardware, 

and other infrastructure. The network enables collaborative use of these facilities among its 

various members for LEO activities. 

Stakeholder Roles 

NASA and OGAs fund new institutes designed to meet their needs as well as the needs of their 

stakeholders. A third-party nonprofit organization manages these institutes, but depending on 

the design, management of the institute can incorporate NASA oversight and feedback. The 

third-party nonprofit organization also coordinates the use of infrastructure. 

Companies co-invest in individual institutes, but other user communities can contribute to 

investment in an institute as well. The participating members in an institute can establish 

multi-user projects and use available infrastructure for project activities, as approved by the 

managing third-party nonprofit. New users can join pre-established institutes or form new 

ones with other potential participants. 

Institutes can enter into a wider network with other established institutes to tackle larger 

challenges and wider focus areas. Similar to the MIIs, industry is expected to increase funding 

54 
 

 

 

 

 

for individual institutes over time (potentially freeing up government funds for investment in 

other areas or in new institutes). 

Process for Accessing LEO 

Figure 7 illustrates the process this model takes for connecting user activities with platforms. 

Figure 7. Process for Accessing LEO through the Institute Network Model 

Step 1: NASA and OGAs guide the creation and selection of institutes. NASA and OGAs form a 

consortium to individually or jointly fund new institutes and receive Requests for Application 

from prospective networks. NASA and OGAs can also route interested participants to existing 

institutes that meet their needs. Users can lease platform facilities and other infrastructure 

from providers participating in the institutes. Users can either coordinate with the third-party 

nonprofit managing the institute or work directly with the provider, as directed by the 

institute. 

Steps 2 and 3: Since commercial providers are part of the institutes, the providers are 

responsible for bringing selected activities to commercial platforms. 

Agreements Between Users and Providers 

NASA, or a consortium of government agencies that includes NASA, solicits new institutes 

through Requests for Application. Institutes are co-funded by the government consortium and 

industry, though the government decreases its funding over time. Applications for new 

institutes guarantee co-investment from commercial participants and potentially other 

participants. 

55 
 

 

 

Impacts to User Communities 

Despite the model’s primary focus on commercialization, which frequently aligns with 

commercial needs, opportunities do exist for other user communities. 

• Academic users can participate in the institutes and enter into agreements to gain access 

to platforms, systems, and other infrastructure. NASA and OGAs may fund institutes that 

provide reduced costs for academic payloads or continue to support academic research 

through grants. 

• Institutes can include international user participation. The institutes are responsible for 

legal considerations to protect intellectual property and other sensitive information. 

• OGA users can form consortia with NASA and others to jointly select and fund institutes 

that meet their needs. Alternatively, OGAs can work directly with the nonprofit 

organization managing the institute as outlined in the cooperative agreement. 

• Commercial users and providers can access partners, infrastructure, and services needed 

to advance and scale capabilities. 

Scoring Highlights 

Table 10 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

Table 10. Institute Network Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

Ability to Meet NASA’s Needs Pro Neutral Con 

Adaptability Pro Neutral Con 

Opportunity for Collaboration Pro Neutral Con 

Market Sustainability Pro Neutral Neutral 

Equity & Accessibility Neutral Con Con 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The benefits of the Institute Network generally scale across future scenarios. This model 

advances commercial capabilities in areas of interest to the government and is best positioned 

56 
 

 

 

to do so in a dynamic growth scenario with many opportunities and players. The model’s

ability to bring many user communities together in support of government needs, with 

emphasis on advancing industry, is a unique way to advance the country’s LEO capabilities. For 

this reason, NASA may want to consider this model after a successful transition to CLDs and 

demonstration of some success. NASA can also incorporate lessons learned from the MIIs (or 

similar programs) once the LEO ecosystem is more established. 

Overall Strengths Across the Future Scenarios 

This model has a high level of variability across all three future scenarios and no criterion 

receives at least two Pros across the three future scenarios. The model performs well in a 

dynamic growth scenario but struggles to provide the same benefit in steady and limited 

growth scenarios, since its ability to meet evaluation criteria relies on a large, more established 

network of participants. 

Overall Weaknesses Across the Future Scenarios 

The Institute Network model does not score positively across multiple future scenarios, 

demonstrating a lack of robustness, in terms of: 

• Ability to Meet NASA’s Needs: Best meets NASA’s needs in the dynamic growth scenario, 

where focus areas can be as generalized or specific as needed, and a multitude of players 

can meet these needs. As opportunities reduce, focus areas may become more targeted. 

NASA also may need to ensure activities that do not have promising return on investment 

can still be advanced. 

• Adaptability: Enables adaptability depending on the level of opportunity across future 

scenarios. Flexibility in research areas and scalability of activities is a major benefit of the 

networks, as well as available commercial platforms. Built-in flexibilities in focus areas 

would help the government adapt as mission needs change and as technologies mature. 

Overall, the institutes are more adaptable in a dynamic growth scenario. 

• Opportunity for Collaboration: Allows flexibility in how users engage other users, 

encouraging information sharing and collaboration rather than competition for advancing 

a given capability. Although the institutes are designed for collaboration, implementing 

such collaboration across user groups could be a challenge, particularly in the areas of 

addressing competition and protecting intellectual property. Again, this criterion scales 

with more opportunity, making it most useful in a dynamic growth scenario, with some 

benefit in a future similar to today. 

• Market Sustainability: Could drive the market in a positive direction given its emphasis 

on commercialization; however, the number of institutes decreases as opportunities 

decrease across future scenarios. This may be beneficial to prioritized focus areas but 

could exclude others. The distribution of responsibility allows for more time, energy, and 

money for individual institutes, delivering a high-quality experience to users. This again 

57 
 

applies to the dynamic growth scenario and becomes less useful with less growth and 

diversity. 

• Equity and Accessibility: Prioritizes commercial interests in specific and potentially niche 

areas. New users might struggle to enter the process and network; participation may be 

limited to less diverse users already working in specific areas. With a focus on 

commercialization, academic participation might be limited to research that advances a 

capability or addresses a government-identified focus area that may not generate return 

on investment. 

58 
 

Model 6: Fee for Service 

In a free market approach, users purchase goods and 

services from commercial providers. Users may 

purchase these goods and services directly from the 

providers, but users may also coordinate with other 

users to reduce costs, pool resources, and ensure 

needs are met in LEO. NASA awards grants for 

research and uses data buys to meet its central needs. NASA’s grant announcements and 

requests for proposals (RFPs) communicate market demand to commercial providers. The 

collection of activities enabled by grants and data buys is designated a National Laboratory. 

Key Discriminators 

• A free market approach to 

accessing LEO, which ebbs and 

flows with supply and demand. 

Infrastructure 

All platforms, equipment, and other systems are commercially owned. NASA does not maintain 

any infrastructure in LEO. 

Stakeholder Roles 

CLD providers have authority over all decisions about their platforms and infrastructure. These 

providers coordinate with NASA and other user communities as customers only. 

NASA, either independently or jointly with OGAs and international partners, funds grants in 

niche areas of research and development and purchases goods or services through NASA’s

commercial LEO services budget. 

NASA can purchase goods and services in several ways, and NASA-funded users may use these 

as determined by NASA. Examples of how NASA can purchase goods and services include 

purchasing accommodations for crew; space to host a payload or other hardware; time to tend 

to a NASA-flown or CLD-owned payload; use of external space to host science payloads for a 

specified amount of time; and consumables or materials. NASA also contracts with commercial 

providers to purchase data with broad utility, such as for human research and technology 

performance. 

Other government-sponsored user communities can contact platform providers directly for 

their needs. Some user communities may prefer to use NASA as an intermediary when working 

with providers. User communities can also provide input about critical research areas through 

decadal surveys and other means. 

Process for Accessing LEO 

Figure 8 illustrates the process this model takes for connecting user activities with platforms. 

59 
 

 

Figure 8. Process for Accessing LEO through the Fee for Service Model 

Step 1: Commercial providers set prices for goods and services based on principles of supply 

and demand. NASA communicates demand for future goods and services to commercial 

providers. NASA gathers input from user communities on their needs. Agency priorities guide 

research topics and data needs, informing potential grants, services, and data buys. While 

commercial providers use this information to understand market demand, they have no 

obligation to fulfill these needs and may forgo service contract awards from NASA in favor of 

more profitable business-to-business transactions. 

Steps 2 and 3: In this model, users can go through NASA (Step 1) to influence priorities; 

however, the commercial provider has the ultimate say on what activities are flown and, in the 

marketplace, which data and services can be purchased. Once the commercial provider 

determines what activities can be accommodated, they take the payloads through the steps to 

connect with a platform. 

Agreements Between Users and Providers 

Agreements are likely in the form of contracts between users and commercial providers. 

Contracts provide a low level of commitment for either short- or long-term services, as agreed 

upon by the user and provider. Follow-on contract options depend on the availability of the 

platform. 

NASA maintains its grant review process and uses an RFP process for services and data buys. 

When NASA jointly sponsors a grant or service/data buy, a more complex interagency or 

international agreement might be necessary. 

60 
 

 

Impacts to User Communities 

With this model, interacting with commercial platform providers offers users a straightforward 

process with a clear point of entry and customer-oriented service. Users are beholden to the 

prices for goods and services set by commercial companies, as driven by the market, though 

some forms of negotiation may exist. 

• Academic users can continue to submit proposals for research grants and guide NASA 

research priorities through decadal surveys and other efforts. With research funding, 

awardees can coordinate directly with platform providers or indirectly through NASA. 

Recipient accommodations on a CLD would be purchased through NASA’s commercial LEO 

services budget. 

• International users can make arrangements to fly through NASA if strategic needs align. 

Otherwise, interfacing directly with CLDs may present challenges for some members of the 

international community if in conflict with their country’s desire to purchase services from

within their own country. 

• OGA users may be able to jointly fund or benefit from grants and data buys, potentially 

with special data use agreements as required. 

• Commercial users can interface directly with platform providers, develop partnerships, 

and participate in transactions in an open market. Commercial users can also submit 

responses to RFPs and receive data buy contract awards, although this option might be 

limited to large companies with richer datasets. NASA or OGAs may choose to continue to 

provide incubation subsidies to support emerging markets, such as in-space 

manufacturing. 

Scoring Highlights 

Table 11 summarizes the model’s scores per future scenario, as evaluated by each of the five 

criteria. See Methods for definitions of the evaluation criteria, Appendix B for the full scenario 

narratives, and Appendix D for the full scoring results, including brief explanations for why 

each criteria receives a Pro, Neutral, or Con score per future scenario. 

61 
 

 

Table 11. Fee for Service Scoring Summary 

Model Evaluation Criteria 

Future Scenario 

Dynamic 

Growth 

Steady 

Growth 

Limited 

Growth 

Ability to Meet NASA’s Needs Neutral Pro Neutral 

✓ Adaptability Pro Pro Neutral 

Opportunity for Collaboration Neutral Neutral Neutral 

✓ Market Sustainability Pro Pro Neutral 

Equity & Accessibility Neutral Neutral Neutral 

✓ Overall strength = Criterion received at least two Pros across the three future scenarios 

Key Takeaways 

The Fee for Service model embodies a flexible, free market and is particularly well-suited to 

steady and dynamic growth future scenarios in which the commercial potential of LEO is more 

fully realized. The model can generally adapt to activities, infrastructure, etc.; however, 

activities may skew towards those that generate the most revenue. To support market 

sustainability, NASA’s demands are clearly communicated and financially supported through 

grants and service/data buys. However, the cost of conducting activities in LEO is primarily 

driven by supply and demand and set by the commercial providers. Users and providers whose 

interests align well with NASA’s interests may seek funding through NASA grants and 

service/data buys, but others are largely left to fund and fend for themselves. Barriers to entry, 

including cost, expertise and know-how, and willingness to work directly with commercial 

providers, may prove prohibitive for new entrants, academic researchers, other government 

agencies, and the international community. 

Overall Strengths Across the Future Scenarios 

The Fee for Service model scores positively across multiple future scenarios, demonstrating 

robustness, in terms of: 

✓ Adaptability: Provides flexibility and scalability of activities, and with available platforms 

and infrastructure options, can allow for multiple diverse activities to occur 

simultaneously. However, overall adaptability is contingent upon a thriving ecosystem 

with ample supply options in terms of platforms and services. While the model can 

generally adapt to what is available, we note that commercially supplied activities may 

skew towards those that generate the most revenue. NASA (and potentially international) 

users may still go through a singular NASA office to get projects to LEO. However, other 

62 
 

 

users will need to work with the commercial providers directly to get their projects to 

orbit. This may encourage users to consider cheaper and more easily accessible flights in 

orbital, suborbital, and parabolic vehicles, in addition to permanent commercial space 

stations. 

✓ Market Sustainability: Encourages market growth by allowing market-driven solutions 

and offerings to flourish; incentivizes businesses to provide a good user experience to gain 

repeat customers. The model may have a tendency to favor some markets over others. 

Overall Weaknesses Across the Future Scenarios 

The Fee for Service model does not score positively across multiple future scenarios, 

demonstrating a lack of robustness, in terms of: 

• Ability to Meet NASA’s Needs: Clearly communicates NASA’s needs through grants and 

service/data buys but does not guarantee access to NASA researchers, who might struggle 

in a dynamic growth scenario where demand is high among commercial users. NASA might 

also struggle with access in a limited growth scenario, where it may face competition with 

other high-paying customers for few flight opportunities. In steady growth, NASA is likely 

not de-prioritized and can access platforms as needed. Offerings and prices set by the free 

market remain outside of NASA’s control.

• Opportunity for Collaboration: Lacks a dedicated organization for helping new, 

inexperienced users enter the market. OGA and international users might prefer to work 

through NASA, given its experience, brand, and trust. OGAs may have opportunities for 

cost-sharing and mutual funding of grants and data buys but only in areas aligned with 

NASA’s needs. International users might also participate in these efforts, if the right 

protections are in place, but might instead prefer to spend money within their own 

borders. 

• Equity and Accessibility: Presents a barrier in cost, especially for academic and 

educational activities. Even with grants from the government, transactions and 

agreements have a “one-off” nature. Grants and some ability to provide input into activity 

selection processes do provide some buffer against free market dynamics; however, those 

dynamics are ultimately not in favor of prioritizing access for all. 

63 
 

 

 

 

Model Comparison 

This section provides an aggregate view of the models by the five model evaluation criteria—

ability to meet NASA’s needs; adaptability to infrastructure, service provider offerings, and user 

demands; opportunity for collaboration; market sustainability; and equity and accessibility—

across the three future scenarios—dynamic growth, steady growth, and limited growth—to 

enable comparison for senior leadership consideration. The Pro, Neutral, and Con scores that 

were previously detailed by the individual models were aggregated into overall model 

strengths and weaknesses, based on a model’s ability to score favorably (Pro) across more than

one future scenario. A model strength indicates a model evaluation criterion for which a model 

received at least two Pros across the three future scenarios. On the flip side, a model evaluation 

criterion is referred to as a weakness, or an area of possible improvement, if it does not score 

positively across multiple future scenarios, meaning the criterion primarily scored neutrally or 

negatively. 

The Government Research Broker had the most model strengths across the future scenarios, 

followed by Innovation Campus, Anchor Tenant, and Fee for Service. While Matchmaker and 

Institute Network exhibited positive aspects, these models performed most favorably in future 

scenarios with well-established communities and markets. 

It is important to note that these scores are specific to the six models as currently defined, and 

the scores could (and likely would) change if the model definitions were to change. We 

understand that different NASA decision makers may prioritize some model evaluation criteria 

over others. While each model has strengths and weaknesses, no single model (in its current 

form) performs well across all criteria in all three future scenarios. To this end, we intend for 

the model comparison to be a useful process in identifying relative strengths of models to 

inform future decisions. 

A decision maker may seek a model that exhibits robustness to a set of unknown future 

scenarios, meaning the model is able to perform well in a variety of environments and 

ecosystems. In this case, the overall model strengths in Table 12 provide a good starting point. 

The Government Research Broker, with four model strengths, rises as a relatively robust option 

for the future, particularly in regard to meeting NASA’s needs, allowing for adaptability,

providing opportunities for collaboration, and providing equity and accessibility. 

64 
 

 

Table 12. Model Strengths Summary 

Model Model Evaluation Criteria 

 

Ability to 

Meet NASA’s 

Needs 

Adaptability 

Opportunity 

for 

Collaboration 

Market 

Sustainability 

Equity & 

Accessibility 

Current Model 

ISSNL N/A ✓ ✓

Future Model 

Trade Space 

1. Anchor Tenant ✓ ✓ 

2. Government Research 

Broker 

✓ ✓ ✓ ✓

3. Innovation Campus ✓ ✓

4. Matchmaker ✓

5. Institute Network 

6. Fee for Service ✓ ✓

✓ Marks an overall model strength across the future scenarios, meaning the model evaluation 

criteria received a Pro in at least two future scenarios. 

Mixing and Matching Models 

The models presented in this study are illustrative examples of means to pursue governmentfunded research, representing a wide trade space of options. No single model represents the 

path forward — the best performing model that meets leadership priorities is likely a 

combination of features from multiple models. NASA leadership can adjust models as desired 

to align closer to their priorities. As examples, the Anchor Tenant model can be expanded to 

include other agencies in prominent tenancy roles; the Government Research Broker model 

can use a contracted third party to serve as broker, rather than a NASA program office; and the 

Institute Network model can operate in a limited capacity until the LEO ecosystem is more fully 

established. 

The relative strengths and weakness of the example models evaluated in this study may help 

illustrate pathways for NASA leadership to tailor a future approach. The following are examples 

of ways models can be combined by mixing and matching different model aspects to account 

for scenario-driven or model-intrinsic shortfalls. 

65 
 

Anchor Tenant 

Strengthen by combining with aspects from Government Research Broker. 

The Anchor Tenant model has potential weaknesses in adaptability, market sustainability, and 

equity and accessibility. These weaknesses and possible concerns can be addressed through a 

blended approach that supports a primary CLD with options for tenancy on other platforms or 

by using orbital transport vehicles to augment activities, such as the concept in the Government 

Research Broker model. These modifications may increase cost, but they provide an 

opportunity to support a broader commercial market and to facilitate research from additional 

communities. Ultimately, a hybrid Anchor Tenant-Government Research Broker model could 

strike the appropriate balance in commitments (e.g., length of time, percentage of space, access 

to crew) among various persistent and transient platforms. In this optimization, the benefit to 

both industry and government is important to consider. 

Innovation Campus 

Strengthen by combining with aspects from Anchor Tenant, Government Research Broker, and 

Matchmaker. 

The challenges the Innovation Campus model has with adaptability, market sustainability, and 

accessibility are largely due to the model’s partial alignment with stakeholder needs. The utility 

of the campus could be enhanced by efforts to expand participation across the government and 

to enable pathways for industry to access campus resources. 

Additionally, the model needs to be combined with access to space and in-space platforms. An 

Innovation Campus can increase the utility of research through an Anchor Tenant model or 

ensure a robust pipeline for research within transport vehicles, like in the Government 

Research Broker model. The campus could also support a Matchmaker model, providing a 

terrestrial center of gravity for LEO activities. As appropriate, matchmaking functions provided 

through the Innovation Campus could be extended to orbital and microgravity platforms. 

Strengthen by combining with aspects from Institute Network. 

The Innovation Campus model was defined and evaluated with NASA as the sole government 

sponsor. However, like the Institute Network model, in which NASA and OGAs can jointly fund 

new institutes designed to meet their needs as well as the needs of their stakeholders, we note 

that the Innovation Campus model could benefit from interagency sponsorship. Adding other 

agency sponsors to the FFRDC or UARC-like model could not only amplify opportunity for 

interagency collaboration and enable whole-of-government coordination but could also 

broaden access for commercial and academic users seeking funding. By tapping into the 

interagency science and technology community and the “for the benefit of Earth” mission sets 

of federal agencies such as NSF, NIH, etc., a wider set of potential users may be reached and 

supported, furthering innovation. We encourage exploration of the feasibility of this 

66 
interagency concept as a means to reduce the financial burden of this model on NASA, provide 

greater access to diverse users, and stimulate interest from commercial users. 

Matchmaker 

Strengthen by combining with aspects from Anchor Tenant. 

In the Matchmaker model, a neutral third party directly and objectively connects users to 

platform providers based on mission and technical requirements. This matchmaker is designed 

to act on behalf of the government; however, successful implementation of this model requires 

the matchmaker to closely understand the government’s needs. A government program office, 

like the one in the Anchor Tenant model, working as a close partner to the matchmaker would 

help mitigate any disconnects. 

Institute Network 

Strengthen by combining with aspects from other institutes and related initiatives. 

The Institute Network model was defined in this work as a network of individual but related 

efforts specially focusing on commercial scaling and maintaining U.S. leadership. That said, we 

acknowledge that NASA and the broader government currently make many investments in 

diverse institutes and initiatives with unique focuses, including the Space Technology Research 

Institutes (STRIs), the Translational Research Institute for Space Health (TRISH), and Lunar 

Surface Innovation Initiative (LSII), to name a few. The Institute Network model would be best 

suited to consider how it fits in, builds upon, or adds something new to the current, established 

network of institutes that span LEO, lunar, and terrestrial topics. 

Fee for Service 

Strengthen by combining with aspects from ISSNL. 

Adopting a Fee for Service model reduces NASA’s, or any agency’s, ability to direct and 

strengthen a commercially driven model. However, economic policies may help channel 

commercial investment into areas that better meet NASA’s needs, enable collaboration across 

the government, and ensure accessibility. A focus on an incubation role as the Fee for Service 

model develops, similar to the current ISSNL-CASIS efforts with incubation, could help steer 

economic development towards capabilities needed for future missions. The U.S. government 

can also act as a “smart buyer” encouraging practices that promote equity and accessibility. 

67 
 

Considerations to Guide Model Selection 

Cost Considerations 

Although cost considerations are a critical driver for model selection, this analysis was not 

designed to provide definitive information on a cost comparison between models. To facilitate 

this cross-model comparison, separate detailed cost models and analysis will be necessary—

potentially one tailored for each considered model. In addition, discussions with stakeholders 

indicated that many of the primary cost drivers (such as transportation, platform use, and 

novel systems) are largely driven by the nature of the ecosystem, as exemplified in the future 

scenarios. That said, several observations on potential cost drivers were identified for each 

model, which may help facilitate follow-on studies and discussions of model cost. 

Anchor Tenant: The cost of the Anchor Tenant model is largely dependent on the degree to 

which a CLD provider requires support from NASA. If NASA accounts for the bulk of the CLD 

revenue, it would represent a substantial, long-term investment to maintain the model. To the 

degree that other users grow in activity, increasing revenue for the CLD, the reliance on NASA 

to cover ancillary costs associated with this model are reduced. 

Government Research Broker: Cost drivers for the Government Research Broker model 

include support for activities conducted on a CLD, similar to Anchor Tenant model costs, in 

addition to the unique research platform in the form of the transportation vehicle. The 

mechanism for funding the vehicle (e.g., long-term lease, pay-per-flight, retainer) is a unique 

factor when considering cost for this model. In addition, this model requires a government 

investment in a program office. 

Innovation Campus: A cost analysis for the Innovation Campus model will differ from the 

other models as the direct costs support a terrestrial campus. This investment may have a longterm impact on the cost to conduct activities in LEO through the transfer of knowledge and 

capabilities, but in the near term, this investment is likely additive to other costs associated 

with launching and conducting activities in the LEO ecosystem. 

Matchmaker: The Matchmaker model includes two factors that contribute to cost: funding to 

support the third-party matchmaker and the costs associated with conducting activities. 

Multiple potential mechanisms for supporting the third-party matchmaker exist, ranging from 

a direct contract with the nonprofit organization to a fee structure based on the transactions 

that occur. In developing the cost analysis, consideration should be given to the resulting 

incentives for the third-party matchmaker and alignment to NASA’s priorities for each 

potential funding mechanism. 

Institute Network: The cost of the Institute Network model is largely dependent on the scope 

and types of institutes within the network. To be successful, investment must come from 

commercial stakeholders in addition to public funding. As with terrestrial public-private 

68 
 

 

partnerships considered in the development of this model, the blend and nature of this 

investment varies. 

Fee for Service: Costs in the Fee for Service model represent a direct transition between the 

users and service or platform providers. However, NASA’s approach to data buys within this 

market might not be simplistic. The current commercial satellite data buy programs for Earth 

science have shown challenges negotiating with multiple companies on a bilateral basis and the 

premium associated with these contracts given NASA’s needs. Additional conversations with 

potential performers will be necessary to help characterize these data buy costs. 

Although we can’t provide a direct comparison of costs, this study does shed some light on the 

complexity of estimating costs for a model. Once the trade space of potential models is 

narrowed to a few explicit alternatives, a detailed cost assessment will be necessary to provide 

an accurate comparison. 

Legislative Considerations 

Congress routinely passes about two or three NASA Authorization Acts each decade, which 

partially guide the agency’s activities until the next act is passed. These acts contain directives 

regarding NASA’s efforts, including those in space exploration, scientific research, space 

technology development, and agency security. The acts reveal congressional opinion of what 

NASA’s priorities should be in the near future. The five most recent Authorization Acts—from 

2005, 2008, 2010, 2017, and 2022—provide an understanding of Congress’s vision for NASA in

recent years. All five acts include goals related to NASA’s role in LEO activities, namely the ISS. 

We summarize current ISS-related requirements in the most recent five Authorization Acts by 

four themes: ISSNL Management, Science and Technology Goals, Documentation and Reporting, 

and Creation of an ISSNL Advisory Committee. Each of the six assembled models require change 

to current legislation in two of the four grouped theme areas: ISSNL Management and Creation 

of an ISSNL Advisory Committee. The type and level of change required varies for each potential 

model. We recommend that NASA engage Congress early to propose the legislative changes 

necessary to enable a particular model. 

ISSNL Management 

Establishment and Operation of ISSNL 

The 2005 NASA Authorization Act designates the ISSNL on the U.S. segment of the ISS. This 

requirement is a significant consideration for the six assembled models regarding both 

language and intent. Legislative changes are required to enable any model because there will 

no longer be a National Laboratory on the ISS when the ISS retires and activities are 

transitioned to CLDs. The National Laboratory nomenclature may be completely removed from 

69 
 

 

 

legislation, or the intent of a National Laboratory may transition to a new model in a post-ISS 

LEO ecosystem that lacks a government-owned platform. 

Different aspects of each model could be designated as a National Laboratory in the post-ISS 

ecosystem if the National Laboratory nomenclature is deemed an appropriate name that 

reflects and reinforces the goals and objectives of the chosen model. Regulation around these 

determinations would need to be clarified in an upcoming Authorization Act. For example, in 

the Anchor Tenant model, the dedicated areas and individual segments or portions of these 

areas within the tenancy are designated a National Laboratory. In the Government Research 

Broker model, each research space is designated a National Laboratory or a collection of 

research spaces are designated a National Laboratory within orbital transport vehicles. In the 

Innovation Campus model, the terrestrial innovation campus is designated a National 

Laboratory. In the Matchmaker model, the suite of services provided to coordinate, facilitate, 

foster, support and aggregate is designated a National Laboratory. In the Institute Network 

model, the capabilities provided through the networked institutes are designated a National 

Laboratory. In the Fee for Service model, the collection of activities enabled by research grants 

and purchased data is designated a National Laboratory. 

Resource Split Between NASA and ISSNL 

The 2010 NASA Authorization Act allocates at least half of U.S. research resources on the ISS to 

ISSNL-managed experiments. The resource split equally between NASA- and ISSNL-managed 

activities is a concern for all six models. This requirement is overly restrictive and will become 

more so as NASA is no longer the sole overseer of U.S. LEO platforms. Legislative changes are 

required to enable any model. 

Cooperative Agreement 

The 2010 NASA Authorization Act designates that NASA enter into a cooperative agreement 

with a nonprofit, which is prohibited from engaging in any non-ISSNL activities. A cooperative 

agreement may be restrictive for all models by limiting the government’s ability to specify 

contracts that leverage the strengths and potential opportunities for any model. Additionally, 

prohibiting the ISSNL management entity from engaging in non-ISSNL activities may be 

problematic for the Institute Network model; this model relies on the ability of commercial 

companies to compete for contracts, so this particular attribute of congressional language 

would have to be rethought to ensure that this model could function as intended. If Congress 

applies the intent of a National Laboratory to CLDs, then legislative changes are required to 

fully enable any model. If Congress does not confer this intent, then this language should be 

removed completely. 

70 
 

 

Creation of an ISSNL Advisory Committee 

The 2008 NASA Authorization Act establishes the ISSNL Advisory Committee to advise 

utilization on the ISSNL. The ISSNL Advisory Committee was never established, but the User 

Advisory Committee was established following the IRT recommendations. Depending on the 

selected model of a National Laboratory in the post-ISS LEO ecosystem, this language regarding 

the ISSNL Advisory Committee should be revised or removed in alignment to governmentsponsored user community recommendations. 

See Appendix E: Legislative Changes to Enable Models for a detailed discussion of the status 

quo legislation, changes necessary to enable any of the models, and recently proposed changes 

to legislation from NASA’s Office of Legislative and Intergovernmental Affairs.

71 
Preparing for the ISS Transition 

To identify opportunities for modifying the current ISSNL-CASIS partnership in the near term, 

we leverage strengths from the ISSNL model and from the top-performing models. We identify 

four possible modifications to the ISSNL-CASIS partnership and NASA’s management of these 

activities. By implementing these modifications early, NASA increases the return from ISSNLCASIS in preparation for future models as one or more CLD replaces the ISS by 2030. NASA 

should engage Congress early to propose legislative changes necessary to pursue these 

modifications. 

1. Create a pathway for ISSNL-CASIS to access commercial platforms as 

they come online prior to the ISS transition and determine NASA’s role in 

brokering these relationships. 

Prior to the ISS transition, commercial platforms may include private modules attached to the 

ISS, private transport vehicles traveling to and from the ISS, and private orbital capsules or 

spacecraft with no platform destination. Expanding the list of possible LEO platforms available 

to ISSNL users could provide more flexibility, diversification of research, and amount of 

research conducted, by enabling research throughout a mission rather than just on the ISS, for 

example (similarly to how research vessels in Antarctica conduct research during all phases of 

travel). For users, this maximizes the use of time in the LEO environment, including during 

transit, and could exploit the unique environments of launch and reentry (e.g., g-loads, highaltitude access). Current non-NASA stakeholders may benefit from integrating research onto 

these platforms as they become available. For example, Axiom’s platform will become available 

prior to the transition. CASIS may consider identifying which of its users may benefit from 

either transitioning access to these platforms or expanding access to encompass both. 

Exploring this pathway may also drive standardization for interfaces among vehicles and help 

spur a market of ancillary services first for ISSNL-CASIS and then future CLDs. 

The contractual and legal feasibility of creating this pathway may need to be further explored. 

In implementing this modification, NASA may wish to consider mechanisms to purchase space 

on these commercial platforms on behalf of CASIS. Depending on the level of government 

oversight desired, NASA could be included in the pathway as a broker of relationships. The 

exact role of NASA, ranging from a more active facilitator to more passive stakeholder, may be 

guided by whichever longer-term model of facilitating activities is chosen. 

2. Elevate the ISSNL incubation role to support increased movement 

towards industrialization. 

The model analysis suggests pathways to grow the ISSNL incubation role to create scalable and 

repeatable operations that support industrialization—on the path to commercialization—and 

72 
 

sale of products or services. Incubation of potential commercial markets has been part of the 

ISSNL mission, and CASIS has seen growing demand from commercial research, technology 

demonstration, and in-space production applications. An even more expanded incubation role 

may contribute to market sustainability and to the adaptability of future models by increasing 

the diversity and quality of future services. It can also mitigate uncertainties in how platforms 

may evolve to support commercial needs. 

Providing additional support to advance early-stage technology developments—of mutual 

benefit to companies wishing to sell products and to CLD providers—may address barriers 

relevant to all parties. For example, in-space manufacturing has widespread interest within 

industry and as a use for CLDs, and therefore may benefit from more government backing prior 

to 2030 as well as beyond the ISS transition to CLDs. 

An expanded incubation role to support movement towards industrialization for 

manufacturing markets of interest may entail increased support to address relevant barriers to 

growth for the LEO economy, as identified in a previous report submitted under NASA’s

NextSTEP-2 Appendix J.

30 This will contribute to the ability of the government to ensure that 

CLD providers are set up for success, that the market will be better able to support diversity in 

activities, and that users will be able to focus on their R&D activities and secure financial 

backing needed to move towards industrialization. 

3. Establish a terrestrial innovation campus for microgravity research and 

development. 

A terrestrial campus provides a dedicated location for NASA to bring together stakeholders in 

the LEO ecosystem. For example, this campus could enable collaboration, connecting users with 

providers to drive market growth, increasing OGA participation in space research (e.g., NIH 

tissue-on-a-chip research), and providing a physical, virtual, or hybrid space for workforce 

development and academic exchange. This campus may be a co-located set of physical facilities 

and offices or an associated set of physical facilities and offices across the country. Visions for 

terrestrial labs are already in development within the commercial and academic sectors, such 

as the planned terrestrial analog of the George Washington Carver Science Park recently 

announced by Voyager Space to be located at The Ohio State University in Columbus, Ohio.

31 

As described, the innovation campus can provide support for a wide range of LEO activities that 

government agencies may want to pursue (see Appendix C). The campus helps prepare for 

maximizing quality microgravity R&D on future platforms by identifying research areas that 

can be prioritized in the near term. Some of these research areas have specific requirements—

precision manufacturing, for example—and would benefit from early identification during the 

development of future LEO platforms. 

By sponsoring an innovation campus before the retirement of the ISS, NASA will be able to 

establish processes and leverage existing expertise that support the nascent CLD ecosystem. 

73 
 

 

Specifically, this modification seeks to build upon, learn from, and coalesce the current 

successful pre- and post-flight activities on the ground, such as those conducted at CASIS’s 

facilities in Florida, the sites of the ISSNL IPs and CSPs, universities nationwide, and NASA 

Johnson Space Center, giving the nation a “center of gravity” for orbital and microgravity R&D 

and innovation. Establishing a terrestrial campus also provides the additional opportunity for 

NASA to investigate the feasibility of using an FFRDC or UARC type of relationship in any of the 

models. For example, NASA may learn whether an FFRDC on a leased commercial platform in 

orbit is possible and whether an FFRDC can have more than one government sponsor. 

4. Formulate a strategy for buying data from commercial providers. 

As more commercial offerings become available in the post-ISS LEO ecosystem, NASA, OGAs, 

and other users may look to purchase data products from companies to augment or 

complement their own datasets. These data products may come from sensors, experiments, 

technology maturation, or human subjects. Buying data from commercial providers could 

provide an agile, alternative approach to meet R&D needs. NASA’s Science Mission Directorate 

established the Commercial Smallsat Data Acquisition (CSDA) Program to identify, evaluate, 

and acquire data from commercial sources that support NASA's Earth science research and 

application goals.32 The CSDA began when companies started to amass Earth observation data 

relevant to NASA’s science goals. Similarly, CLDs and companies that perform activities on 

CLDs may amass data relevant to NASA’s exploration goals. 

To prepare for when exploration data may be purchased from companies to augment or 

complement NASA or OGA datasets, a strategy and an implementation plan are necessary. 

NASA and OGAs will need to continuously monitor the development of companies and acquire 

relevant data. Data that is favorably evaluated may be purchased for broad sustained use and 

disseminated among the U.S. government and to government-funded researchers. NASA can 

prepare now for purchases in an entirely new market by investigating legal and regulatory 

concerns, such as navigating intellectual property, privacy protection, and ethics of selling 

human data. NASA can continue to prepare now by leveraging lessons learned from the CSDA 

Program, such as establishing a pilot program to identify vendors and evaluate data, and 

standardizing end-user license agreements across the government to facilitate collaboration. 

74 
 

 

 

Additional Insights 

This section provides additional study insights identified during discussions with stakeholders 

and suggestions for follow-on studies. The insights and suggested studies are tangential to the 

scope of this effort; however, they further explore and refine some of the concepts reported in 

the previous sections. 

Consider the transportation ecosystem 

Launch costs were identified by several stakeholders as a critical barrier to the successful 

development of the identified models. As noted above we made assumptions about launch 

costs generally trending down, and without these trends the dynamic and possibly steady 

growth future scenarios may not be possible. In addition to costs, stakeholders noted the 

reliability of launch schedules and manifests, and the underrealized demand for downmass is 

impeding transition to a commercially driven ecosystem. The role of the government to 

continue to support this critical facet of the LEO infrastructure should be part of the post-ISS 

national lab strategy. 

Provide clear goals 

Several stakeholders noted that the success of NASA’s role in the future LEO ecosystem will 

depend, in part, on the agency’s ability to clearly define and communicate goals for LEO 

activities. It is necessary to understand how these goals integrate with the broader commercial, 

research, and exploration activities both on Earth and beyond LEO. If NASA’s Artemis 

Campaign and Moon to Mars initiative are blueprints for space exploration, should LEO be the 

blueprint for space commercialization? 

Consider the name 

The current ISS model uses the name “National Lab,” which immediately draws comparison to 

the DoE National Lab model. This connotation is confusing, given that the ISSNL varies 

significantly from the DoE National Lab model. When selecting a model, consider a name that 

reflects and reinforces the goals and objectives of the model. 

Consider level of government oversight as the LEO ecosystem grows 

Several stakeholders, both inside and outside NASA, recommended that NASA consider models 

that provide more near-term oversight to nurture the LEO ecosystem through its early stages. 

Stakeholders also acknowledged that as the LEO ecosystem grows over time, models with more 

government oversight may stifle growth; therefore, more flexible and scalable models may be 

needed to keep pace with demand. 

75 
 

Consider how platforms may evolve to support fewer, specialized activities 

Several stakeholders mentioned the uncertainty in how platforms may evolve to support 

differing activities, which may impact NASA’s ability to carry out research. When selecting a 

model, ensuring it can adapt as needed to major changes such as these can buffer against their 

uncertainties. 

Consider conducting follow-on studies 

Several more detailed studies were suggested by stakeholders and considered during this 

analysis. Ultimately, these studies were beyond the scope of this effort, but they would benefit 

NASA decision makers as they plan for the transition to one or more CLDs by 2030. These 

studies may be performed by NASA or any member of the stakeholder community. Specifically, 

suggested studies include: 

• Detailed cost assessments of considered models 

• Roadmaps for recommended models to adapt and evolve as the LEO ecosystem 

continues to grow beyond 2030 

• Interagency and international impact analyses 

• Legal and regulatory assessment of selected model(s) 

• Sensitivity analysis of model assumptions and their applicability to future scenarios 

outside the trade space we considered 

76 
Summary 

NASA is preparing for the retirement of the ISS and transition of LEO activities to one or more 

CLDs by 2030. NASA’s Commercial LEO Development Program has already awarded contracts 

to four primary commercial entities to work towards this transition.8,9 As NASA and other user 

communities continue to prepare for this transition, NASA and these communities need a plan 

for how to carry out government-funded activities in LEO post-ISS. Addressing this challenge 

also raises the question of how the current model of the ISSNL can evolve to support this 

transition. 

In light of these challenges, NASA senior leadership tasked OTPS with answering two 

questions: 1) what are potential models for an ISS National Lab facilitating government-funded 

or subsidized activities on a commercial LEO platform after the transition of the ISS to one or 

more private platforms, and 2) in light of these options, what modifications would be helpful to 

make in the current ISSNL-CASIS partnership and the NASA management processes as NASA 

plans for the transition of the ISS by 2030? 

To answer the first question, we conducted a stakeholder-driven analysis to identify a trade 

space of six differentiated model options. We then evaluated their performance in three 

potential future scenarios, according to evaluation criteria deemed important to stakeholders. 

The six models are illustrative and representational of a potential trade space. Additionally, 

each model requires change to current legislation related to the following: establishment and 

operation of the ISSNL, resource allocation split between NASA and the ISSNL, NASA-CASIS 

cooperative agreement, ISS longevity, and creation of an ISSNL advisory committee. To further 

aid in leadership decision-making, we provided considerations for how to strengthen each 

model by mixing and matching different model aspects. 

To answer the second question, we looked to strengths of the top-performing models to evolve 

the current ISSNL-CASIS relationship and improve NASA’s posture for success post-ISS. We 

identified four possible modifications to the ISSNL-CASIS partnership and NASA’s management

of these activities. 

• Create a pathway for ISSNL-CASIS to access commercial platforms as they come online 

prior to the ISS transition and determine NASA’s role in brokering these relationships.

• Elevate the ISSNL incubation role to support increased movement towards 

industrialization. 

• Establish a terrestrial innovation campus for microgravity research and development. 

• Formulate a strategy for buying data from commercial providers. 

By implementing these modifications early, NASA can increase the return from ISSNL-CASIS 

and help prepare for future models as one or more CLD replaces the ISS by 2030. 

77 
Appendix A: Insights from Stakeholders 

To better understand how the study results reflect the needs and experiences of the different 

stakeholders for LEO activities, this appendix highlights specific insights from conversations 

with members from four stakeholder groups: NASA, other government agencies (OGA), 

commercial, and academic and nonprofit. We talked to at least 10 representatives in each of the 

four stakeholder groups for broad representation of thought, on the topics of: 

• Views on the Future LEO Ecosystem 

• LEO Platform Activities and Priorities 

• Thoughts on NASA’s Role

• Potential Models and Mechanisms to Connect Users to Platform Providers 

• Model Evaluation Criteria 

• Challenges, Risks, and Concerns 

There was no consensus on the views around these topics even within stakeholder groups. In 

order to give the most comprehensive summary for each stakeholder group, similar comments 

were merged while conflicting comments were preserved into a final list of themes. Each of the 

themes is clarified with context and illustrated with paraphrased quotes from the stakeholders. 

Note that all included quotes are paraphrased for brevity and content. 

78 
Insights from NASA Stakeholders 

The NASA stakeholders we spoke to possessed expertise in commercial spaceflight, economics, 

and biological sciences, among other areas. Their perspectives ranged from research-oriented 

needs to those with a focus on growing the LEO ecosystem. Discussions covered views that 

spanned operations-related needs to strategic needs for the agency. 

We held discussions with 13 individuals within this stakeholder group. 

Views on the Future LEO Ecosystem 

Themes Context 

Some LEO studies have already been completed and are 

driving this community’s understanding of LEO’s future. 

Industry studies have already 

partially shaped opinions on 

future activities. 

The future of the LEO ecosystem will change as thinking 

develops with time. 

New decadal reports, arising 

market trends, and new 

technology capabilities in the near 

future will provide more 

guidance. 

Suborbital activities will continue to be a steppingstone 

for LEO, and LEO activities a steppingstone for longer 

duration missions beyond LEO. 

LEO activities can test crews for 

long-duration missions without a 

relatively complex logistical 

component. 

Quotes 

• “The decadal will drive future activities and represents a change in mentality regarding 

requesting resources necessary to do the most compelling science.”

• “There are several gaps that might be included in LEO activities: long missions, gravity 

transition missions, partial gravity simulators.”

• “We have the narrative of competition now, but there are trends toward monopolies.”

79 
LEO Platform Activities and Priorities Mentioned 

Themes Context 

Regular and reliable access to resources for research, 

chiefly money, is necessary. 

This allows for multi-year-long 

research, rather than the current 

short-term time scales on the ISS, 

and for more research initiatives. 

The market should be demand-driven and should have 

demand met at a reasonable level. 

Customers’ needs should be the 

motivation behind market-based 

planning and decisions. 

A significant focus on in-space manufacturing is 

important. 

Future in-space manufacturing is 

building on the success of NASA’s

In Space Production Applications 

and other efforts. 

Tourism could provide new opportunities. Once more established, tourism 

can be leveraged for additional 

datasets and platforms. 

Quotes 

• “For years, the Space Station was always a limiting resource for research. In a robust 

ecosystem, there will be lots of different opportunities and we can start thinking about 

research campaigns that span years; regular, reliable access is critical.”

• “Private money is opening opportunities. Having private astronaut data will 

significantly increase the size of datasets.”

• “If there is demand to fly a payload one should be able to find an opportunity to do so.”

80 
Thoughts on NASA’s Role

 

Themes Context 

NASA may have to be the only customer for CLDs at the 

beginning of the commercialization of LEO. 

While demand for LEO activities 

may fluctuate in the near future, 

NASA may temporarily be the 

sole customer for CLDs. 

NASA must maintain the opportunity for international 

engagement and diplomacy in LEO. 

Other space agencies should 

continue to have the opportunity 

to participate in LEO activities. 

NASA should adopt a role of “convener.” NASA could reduce barriers to 

entry and be a facilitator in 

convening different groups with 

similar interests. 

NASA should adopt the role of “protector.” NASA could be responsible for 

balancing and protecting the 

needs of customers. 

NASA should conduct knowledge transfer to industry 

players. 

Tools like the Commercial Crew 

and Cargo program and the CLD 

program help enable this transfer. 

Quotes 

• “We should be a facilitator and customer. If we lead, we will shackle commercial 

development.”

• “NASA has a strong brand and can be seen as a credible neutral party, which could lead 

to a ‘convener’ role.”

• “Our job is to knock down barriers and let people run in.”

81 
Potential Models and Mechanisms to Connect Users to Platform Providers 

 

Themes Context 

The nonprofit component of the National Lab model is 

generally ideal. 

Science and technology objectives 

can be achieved that the market 

would not be able to support, and 

this model has helped define 

demand for commercial groups 

for the ISS. 

NASA needs an alternative to the restrictions of the 

ISSNL cooperative agreement. 

Other types of contracts or grants 

may provide NASA with more 

flexibility. 

CLDs should offer variable services. To be profitable, each CLD will 

have its own business model and 

thus will go after different 

customers. 

A government platform would generally be 

counterproductive. 

Developing such a platform would 

hinder the development of 

commercial LEO and introduce 

the government as a competitor. 

Quotes 

• “In-space manufacturing is not a NASA requirement or goal; it needs a National Lab 

model like we have with CASIS.”

• “The National Lab model feels contrary to the desired ‘one of many’ approach. The 

National Lab is too top-down driven.”

• “Give commercial a hand to get going and have a clear handoff until they take over.”

82 
Model Evaluation Criteria 

 

Themes Context 

Opportunities for international consumers are 

necessary for a sizeable market. 

Models need to consider how to 

satisfy international demand, 

either directly through NASA’s

selected model or indirectly 

through the ecosystem. 

Non-NASA science needs must be addressed. Non-NASA research is crucial and 

could be addressed through a 

National Lab-type model. 

A model needs to have the ability to transition to 

multiple CLD customers, given that it originates with 

NASA as the only customer. 

Some of NASA’s past behavior

demonstrates a lack of followthrough when planning on 

creating a multi-customer 

marketplace. 

Quotes 

• “There might not be a one-size-fits-all mechanism.”

• “Everyone knows that NASA will be the anchor customer in the first few years.”

• “Companies need to understand the demand function. They need a consolidated demand 

signal, but that might not be NASA—maybe a nonprofit?”

83 
Challenges, Risks, and Concerns 

 

 

Themes Context 

A lack of collaboration and communication between the 

NASA, OGA, and commercial groups and their respective 

architectures is a concern. 

Currently, there is not much 

known about these architectures. 

Costs of maintaining a sustained crew and vehicle 

launch and return must be reduced. 

Having multiple launch and return 

providers and new capabilities, 

including rideshare opportunities, 

is critical to creating a robust LEO 

environment. 

The needs of CLD customers are as of yet unknown, so 

flexibility in NASA’s services will be a necessity. 

NASA should focus on creating 

baseline LEO capabilities to adapt 

to different commercial needs 

when they are realized. 

There is a lack of support for microgravity research. Current support is insufficient to 

maintain a campaign of research. 

Commercial flight companies may not have a demand 

for space stations in the long run. 

Alternatives, like SpaceX’s

Starship, could undermine the 

usefulness of space stations. 

Quotes 

• “The pipeline of research and technology will be overflowing but limited by 

transportation and cost.”

• “What you need may change in three years, but if you have a foundational capability 

that provides a standard for anything you want to do, you will be prepared.”

• “The workforce and support of the microgravity research community will be missing. I 

can see something like JPL with a cool campus and NASA funding microgravity 

problems.”

84 
Insights from OGA Stakeholders 

Several government agencies and other federal entities beyond NASA have a strong stake in the 

future of LEO. Discussions with this stakeholder group included discussions with NIH, NRL, 

AFRL, SDA (DoD), DOE, FAA, and NSF. Individuals at these organizations serve to accomplish 

their respective missions, but all have overlapping interest in the success of LEO 

commercialization. 

We held discussions with 10 individuals within this stakeholder group. 

Views on the Future LEO Ecosystem 

Themes Context 

OSAM will be necessary for the success of LEO activities. In-space assembly will be 

required for certain satellites 

currently in development. 

LEO can serve as a testbed for further exploration, like 

for future trips to the Moon and Mars. 

N/A 

LEO should be run by the commercial sector, while GEO 

is run by the government. 

The majority of efforts in some 

agencies lies specifically in GEO, 

leaving LEO to be developed by 

private groups. 

One main goal of the LEO ecosystem should be to 

improve conditions on Earth. 

LEO activities should have a 

partial objective of finding new 

discoveries in research, 

manufacturing, etc. that have 

Earth, not just space, applications. 

Quotes 

• “Test platforms and even transfer vehicles in LEO can provide easier access to 

experimentation for exploration beyond LEO.”

• “LEO should be a robust and competitive commercial sphere, with megaconstellations 

and multiple players invested in technological development.”

• “When we look at LEO, whatever occurs there has to benefit Earth. We have to make 

sure to have that focus.”

85 
LEO Platform Activities and Priorities Mentioned 

 

Themes Context 

Platforms should contain a broad range of experimental 

equipment and laboratory technology. 

Skilled scientists should have 

access to these resources at a 

justifiable cost. 

LEO should provide opportunities for new technology to 

be tested in space. 

LEO could be a test platform for 

many types of technology, 

including GEO electronics and 

experiments. 

Casual tourism should be considered for the far future. Likely would not be achievable in 

the 2030 timeframe. 

Certain current abilities that the ISS provides to OGAs 

need to be maintained by commercialized LEO. 

OGAs rely on services currently 

provided by the ISS that should 

persist beyond 2030. 

Transparent data publication of LEO laboratory 

activities should be provided. 

Increasing access to LEO data 

fosters innovation and 

development within the LEO 

ecosystem. 

Quotes 

• “Space activities are so rare that even showing that a technology works for a few hours 

is an accomplishment that LEO has a unique ability to prove.”

• “There should be something like the ‘iPhone development cycle’ where you’re frequently 

replacing devices to always have the best ones in operation.”

• “We currently have a good relationship with the ISS, as we routinely put payloads up 

there. We would need some way to maintain that ability in a post-ISS world, maybe with 

free flyers to get costs down.”

86 
Thoughts on NASA’s Role

 

Themes Context 

NASA should encourage and facilitate international 

collaboration. 

Other departments may not have 

the opportunities for 

international collaboration that 

NASA has, so NASA must be 

responsible for these 

partnerships. 

NASA should incorporate some aspect of diplomacy in 

LEO. 

Diplomacy on the ISS is something 

to be replicated. 

NASA should be involved with every facet of LEO, 

adopting the roles of “customer,” “leader,” and 

“facilitator.”

This structure would provide 

confidence in LEO and a common 

set of goals. 

NASA should adopt the role of “communicator.” NASA should renew a public 

interest in space. 

NASA should adopt the role of “coordinator.” NASA should help get 

experiments to space and provide 

guidance in the process of running 

an experiment. 

Quotes 

• “Continue the diplomacy in space necessitated by the ISS, even when it doesn’t correlate 

with maximum efficiency.”

• “International cooperation is a strength of NASA and is necessary to prevent ‘bad actors’

from targeting the platform.”

• “NASA’s role is to reinvigorate interest in space, like with JWST, which is something that 

other agencies can’t do.”

87 
Potential Models and Mechanisms to Connect Users to Platform Providers 

 

 

Themes Context 

A model like the ISS National Lab is necessary. The ISSNL model provides 

opportunities to government 

agencies outside of NASA and 

strengthens national capability. 

The ideal model is an infrastructure that is not owned 

by a single entity but that multiple parties rely on for 

operation. 

A cell phone tower is an analogy 

to this model, and NASA would 

need to compel companies to get 

payloads up to this “tower” and 

maintain them. 

There should be services offered by the government as 

well as private companies. 

A mix of services provided by 

government and companies 

enables differentiation within the 

ecosystem. 

Quotes 

• “Continuation of an intergovernmental laboratory such as ISSNL in the future of LEO is

critical, as its independence from NASA has provided unique resources and access.”

• “Think of postal services—there’s USPS, a government-run option, but also FedEx and 

UPS that provide different services. There’s room for more than one entity.”

• “We need to create a mechanism for connecting agencies and reducing the 

administrative hurdles.”

88 
Model Evaluation Criteria 

 

 

Themes Context 

LEO needs to provide a diversity of suppliers. Having multiple suppliers of 

multiple services is necessary. 

Opportunities on multiple commercial platforms must 

be centralized and screened for redundancy. 

Having platforms run by several 

smaller companies yields 

productivity but could be 

inefficient for government users. 

The cost of using LEO facilities should not be 

prohibitive. 

Ensuring that the barriers to entry 

for LEO opportunities are 

relatively low is essential. 

The new model should make getting to space easier and 

more accessible. 

LEO should become a universal 

payload-citizen science 

environment, similar to CubeSat 

“revolution.”

Quotes 

• “We work with FFRDCs and UARCs. The structure isn’t bad but it’s very personality

dependent. To be productive, organizations can’t be too big.”

• “Opportunities for facility use that are accessible outside of the space community are 

important and cannot be prohibitively expensive.”

• “A centralized model for proliferated platforms should ensure efficiencies and make sure 

that the value across the enterprise is not reduced.”

89 
Challenges, Risks, and Concerns 

 

Themes Context 

Reliable access to information on launches and returns 

is necessary. 

Launch and return information 

can affect a scientist's work, 

producing samples and 

subsequent timing. 

Not every LEO activity should be classified. Excessive bureaucracy and 

secrecy are concerns. 

There is a risk of a negative image of LEO if investments 

go wrong or do not produce results. 

Concern about the image of 

“wasting taxpayer dollars.” 

There is confusion over regulation and burdensome 

documentation requirements. 

Rules should be clarified, and 

documentation kept to a 

minimum. 

Ground-based astronomy could become obsolete due to 

light pollution and debris in LEO. 

NASA should explore ways to 

mitigate effects of these 

circumstances. 

Quotes 

• “Access to launch and to the lab are important as well; changing launch details causes 

upsets for experiments because it can take up to a year to have the right amount of 

[biological] cells to send into space. Ideally, we would always know the actual date in 

advance with a very low chance of that date shifting.”

• “Integration and launch capabilities should be simple, like getting on a train, instead of 

fraught with red tape, like getting on an airplane.”

• “There are burdens of the ‘extreme documentation’ needed for human space flight. 

There’s confusion about what the requirements are and how to go about proposing 

cross-agency collaboration.”

90 
Insights from Commercial Stakeholders 

Companies will be both providers and users of services in LEO. They will establish platforms to 

provide habitation, research, and manufacturing services, among other activities, and be 

customers of these services, depending on the company function. 

We held discussions with 10 individuals in this stakeholder group. 

Views on the Future LEO Ecosystem 

 

 

Themes Context 

The decommissioning of the ISS is a major inflection 

point for LEO. 

2030 is the timeframe when the 

ISS becomes politically and 

financially irrelevant. 

LEO commercialization will yield the emergence of new 

business models. 

There will be a new type of 

economy, similar to what 

occurred after the internet 

became widespread 

The new LEO economy will be much more similar to a 

terrestrial economy than a space economy. 

Terrestrial markets will move to 

space to increase profits, 

especially when related to space 

exploration or applications. 

The decommissioning of the ISS provides opportunities 

for ISS-related technology to be adapted to different or 

broader uses. 

The future market provides 

opportunities for technology 

currently only used for specific 

ISS-related tasks. 

Quotes 

• “From a LEO economy perspective, 2030 is an inflection point where there’s a change 

from government platforms to commercial platforms.”

• “Our plan is to continue to offer [what we currently offer], but with the demise of the ISS, 

we can be more than just that. We’re seeing what we can provide and what the market 

is looking for.”

• “We’re betting on the need for human space stations. Others are also banking on 

expanded operations in LEO. We’re seeing commercial needs.”

91 
LEO Platform Activities and Priorities Mentioned 

 

Themes Context 

There should be a focus on manufacturing and 

consumer-based services. 

Increasing manufacturing and 

consumer-based economies in 

LEO is an enabler for other 

activities. 

Tourism is a big market right now. Some activities may be more 

profitable in the future, but 

tourism is currently a profitable 

activity. 

Individual platforms will not be able to provide all types 

of services. 

CLDs will need to specialize to 

some degree. 

Activities should not need to have a human presence. Astronauts greatly increase 

expenses and do not add to the 

functioning of the ecosystem. 

Immediate focus should be on building infrastructure to 

support future needs. 

Doing so removes the need to try 

to predict what the LEO market 

will look like in the future. 

Quotes 

• “We see commercial needs. Things like tourism now, but also research-based and 

commercial-based operation, manufacturing, and more.”

• “Do you build your station for tourism or for science? People are seeking all of the above, 

but CLDs won’t be one-size-fits-all.”

• “...want to do research, manufacturing, film, commercials, etc. We see the need to be 

diverse because there’s so much uncertainty.”

92 
Thoughts on NASA’s Role

 

Themes Context 

NASA should be one of many customers. The LEO market should span 

business to government, business 

to business, and business to 

consumer. 

NASA’s role must fall between a provider and a user. NASA has a role as a customer of 

LEO services and facilitator of 

other users accessing those 

services. 

NASA has an opportunity to show confidence in U.S. 

CLDs, which would encourage international partners to 

invest in them. 

NASA should do so as soon as 

possible. 

NASA should maintain international partnerships to 

maintain U.S. leadership in space. 

NASA can do so through 

agreements and buying seats on 

U.S. commercial flights to 

encourage other countries to buy 

seats as well. 

NASA should find a way to share existing knowledge 

with industry groups engaging with LEO for the first 

time. 

The lessons learned and data that 

NASA has collected should be 

offered to companies. 

Funding from NASA provides confidence in commercial 

projects. 

With NASA’s approval, companies 

may be less nervous about their 

ability to attract investors and 

customers. 

93 
Thoughts on NASA’s Role

Quotes 

• “NASA can't use the resources of commercial companies and still exercise ownership 

over the equipment. If NASA is a partial owner, there needs to be a clear standard 

regarding what NASA pays for.”

• “Without intentional leadership from NASA, international engagement and investment 

decreases.”

• “The NASA seal of approval is huge.”

94 
Potential Models and Mechanisms to Connect Users to Platform Providers 

 

Themes Context 

NASA should employ an anchor tenant model. This model is flexible enough to 

be able to meet the needs of many 

customers. 

NASA should not employ the anchor tenant model. Using an anchor tenant model 

would not allow for the necessary 

shift from R&D to a full ecosystem. 

A business park model is the best option for customers. The business park model would 

allow customers to experiment 

with activities while remaining 

stable. 

There are many questions with a “space hotel” model. Logistical questions arise, like 

would the CLD provide astronauts 

with lunch, or just give them 

access to the kitchen? Is NASA cocreating the experience or just 

receiving services? 

Quotes 

• “NASA continuing to act like an anchor tenant for maintenance is more important than 

the percentage of business that they provide, for the sake of consistency.”

• “The anchor tenant model is essential to kicking off a business park model for a CLD.”

• “The model of the business park is fundamental to success.”

• “Commercial entities have gone through CASIS for access, but we hope to have channels

where they can come directly to us. However, setting up independent relations with all 

agencies becomes cumbersome.”

95 
Model Evaluation Criteria 

 

 

Themes Context 

Ecosystem architecture should be flexible enough to 

sustain varied commercial demand. 

Diversity of capabilities could 

combat uncertainty. 

NASA should be “buying time.” Contracts with NASA should be 

based on time periods, not 

deliverables. 

It should be easy for customers to switch between 

service providers. 

Companies should not have to set 

up independent relationships 

with every provider. 

Other government agencies should have opportunities 

to participate in LEO activities. 

Agencies like NSF and NIH as 

customers will make LEO a 

broader market. 

If NASA wants to be a customer in the long term, the 

chosen model should be flexible enough to allow a 

transition from NASA to the Department of Commerce. 

If the government wants to be one 

of many customers, the 

Department of Commerce needs 

to take lead on the customer and 

economic development 

components. 

Quotes 

• “The single most important thing is flexibility of the architecture.”

• “Commerce will need to have the resources to take over NASA’s position as customer, 

which it doesn’t right now. For NASA to try to recreate Commerce’s role would be an

inefficient use of the government’s efforts and of NASA’s expertise.”

• “Consider cost-sharing and substantiating the market for certain areas. Flexibility is 

key.”

96 
Challenges, Risks, and Concerns 

Themes Context 

It will be difficult for customers to understand what CLD 

features will be available when. 

Early, publicized capabilities for 

the post-ISS transition could solve 

this problem. 

Providing robust data services to customers will be 

critical. 

To be successful, LEO needs to 

address logistical delays. There is 

an expectation in the broader 

economy that users can get their 

data on demand. 

There should be consideration for an astronaut crew 

dedicated to maintenance. 

Astronauts would have more time 

for experiments if there were a 

crew on board for maintenance, 

which is a current burden on the 

ISS. 

There is confusion about insurance logistics for CLDs. It is unclear if the government 

needs to be involved and if 

government astronauts need to be 

insured. 

There is a growing worry over not having a specific 

point of contact in the government for mission 

authorization. 

The government needs to be 

specific about what requirements 

providers are working towards 

and who can sign off on them. 

NASA’s small business and university programs are 

slow to provide funding. 

The funding cycle doesn’t align

with small business or a growing 

economy. 

Time between the retirement of the ISS and the start of 

use of CLDs needs to be minimized. 

Opportunities scientifically and 

commercially will be lost without 

a continued presence in LEO. 

97 
Challenges, Risks, and Concerns 

Quotes 

• “There’s uncertainty about what the transition model will look like. Will the ISS coexist 

with a CLD for a period, and will someone be allowed to choose to put a payload on a 

CLD at that point, or does the ISS take priority?”

• “There is no shortage of programs to support universities, institutions, and small 

businesses. All of them are very slow. SBIR takes years. NIAC is great but things are 10 

years down the road.”

• “We cannot have a space station gap. We need to make sure there’s a continual presence

in LEO. A single year gap in a space station could have a decades long impact in the 

research pipelines we’re seeing.”

• “I worry about the timeframes of NASA moving in these directions. An ISS replacement 

would take years to develop, realistically. We must find a way to replace those critical 

items—whether crew capsules, facilities within ISS—and finding temporary fixes to 

overcome gaps now.”

98 
Insights from Academic and Nonprofit Stakeholders 

This research community includes both universities and research-focused nonprofits. Those 

with an academic interest in LEO research determine the ways in which science priorities are 

tangibly realized on LEO platforms and thus are significant users and facilitators of CLD 

platforms. 

We held discussions with 10 individuals in this stakeholder group. 

Views on the Future LEO Ecosystem 

 

 

Themes Context 

There will be multiple platforms that are a mix of 

commercial- and government-run. 

Even if the U.S. government does 

not have a strong LEO presence, 

foreign governments likely will. 

By 2030, the LEO ecosystem will be dominated by 

industry. 

Current private sector 

investments are growing, and the 

ecosystem will be driven by the 

private sector after the retirement 

of the ISS. 

The two major stakeholders in LEO will be commercial 

and research. 

The commercial sector is driven 

by profit and the research sector 

is driven by discovery. 

The LEO ecosystem will fill the role of the current ISSNL, 

providing opportunities in R&D for technology. 

The activities currently provided 

by the ISSNL will be available 

across the LEO ecosystem. 

Quotes 

• “There are several other governments that have expressed interest in having a presence 

in LEO, whether that’s flying astronauts or doing science.”

• “We’re seeing a proliferation of the private sector, which I see continuing. By 2030, I 

think that transition will be complete, leading to an ecosystem that's run by the private 

sector.”

• “The days of NASA being the primary driver in LEO are gone. NASA doesn’t have to be 

primary driver and can focus resources elsewhere, like the Moon.”

99 
LEO Platform Activities and Priorities Mentioned 

Themes Context 

Academic LEO science needs to remain a priority in LEO. Science needs funding from NASA 

because commercial business 

models won’t fund it. 

Tourism alone will not provide enough customers for 

businesses to invest in LEO. 

Regardless, LEO tourism should 

be pursued. 

Platforms for science should have specific focuses. Research in LEO should move 

away from multipurpose to 

single-purpose facilities to enable 

specialization and reduce 

redundancy 

CLDs should have a diversity of capabilities. One question is how to ensure this 

variety in capabilities. 

Quotes 

• “If there aren’t low-cost opportunities, there will be no opportunity for academia to 

participate.”

• “As we move closer to 2030, I think there’s going to be a renewed focus on science 

facilities that are more purpose-built and less multipurpose, which tend to not satisfy 

anyone completely.”

• “There’s an opportunity for industry and research partners to develop larger 

instrumentation techniques to see how things like additive manufacturing in 

microgravity would work in LEO.”

100 
Thoughts on NASA’s Role

 

 

 

Themes Context 

NASA should be a customer and provide other means of 

making profit in LEO. 

NASA will need to bolster 

commercial efforts to maintain 

industry investment in LEO. 

NASA should provide microgravity environment 

training to private astronauts. 

Doing so will be cheaper than 

current training practices. 

NASA needs to provide funding to academic users for 

LEO science or subsidize it. 

Grants currently supporting 

academic research do not account 

for launch costs, and NASA will 

need to continue or transfer this 

subsidy cost. 

NASA should adopt the role of “convener.” NASA could bring multiple, less 

funded organizations together to 

bolster U.S. presence in LEO 

science. 

NASA should adopt the responsibility of space 

environment management. 

There is not a single entity with 

this responsibility right now, and 

the danger of a lack of regulation 

will increase. 

Quotes 

• “NASA could be a funding agency driving the research interests, especially in the 

academic community, as they understand the realistic costs of sending a payload to a 

platform.”

• “NASA could drive the market, but I don’t think they’re going to control it.”

• “The LEO environment is only going to get more complicated with more satellites and 

debris. That could and should be a role for NASA to step in.”

• “NASA can’t move at the pace that a private sector wants to innovate.”

101 
Potential Models and Mechanisms to Connect Users to Platform Providers 

Themes Context 

A single body to vet and choose experiments from the 

research community is necessary. 

This could be CASIS or something 

similar. 

A body needs to coordinate launch schedules and 

logistics. 

N/A 

NASA could provide mission requirements and accept 

bids. 

This is similar to DoD’s Space 

Enterprise Consortium and 

bandwidth auctions. 

DoE’s Management and Operations contract model 

could provide a good blueprint. 

This model includes metrics to 

evaluate work. 

An anchor tenant model should be considered. NASA can use an anchor tenant 

model to transfer best practices to 

industry. 

Quotes 

• “NASA is not universally sold on the idea of handing things off to industry.”

• “I hope the government will continue to take a role in research, because when we turn 

that over to the private sector, it tends to languish.”

• “An anchor tenant model comes with NASA best practices that can help lead industry to 

develop their own best practices.”

102 
Model Evaluation Criteria 

 

 

 

Themes Context 

The research community needs adequate access to all 

sizes of payloads. 

There are currently not many 

opportunities for academic users 

to run large experiments. 

The first model should serve as an incubator for 

industry. 

The government should provide 

an incubator function to 

encourage industrialization. 

Nonprofit entities should not compete with the 

government in any model. 

The current split of CASIS and 

NASA work creates an artificial 

divide in research areas that both 

NASA and other stakeholders 

need. 

Any agreements between the government and 

nonprofits should be less restrictive than the current 

cooperative agreement. 

The current agreement obstructs 

what both NASA and CASIS can 

do. 

Research groups should be able to pick between 

platforms for their research. 

There needs to be enough 

differentiation for platform 

selection to be driven by science 

needs. 

Quotes 

• “Having a single managing organization like CASIS is not sustainable.”

• “The thing that’s missing is industrialization, which is how we take technology from the 

laboratory to something we can do at scale where we can make product and make 

money.”

• “You might have heard the idea that ISSNL competes with the BPS division of SMD, and 

that's a problem. Why would a national laboratory that works through NASA be 

competing with its parent sponsor?”

103 
Challenges, Risks, and Concerns 

Themes Context 

There is a desire for consistent and thorough safety 

inspections. 

A single entity is needed to be 

responsible for safety; this could 

be made up of NASA and FAA. 

Launch costs are a constraint. Regardless of the model, launches 

are expensive and may not be 

worth pursuing if potential for 

profit is not large enough. 

Human presence on research platforms can be harmful. Human interaction with a 

platform could disrupt research 

processes. 

Academic users will need guidance on how to 

successfully run an experiment on LEO platforms. 

Industry will have more resources 

than nonprofits or universities to 

figure out logistics. 

Current congressional authorization language allows for 

only ISSNL work on the ISS. 

Language needs to be updated to 

include platforms beyond the ISS. 

Workforce development is crucial for a sustainable CLD 

environment. 

Rotational internship programs or 

something similar could be a good 

means to do so. 

CLDs will not be able to provide the necessary large 

scale of manufacturing. 

One solution could be to have a 

platform dedicated to only 

manufacturing, with no research 

component. 

104 
Challenges, Risks, and Concerns 

 

Quotes 

• “Having humans on the platform creates all kinds of vibrations and noise that may not 

be conducive to good experimental results.”

• “NASA has to make equitable opportunities for research interests. Principal 

Investigators won’t be able to figure out which platforms are available or how to use 

them. How can they figure these things out?”

• “Scientific communities should have conversations with CLD providers to make sure 

their needs are met.”

105 
Appendix B: Scenario Narratives 

This section describes three future scenarios that inform the scoring of the models and the 

model recommendations: 

• Dynamic Growth 

• Steady Growth 

• Limited Growth 

These scenarios represent the three possible futures that we anticipate for the LEO ecosystem 

in the 2030s after the retirement of the ISS. The future scenarios are used as a tool to frame the 

analysis for model performance rather than serving as a prediction of the future LEO 

ecosystem. For each future scenario, we list its defining characteristics, provide a summary 

overview, describe the primary limitations and opportunities of the future scenario, and 

describe the anticipated outlook for each user community in the LEO ecosystem: science and 

academic users, OGAs, international partners, commercial organizations, and NASA. 

Note that rather than representing distinct futures only, the future of the LEO ecosystem may 

see more than one of these future scenarios occur over time, or any number of other potential 

scenarios, as the ecosystem evolves. The future trajectory of the ecosystem may also expand or 

contract resulting in multiple platforms or smaller, reconfigurable sorties. 

106 
 

 

Dynamic Growth Scenario 

Key Characteristics 

• Flexible 

• Diverse 

• Accessible 

• Affordable 

• Robust 

• Tailored 

• Exciting 

Dynamic Growth 

Successful commercial markets 

spur innovation and capital 

investment. Characterized by: 

• Multiple platforms 

• Diversified commercial services 

with niche offerings 

• Influx of venture capital 

• Complex, difficult to navigate 

unaided 

Overview 

NASA’s investments in the CLD Space Act Agreement 

have ignited new LEO markets and investments. Early 

successes resulted in increased venture capital 

investment and accelerated interest in using and visiting LEO. 

Multiple, diversified services and activities span multiple providers. Possibly one single 

exquisite facility supports the activities, but more likely, several CLDs and reusable vehicles 

compete for user demand, which has expanded in both number of users and variety of demand. 

In addition to science, human exploration research, and technology demonstration, space 

tourism has grown significantly, and on-orbit manufacturing is an established market. 

Lower launch costs and greater accessibility enable new business models, with new and 

improved offerings available every few years. These new business models increase flexibility 

and enable providers to tailor LEO platform services to specific users. 

Limitations 

Some activities, such as partial gravity or testing of nuclear technologies, may not be available 

through commercial services. Overall, NASA can meet its mission needs and, depending on 

which model it adopts, can maintain a strong presence in LEO. 

The rapid growth and diversity of services and activities create challenges for regulating LEO 

activities. Debris is a growing problem. A lack of internationally recognized standards or “rules 

of the road” increase the risk to LEO assets and human life. The rapid growth of manufacturing

and pharmaceutical production in LEO raises concerns about ensuring quality and certifying 

authentic products. 

Opportunities 

The co-development of transportation for LEO entry and return has reduced launch costs and 

increased the number and variety of LEO access options. Users can choose among multiple 

options for returning payloads, including specialized services for cryogenically cooled or lowvibration payloads. Although space tourism remains limited to a wealthy elite, newly available 

107 
 

on-orbit habitats increase tourism options and the growing market aspires to lower costs and 

thereby increase access for future tourists. In addition to physical access, providers have 

expanded virtual networks in LEO, enabling realistic virtual access to users across the planet. 

This democratization of LEO ensures continued societal interest in space and promises 

continued growth. 

Outlook for User Communities 

Science and Academic Users: Scientists have more opportunities to directly access their 

experiments. Moreover, results and payloads can rapidly be sent and returned from LEO, which 

increases returns from scientific projects and enables campaigns of scientific investment rather 

than one-off experiments. Applied science with commercial value dominates due to private 

investment. Researchers may have multiple platforms and providers to choose from or may 

seek to use a dedicated premier laboratory, depending on the models adopted by NASA, OGAs, 

or other nation’s space agencies.

Other Government Agencies: LEO is an important technology test bed for DoD. However, 

security restrictions, as well as security concerns rising from the increased number of LEO 

users, limit activities on commercial platforms to early technology demonstrations. DoD may 

use a separate, mission-focused platform. Other research agencies like NSF, NIH, and 

Department of Agriculture follow NASA’s lead and leverage the mechanisms that NASA sets up.

The degree of activity for these agencies varies by the ease and cost of these mechanisms. 

International Partners: Although NASA’s investment resulted in a favorable position for U.S. 

commercial companies, other nations are active in LEO. Foreign LEO platforms are in 

development and reusable spacecraft have been proposed. However, a U.S. competitive 

advantage exists, and many space agencies are interested in working with the United States 

through NASA or with the companies directly. Avenues to accessing U.S. capabilities in LEO are 

highly dependent on the model NASA adopts but include a range from government-togovernment, government-to-industry, and industry-to-industry agreements. 

Commercial: Industry uses LEO for a range of activities, from manufacturing to satellite 

servicing to tourism. The success of prior ventures and an influx of venture capital allow 

commercial companies to experiment with different business models and services. 

NASA: The level of activity in LEO benefits NASA greatly, with low-cost services covering most 

of the agency’s research and technology demonstration needs. However, no longer the primary

customer for LEO access and services, NASA must adapt to commercial timetables and accept 

less control over launches. Opportunities for a dedicated long-term platform are fewer and 

significantly more expensive than payloads on a shared platform.21 Some activities, such as 

partial gravity or testing of nuclear technologies, may not be available through commercial 

services. Overall, NASA can meet its mission needs and, depending on which model it adopts, 

can maintain a strong presence in LEO. 

108 
Steady Growth Scenario 

Key Characteristics 

• Stable 

• Quasi-flexible 

• Enabling 

• Inspirational 

• Hopeful 

• Attainable 

Steady Growth 

Moderate market growth akin to 

the status quo—slow but steady. 

Characterized by: 

• One platform, or multiple small 

similar platforms 

• Lack of diversity in activities 

• Prioritization of limited space 

• Some organic commercial 

market developments 

• Common focus across 

stakeholder groups 

Overview 

This post-ISS scenario is akin to the status quo. With 

moderate development of the LEO ecosystem, both 

users and providers continue to increase, though at a 

slow pace. Whether one platform or multiple small 

platforms are available, the range of services and 

activities is not diversified. 

NASA has sufficient access to LEO and LEO infrastructure to meet its primary needs. Other user 

communities are somewhat more limited, because commercial services remain generalized. 

Commercial companies lack sufficient development and private investment to offer 

specialization. Despite these limitations, LEO continues to be a symbol of collaboration and an 

international playing ground. 

Limitations 

Although cost to access space is lower than today’s standards, the cost is still high enough to 

hinder market development, leaving providers to rely more heavily on government customers. 

Partnerships with government agencies might lower cost to access for some commercial 

customers. 

The top-priority commercial markets are those with the greatest likelihood for generating the 

highest revenue, so most scientific research accesses space through NASA mechanisms only. 

Due to volume and mass restrictions on launches and platforms, technology development is 

limited to the highest priority activities. 

Opportunities 

LEO remains a destination of geopolitical benefit to the United States. With steady, gradual 

growth in LEO activities, customers across domains and nations continue pursuing synergies 

and partnerships with the U.S. government and any active U.S. commercial providers. The 

current pace of technology development continues. 

109 
 

Having enabled at least one commercial platform, early risk reduction activities, especially in 

financial risk, have given some confidence to investors, suggesting a potential for unanticipated 

market growth. 

Outlook for User Communities 

Science and Academic Users: Similar to today, LEO is a destination for scientific research 

across disciplines. Engagement from academia remains strong, especially in support of 

research for human exploration missions. The design of the LEO platform(s) is flexible enough 

to incorporate most instruments identified as high priority, including state-of-the-art sensing 

and observation instruments. With real-time data downlinks and high-speed video 

transmission, scientists can adjust experiments in real time, achieving greater efficiencies and 

outputs. Continued opportunities for involvement in scientific research in LEO inspires 

students of all levels across the United States. 

Other Government Agencies: Because costs to access LEO are not much lower than costs 

today, government agencies limit their participation to top-priority activities, as determined by 

National strategies and NASA’s research needs.

International Partners: Nations who partnered with NASA on ISS may continue to work 

directly with NASA on commercial LEO platform(s). Less volume is available than on ISS, so 

nations may partner with other government platforms or develop plans to access LEO 

themselves to maintain momentum. Barter agreements between partnering nations are 

possible if the agreement benefits both parties. As such, major space-faring nations might rebalance bartering tools between governments involved in LEO. Depending on the model, NASA 

may benefit from maintaining accessibility and flexibility for international partners. Emerging 

space-faring nations may view partnering opportunities with NASA differently than nations 

who previously partnered on ISS. Emerging international partners might prioritize accessibility 

and strategic value when considering different partnership opportunities with NASA. 

Commercial: From the early efforts to commercialize LEO to the 2030s, industry experiences 

rises and falls in demand and investment. Services such as orbital tourism and flying 

commercial or government astronauts have enough demand to be a reliable revenue stream. 

Activities with less demand, such as advanced and additive manufacturing, vary in terms of 

progress and profitability. Rather than catering to diverse services and activities, commercial 

companies might dedicate individual platforms to one type of service or activity, which then 

develops that market area further. 

NASA: Though NASA might have to prioritize some needs, it can accomplish its goals in LEO for 

exploration missions. NASA uses insights from the Commercial Crew Program to adjust to 

unexpected outcomes in services or activities. Efforts to provide dissimilar redundancy for 

cases where NASA’s mission cannot be accomplished without access to LEO remain an option

for any major unmet needs. 

110 
 

Limited Growth Scenario 

Key Characteristics 

• Restricted 

• Inflexible 

• Focused 

• NASA-centric 

• Needs-based 

• Undeveloped 

Limited Growth 

Lack of mature commercial 

platforms and limited 

opportunities. Characterized by: 

• Single CLD in development with 

NASA monopsony 

• High cost to close NASA gaps 

• Focus on prioritized, strategic 

activities 

Overview 

Despite NASA’s efforts to develop the U.S. LEO 

commercial market, commercial providers have not 

been able to survive the costs of entry, and expected 

markets failed to materialize. Investors have pulled 

out, leaving providers unable to buy down risks and mature technologies. 

Therefore, after the recent retirement of the ISS, the U.S. has limited access to LEO. One CLD is 

operational and can host research but in a much more limited capacity than on the ISS. Users, 

including NASA, fly only their highest priority needs. Other users seek means of continuing 

activities in microgravity without using a LEO platform. 

Geopolitical dynamics are shifting. China likely continues to operate its station and expresses 

interest in attracting new partnerships, including with other spacefaring nations. As the U.S. 

shifts attention to the Moon and Mars, it cedes some geopolitical benefit of LEO to China and 

others. 

Limitations 

NASA has low flexibility for activities in LEO. Only the most strategic technology development 

can continue. NASA may consider other means to ensure that mission-critical work can 

continue for Moon and Mars exploration missions. Ensuring dissimilar redundancy may allow 

for more needs to be met, such as pursuing a crewed or uncrewed orbital vehicle such as 

Dragon or Dream Chaser. 

Opportunities 

Some residual momentum from the commercial LEO market is transferred to new 

partnerships, potentially with other nations. 

NASA can redirect resources from sustaining a laboratory and testbed in LEO toward other 

research activities and exploration missions. 

111 
 

 

Outlook for User Communities 

Science and Academic Users: Academic institutions in the United States have significantly 

fewer opportunities to access LEO. Where possible, academic users will largely shift to 

suborbital research, ground analogs, and drop towers. Science in support of human research 

(e.g., for long-duration missions) is prioritized due to the limited volume and accessibility of 

LEO platforms. 

OGAs: Most government agencies cannot justify the cost unless specifically tied in through a 

partnership with NASA in support of joint programmatic goals. DoD may consider pursuing its 

own platform. 

International Partners: International partnerships with NASA in LEO have shifted to either 

those in support of Artemis or those reserved for diplomatic reasons. The Chinese space station 

has enough volume to host experiments and astronauts; other nations therefore look to China 

to continue research in LEO. With NASA’s efforts in cis-lunar space and only one CLD in 

development, dynamics have shifted with respect to nations’ roles in LEO.

Commercial: Commercial activities are limited, though the range of activities that can be 

prioritized is high. The inability to mature many technologies leaves more to be done. Some 

commercial research critical for Moon and Mars exploration is prioritized, but a lack of private 

investors leads to a heavier reliance on government. 

NASA: Though the agency planned for a prioritization of activities critical for Moon and Mars 

exploration, these goals suffer schedule impacts due to limited opportunities in LEO. 

Specifically, crewed missions to Mars are pushed back significantly. Long-duration lunar 

surface missions also have some delay, as constraints in LEO have slowed the development of 

technologies needed for safe operations outside Earth’s safety net. Schedule impacts to Moon

and Mars can potentially be buffered by planning for dissimilar redundancy (e.g., uncrewed or 

crewed orbital vehicles to continue mission-critical research in addition to the CLD in 

development). NASA can carry only its highest priority needs. 

112 
 

 

Appendix C: Future LEO Activities 

To inform the future scenarios, we looked at what activities may be available in the post-ISS 

LEO ecosystem and how they might vary across future scenarios. This assessment is based on 

existing literature, including the NASA Quantifying Demand22 white paper, and discussions 

with stakeholders, which are summarized in Appendix A: Insights from Stakeholders. 

For each future scenario, we assume that some activities are covered by non-NASA entities, 

primarily by commercial partners. Activities that are not covered by non-NASA entities are 

identified as having potential for government funding. These activities cover a wide range and 

some may necessitate or be better suited to human presence and tending, while others may be 

performed on autonomous, robotic uncrewed platforms. 

From the future scenarios, several key factors drive what activities are available. 

• In the dynamic growth scenario, there is a proliferation of users, activities, and services in 

LEO. Activities are not restricted by platform volume and opportunities exist for most 

conceivable activities. 

• In the limited growth scenario, commercial services have not fully materialized, and a 

single permanent platform still in development comes with volume restrictions. 

Generally, the number of services increases as the LEO ecosystem grows. In the dynamic 

growth future scenario, markets can sufficiently sustain activities and industry is less reliant on 

the government. The government may purchase any of the listed activities as a service. In the 

steady growth future scenario, available activities center around platform operations and more 

generalized services. In the limited growth future scenario, there are fewer options available to 

purchase. With limited market growth, industry focuses on generalized services. 

After identifying what may be available for the government to purchase, we looked at how the 

government may prioritize the activities. 

As seen in Table 13 below, the types of activities and their focus shift across future scenarios. 

Each future scenario contains details that impact the importance of activities to NASA and 

other government stakeholders. For example, when markets are not mature, as in the limited 

growth future scenario, the government has more opportunity to stimulate various markets. As 

markets mature, however, increased commercial services allow the government to invest in 

more niche applications and buy mature systems and technologies from the market. Some 

activities (e.g., crew training or systems demonstration) remain split between commercial 

services and government investment. We considered the mixture of activities within each 

future scenario when evaluating the models. 

See Table 13 for the summarized listing and characterization of future LEO activities. We 

assembled this information from the extensive literature review and stakeholder discussions. 

The table includes check marks (✓) for demanded activities that are in scope for government 

113 
support and a cross () to denote activities that are out of scope for government support. In 

future scenarios where there is significantly more (✓+) or less (✓-), demand for government 

support modified which checkmarks are used. Finally, shading indicates commercial services 

can likely satisfy some or all demand for these activities. For the latest estimates on quantified 

demand (that is the number of projects or crew trips per year) that may be considered for the 

steady growth future scenario, we refer the reader to the 2019 white paper on Forecasting 

Future NASA Demand in Low-Earth Orbit: Revision Two – Quantifying Demand, the 2022 ISS 

Transition Report, the 2022 In-Space Production (InSPA) plans, and the 2023 Request for 

Information for future Commercial LEO Destinations – Concept Operations and 

Utilization.

22,5,33,4,34 The various documents provide estimates for future LEO activities by 

considering historical needs from the NASA Mission Directorates, NASA programs such as the 

NASA Human Research Program, and the ISSNL. 

The key takeaway remains that government priorities shift across future scenarios, since what 

is readily available also shifts. These shifts are not linear, and they can impact model 

performance across future scenarios. We took this into account in our model assessment. 

114 
 

 

 

 

Table 13. NASA and National Priorities for Future LEO Activities. 

Government demand and commercial supply are expected to vary across future scenarios. Expected government 

demand is indicated by ✓. Expected change in government demand as compared to the steady growth scenario is 

indicated by more (+) or less (-). No expected government demand is indicated by . Commercial supply is 

indicated by shading. 

LEO Activity Description 

Future Growth Scenario 

Dynamic Steady Limited 

Education 

STEM Engagement Science, Technology, Engineering, 

and Math (STEM) Engagement 

✓+ ✓ ✓-

Science & Research 

Human Research Addressing radiation, isolation and 

confinement, distance from Earth, 

altered gravity, and extreme 

environments 

✓+ ✓ ✓-

Biological (Life) 

and Physical 

Science 

Biological (including plants, model 

organisms such as rodents, 

microorganisms) and physical 

(including quantum) 

✓+ ✓ ✓-

Other Science and 

Remote Sensing 

Including astrophysics, 

heliophysics, planetary science, 

and Earth Science 

✓+ ✓ ✓ 

Technology Demonstration & Development 

Production and 

Manufacturing 

In-Space Production Applications 

(InSPA) including advanced 

materials and bio-manufacturing 

✓- ✓ ✓

Human Exploration 

Systems 

Including food system, exercise 

equipment, medical equipment, 

Environmental Control and Life 

Support Systems (ECLSSs), plant 

growth facilities 

✓+ ✓ ✓

Other Systems Including (quantum) 

communications, power and 

✓+ ✓ ✓ 

115 
Future Growth Scenario 

LEO Activity Description 

Dynamic Steady Limited 

energy storage, robotics, and 

autonomous systems 

Operations 

Cargo 

Transportation 

Utilizing Commercial Crew and 

Cargo 

✓ ✓ ✓

NASA Crew 

Training, 

Transportation, and 

Accommodation 

Utilizing Commercial LEO 

Destinations (CLDs) 

✓ ✓ ✓

Debris Mitigation 

and Remediation 

✓+ ✓ 

Other Operations Including extravehicular activity 

(EVA), small satellite deployment 

✓ ✓ ✓ 

Market Stimulation 

Private Crew 

Training, 

Transportation, and 

Accommodation 

Utilizing Private Astronaut 

Missions (PAMs) 

 ✓ ✓

Tourism Private crew not serving a NASA or 

National Lab mission or objective 

   

Commercial 

Incubation 

Including industrial and 

commercial development 

 ✓ ✓ 

Commercial Media Including games, movies, 

advertising, and branding 

  ✓ 

116 
Appendix D: Full Evaluation Criteria and Scores 

For an in-depth comparison of the models, this section provides the full scoring results and 

evaluation criteria for each model, per future scenario. Each highlight is a summary of the study 

team’s scores for each criterion. 

Full Score for ISSNL 

Dynamic Growth 

Table 14. ISSNL model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs N/A 

Adaptability 

Constraints related to legislation, including the cooperative agreement, 

resource allocation, and contractual limitations, prevent ISSNL from 

being an adaptable model. This especially holds in this future scenario, 

which is heavily dependent on flexibility and scalability. 

Opportunity for 

Collaboration 

The model still provides a means to collaborate between NASA, OGAs, 

and international partners, but the dynamic growth scenario may force 

non-NASA entities to pursue other options that better suit their needs 

or possess better capabilities. 

Market 

Sustainability 

The cooperative agreement in place may limit ISSNL’s ability to 

encourage market growth and provide a good user experience 

compared to other potential options in a dynamic growth scenario. 

While it can potentially help mitigate some risks to return on 

investment (ROI), this will not be needed in a dynamic growth scenario 

with many customers. Incubation and acceleration functions are needed 

to enable small companies. 

Equity & 

Accessibility 

The model still allows input into the activity selection process, provides 

low-cost pathways for research, and proactively seeks input from 

diverse stakeholder groups. 

 

117 
 

 

 

Steady Growth 

Table 15. ISSNL model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs N/A 

Adaptability 

Constraints related to legislation and the cooperative agreement 

prevent ISSNL from being an adaptable model. In a steady growth 

scenario, flexibility and scalability are required for platforms and 

activities to flourish. 

Opportunity for 

Collaboration 

The model still provides a means to collaborate between NASA, OGAs, 

and international partners, but the steady growth scenario may force 

non-NASA entities to pursue other options that better suit their needs 

or possess better capabilities. 

Market 

Sustainability 

This model encourages market growth and could potentially mitigate 

risks to ROI for platform providers by covering costs for payload 

integration and by helping users in the form of grants and subsidies. 

Incubation and acceleration functions are needed to enable small 

companies. 

Equity & 

Accessibility 

The model still allows input into the activity selection process, provides 

low-cost pathways for research, and proactively seeks input from 

diverse stakeholder groups. 

Limited Growth 

Table 16. ISSNL model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs N/A 

Adaptability Constraints related to legislation, including the cooperative agreement 

prevent ISSNL from being an adaptable model. In a limited growth 

118 
 

Model Evaluation Future Scenario Highlights 

Criteria 

scenario, flexibility and scalability are required for platforms to 

succeed. 

Opportunity for 

Collaboration 

The model still provides a means to collaborate between NASA, OGAs, 

and international partners in a way that current parties are familiar. 

Market 

Sustainability 

This model encourages market growth and could potentially mitigate 

risks to ROI for platform providers by covering costs for payload 

integration and by helping users in the form of grants and subsidies. 

Incubation and acceleration functions are needed to enable small 

companies. 

Equity & 

Accessibility 

The model still allows input into the activity selection process, provides 

low-cost pathways for research, and proactively seeks input from 

diverse stakeholder groups. 

Full Score for Anchor Tenant 

Dynamic Growth 

Table 17. Anchor Tenant model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

Overall NASA’s needs are fulfilled. 

Adaptability Restriction to one platform and inflexible contracts hinder the dynamics 

of the market. Expanding to multiple platforms (though not considered 

here) would improve diversity of activities, their simultaneous 

operations, and ability to scale. 

Opportunity for 

Collaboration 

Opportunities and experiences vary across OGAs and international. The 

NASA-centric role may hinder some, prompting them to pursue nonNASA options. 

Market 

Sustainability 

Processes could hinder the speed needed for growth but would provide 

stability to a CLD. The ability to span across multiple platforms was not 

119 
 

 

considered here, but the anchor tenant role would mitigate risks for 

other CLDs, if considered. 

Equity & 

Accessibility 

Diverse groups can be sought and can provide input on activities, 

though with some difficulty. Grants open up opportunities with many 

applicants competing. 

Steady Growth 

Table 18. Anchor Tenant model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

Overall, NASA’s needs are fulfilled.

Adaptability This model works well catering to the level of activities in 

this future scenario, with some limitations due to volume 

restrictions. 

Opportunity for 

Collaboration 

Overall OGAs and international partners are satisfied, though 

some international partners may pursue other options. 

Market 

Sustainability 

The model may show preference towards some activities, 

but nevertheless provides some market stability. Overall, 

this is beneficial to the CLD provider. 

Equity & 

Accessibility 

The diversity of stakeholder groups can be limited, but 

opportunities are available for many. 

Limited Growth 

Table 19. Anchor Tenant model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to NASA’s 

Needs 

NASA’s needs are mostly met, with some need to prioritize 

due to constraints. 

120 
 

 

Adaptability Flexibility and ability to cater to activities are limited. 

Prioritized activities can be carried out within platform 

constraints. 

Opportunity for 

Collaboration 

Collaboration is more limited and must have stronger 

alignment with NASA’s needs. International users may have 

less opportunity than OGAs. 

Market 

Sustainability 

Growth is limited, but the model can cater to available 

opportunities. Overall, the model is beneficial to CLD 

providers. User experience can be cumbersome. 

Equity & 

Accessibility 

Diverse groups can be sought, but opportunities are very 

competitive and must have strong alignment to NASA’s

priorities. 

Full Score for Government Research Broker 

Dynamic Growth 

Table 20. Government Research Broker model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA’s needs can be met. Activities aside from basic research (e.g., tech 

demo, crew training) will need to use the CLD platform more heavily. 

Adaptability 

Highly adaptable to platforms, activities, users, and transport vehicle 

options. Noted ability to move from platform to platform. Scalability of 

activities is limited by the volume of the orbital transport vehicle and by 

platform volume. 

Opportunity for 

Collaboration 

The model promotes collaboration by aggregating and brokering 

opportunities for themed missions, spanning different user bases. A 

user advisory committee helps ensure collaboration among non-NASA 

partners. There may be some competition for grants, but opportunities 

for partners are abundant. 

Market 

Sustainability 

The model can accommodate some market growth. The broker must 

ensure NASA-funded research does not compete with industry (through 

121 
 

Model Evaluation Future Scenario Highlights 

Criteria 

NASA-aligned grants or other means). CLD providers also have some 

level of guaranteed business, but NASA may wish to consider ways to 

ensure the research space utilizes both the orbital vehicle and the 

platform to give more assurance and avoid competition with CLDs. 

Equity & 

Accessibility 

The model seeks input from many and grants ensure users are 

connected with opportunities. The user advisory committee allows for 

input, but competition may dilute that input. More resources (i.e., more 

flights) may increase equity and accessibility in this future scenario, 

given the plethora of supply and demand. 

Steady Growth 

Table 21. Government Research Broker model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs NASA’s needs are mostly met.

Adaptability 

Highly flexible, especially given differing ways platforms can 

exist in this future scenario (one or multiple small 

platforms). Enables diverse activities. Scalability of activities 

has some dependency on usable CLD volume, abundance of 

orbital vehicles, or ability to dedicate flights to scale 

activities as needed. 

Opportunity for 

Collaboration 

The model promotes collaboration by aggregating and 

brokering opportunities for themed missions, spanning 

different user bases. A user advisory committee helps ensure 

collaboration among non-NASA partners. There may be 

some competition for grants, but opportunities for partners 

are regular. 

Market 

Sustainability 

The model can accommodate some market growth. The 

broker must ensure NASA-funded research does not 

compete with industry (through NASA-aligned grants or 

other means). CLD providers also have some level of 

122 
 

Model Evaluation 

Future Scenario Highlights Criteria 

guaranteed business, but NASA may wish to consider ways 

to ensure the research space utilizes both the orbital vehicle 

and the platform to give more assurance and avoid 

competition with CLDs. 

Equity & 

Accessibility 

The model seeks input from many, grants ensure users are 

connected with opportunities, and the user advisory 

committee allows for input. NASA may need to more 

proactively seek input to ensure identified users can be 

connected to supply. The broker may also need to ensure it’s

not hindering competition. 

Limited Growth 

Table 22. Government Research Broker model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs NASA’s needs are mostly met, though some prioritization is necessary.

Adaptability 

Overall, the model can adapt to the restrictions of the future scenario, 

with some volume limitations from the platform and vehicle. The 

broker role is more applied to matching users and activities to the 

orbital transport vehicle. 

Opportunity for 

Collaboration 

Overall, the model is effective for collaboration, but alignment to NASA’s

needs may be required in a limited growth future scenario, especially 

for non-research-oriented activities. 

Market 

Sustainability 

The model can accommodate some market growth but may be more 

limited. The model may provide assurance to the CLD provider but 

might not do enough to sustain the platform if activities do not utilize 

both the orbital vehicle and the platform. 

Equity & 

Accessibility 

The ability to be equitable and provide accessibility (aside from those 

with high alignment to NASA’s needs) is low. 

123 
 

 

Full Score for Innovation Campus 

Dynamic Growth 

Table 23. Innovation Campus model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

The model meets NASA’s needs, assuming there’s an additional method 

of connecting supply to demand. There is an abundance of 

opportunities and users, and NASA has final authority on the campus’ 

focus. 

Adaptability 

Overall, the model is adaptable to the dynamics of this future scenario. 

Built-in flexible agreement types and opportunities to reach beyond 

NASA’s priorities (if desired) may increase diversity of activities. 

Opportunity for 

Collaboration 

The model has a noted ability for collaboration in this future scenario 

but may favor those with more alignment to NASA’s needs.

Market 

Sustainability 

Overall, the model has the ability to drive some market growth. 

Developing and testing technologies terrestrially first may provide a 

higher mission success probability, which helps reduce risk to ROI for 

CLD providers. 

Equity & 

Accessibility 

Overall, the model has a strong ability to seek input from many groups, 

but this may be limited to ground-based needs. There’s a low-cost 

pathway for research, but activities need to overlap with NASA’s needs.

Steady Growth 

Table 24. Innovation Campus model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

The model meets NASA’s needs, assuming there’s an additional method 

of connecting supply to demand. Built in flexibility may help ensure the 

campus activities can adjust to CLD capabilities. 

124 
 

Model Evaluation 

Future Scenario Highlights Criteria 

Adaptability 

The model has some restrictions on its ability to adjust to differing 

outcomes and expand activities, but it can prioritize many activities at 

once. 

Opportunity for 

Collaboration 

The model has strong potential for collaboration, with some preference 

to those with more alignment to NASA’s needs.

Market 

Sustainability 

Overall, the model has the ability to drive some market growth. 

Developing and testing technologies terrestrially first may provide a 

higher mission success probability, which helps reduce risk to ROI for 

CLD providers. 

Equity & 

Accessibility 

The model has some ability to seek diverse groups, but user needs must 

overlap with NASA’s priorities. 

Limited Growth 

Table 25. Innovation Campus model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

The model may present some difficulty in meeting NASA’s needs due to 

limited resources (assuming there’s an additional method of connecting

supply to demand). The focus of campus activity may be narrower. Due 

to the need to prioritize mission-critical research for the LEO platform, 

a narrow focus and the ability to partner where needed may be 

beneficial. 

Adaptability 

Limited opportunities in this future scenario may present difficulties in 

justifying resource needs. NASA may need to explore ways of limiting 

the activity focus or otherwise reducing financial ties. 

Opportunity for 

Collaboration Collaboration is possible, but alignment to NASA’s needs is necessary. 

Market 

Sustainability 

The model can allow for market growth, but opportunities are more 

limited. Developing and testing technologies terrestrially first may 

125 
 

Model Evaluation 

Future Scenario Highlights Criteria 

provide a higher mission success probability, which helps reduce risk to 

ROI for CLD providers. 

Equity & 

Accessibility 

The model can seek out diverse users, but alignment with NASA 

priorities is needed. A low-cost pathway for research may provide 

opportunities, but in a limited capacity. 

Full Score for Matchmaker 

Dynamic Growth 

Table 26. Matchmaker model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

Overall, the model can meet NASA’s needs and can be designed to 

incorporate more NASA oversight to ensure this, especially in a robust 

market with many users. 

Adaptability 

The model is capable of enabling diverse activities and optimizing as 

needed. The model does well with high supply and demand. 

Opportunity for 

Collaboration 

The model enables collaboration, though collaboration may need to be 

considered up front to be most effective. 

Market 

Sustainability 

The model somewhat enables market growth and communicates 

demand well. The model reduces some risk for CLD providers but may 

need to proactively encourage this early (e.g., by improving efficiencies 

and providing incentives). 

Equity & 

Accessibility 

The model doesn’t proactively seek out users, but this can be designed 

for early on. This would be especially useful for a robust supply and 

demand future scenario. Users can provide input into activities but 

aren’t guaranteed selection. The model can be designed to include lowcost pathways for research if that is desired. 

126 
 

 

Steady Growth 

Table 27. Matchmaker model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA has the ability to meet its needs but will need to be proactive to 

ensure prioritization. 

Adaptability 

The model is capable of enabling diverse activities and optimizing as 

needed. Some attention may be needed to ensure activities and their 

potential to scale are not constrained. 

Collaboration Collaboration is enabled but with some limitations. 

Market 

Sustainability 

The model provides some market growth and communicates demand 

well. The model reduces some risk for CLD providers, but may need to 

proactively encourage this early on (e.g., improving efficiencies and 

providing incentives). 

Equity & 

Accessibility 

The model doesn’t proactively seek out users, but this can be designed 

for early on. Users can provide input into activities but aren’t

guaranteed selection and may have to work within limitations. Low-cost 

pathways for research can be included as an add-on to this model. 

Limited Growth 

Table 28. Matchmaker model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA’s needs may be met if the agency has some oversight over the 

nonprofit. The role of the nonprofit may be reduced in a limited growth 

scenario. 

Adaptability 

The model is adaptable. Any limitations are driven more by the 

restrictions of the future scenario rather than the model (i.e., limited 

volume and opportunities). 

127 
 

Model Evaluation 

Future Scenario Highlights Criteria 

Opportunity for 

Collaboration 

Collaboration is limited. Partners need strong alignment to NASA’s

needs. 

Market 

Sustainability 

The model has some limitations but can operate within the future 

scenario. The model might not provide enough assurances to CLD 

providers. 

Equity & 

Accessibility 

The model doesn’t actively seek input from others, but this can be 

designed for early on. The matchmaker may face competition for 

opportunities with just one platform in development. Non-NASA users 

have much less opportunity and ability to provide input. Low-cost 

pathways for research can be included as an add-on to this model but 

would need strong alignment to NASA’s priorities.

Full Score for Institute Network 

Dynamic Growth 

Table 29. Institute Network model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

The institutes funded by NASA, OGAs, and industry can help NASA meet 

most of its needs if enough institutes are formed and can advance focus 

areas sufficiently. The government consortium may need to regularly 

assess performance to ensure progress on all targeted areas. 

Adaptability 

The dynamic ecosystem includes participation from different 

stakeholders in the various institutes. This network can help provide 

flexibility and scalability and can accommodate both diverse and 

simultaneous activities. 

Opportunity for 

Collaboration 

With a high number of participants, NASA, OGAs, and international 

partners have numerous avenues for collaboration, though 

implementing this collaboration may remain a challenge. 

128 
 

Model Evaluation 

Future Scenario Highlights Criteria 

Market 

Sustainability 

The institutes rely on participation from platform providers, who have 

some level of guaranteed business from other members of the institute. 

Pairing this with a focus on commercialization can result in market 

growth. 

Equity & 

Accessibility 

There are some low-cost pathways to research for academic and 

research organizations, but these are limited to areas with 

opportunities for commercialization. It may be difficult for prospective 

users to identify and join the right institutes if there are several in 

existence, and overall participation is limited to those with direct 

expertise in specific areas. 

Steady Growth 

Table 30. Institute Network model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA may need to ensure focus areas more strongly align with 

prioritized mission needs. The focus on commercialization may mean 

that NASA also has to incentivize focus areas that might not generate as 

much ROI as other areas. 

Adaptability 

The institutes can remain somewhat flexible and activities can scale to 

some extent, but activities are largely focused on a small subset of areas 

and do not encourage other diverse activities. Conducting simultaneous 

activities will be limited by platform availability. 

Opportunity for 

Collaboration 

There remains some degree of coordination in standing up and 

participating in new institutes, but there are fewer institutes in 

existence, less participation from stakeholders, and fewer areas of 

overlapping needs between NASA, OGAs, and international partners. 

Market 

Sustainability 

Market sustainability exists but only for specific areas of focus, resulting 

in a limited amount of market growth and mitigation of risks to ROI for 

platform providers. Users will continue to have a positive experience 

but only for the outlined areas of focus. 

129 
 

 

 

Model Evaluation 

Future Scenario Highlights Criteria 

Equity & 

Accessibility 

It is difficult to provide equity with a limited number of institutes and 

only niche areas to develop. Participation is limited to known players 

with capabilities in those areas. 

Limited Growth 

Table 31. Institute Network model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA’s needs will not be met in LEO as there are limited to no 

opportunities for participation in the institutes in a limited growth 

scenario. As such, NASA will not be able to meet needs outside of 

commercialization in very specific and niche areas. 

Adaptability 

There may be some degree of flexibility and scalability related to very 

specific and niche areas, but having limited platform and infrastructure 

options prevents diverse and simultaneous activities. 

Opportunity for 

Collaboration 

Areas of focus for the institutes will be extremely specific. It will be very 

difficult for NASA, OGAs, and international partners to identify potential 

areas of overlapping interest. 

Market 

Sustainability 

In a limited growth scenario with only very specific areas to explore, 

this model can still provide some degree of market growth and a 

satisfactory user experience. However, limiting activity to niche areas 

does not help mitigate risk to ROI for platform providers, which require 

a wide customer base. 

Equity & 

Accessibility 

Equity and accessibility will not be provided due to a very limited 

number of institutes in only niche areas. Participation is limited to the 

well-known players with capabilities in those areas. 

130 
 

Full Score for Fee for Service 

Dynamic Growth 

Table 32. Fee for Service model in the dynamic growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA can mostly meet its needs, but potentially with some watchouts. 

Being one of many customers, NASA may experience some 

prioritization effects. Grants and data buys help ensure needs are met. 

Adaptability 

The model is overall very adaptable to this future scenario. Model 

platforms enable more and more diverse activities, which can be 

conducted simultaneously and at scale. Niche services may also thrive. 

Being a true free market model in a robust supply and demand future 

scenario, companies may have the upper hand in selecting users and 

prices. This may lead to preference in users and activities generating 

the most ROI. 

Opportunity for 

Collaboration 

Opportunities for collaboration with OGAs and international partners 

may vary in nature and by user experience. OGAs may pool funding, 

including funding for their own data buys, or may mostly participate 

through grants. Some international partners may find the process 

simple, and some may be hesitant to purchase directly from CLD 

providers. 

Market 

Sustainability 

This model is very well-suited for this future scenario; the dynamic LEO 

ecosystem supports the low level of government control inherent in the 

model. The model must encourage market growth to thrive. CLD 

providers may have some risk early on (i.e., may need some 

government assurances while the market is beginning to grow), but the 

ROI is high. 

Equity & 

Accessibility 

Proactively seeking input from diverse users is likely not a priority of a 

free market model, but grants help increase participation. Customers 

with the most to spend may again be preferred, limiting participation of 

others. 

131 
 

 

 

Steady Growth 

Table 33. Fee for Service model in the steady growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA can meet its needs, though aside from grants and data buys, 

services might come at a price. 

Adaptability 

The model can mostly adapt to this future scenario, where activities are 

not diverse and platforms can exist in different ways (i.e., one platform 

or several small). Activities may skew towards those that generate the 

most revenue, limiting a diversity of activities from panning out. 

Opportunity for 

Collaboration 

This model presents varied opportunities for collaboration with OGAs 

and international partners. OGAs may need more alignment with NASA 

needs, and international partners may have less opportunity for 

collaboration due to competing priorities. 

Market 

Sustainability 

This model helps encourage market growth. A demand signal is 

communicated through grants. Again, there may be some preference 

toward higher cost services. CLD providers may have some risk early on 

and may need some government assurances while the market is 

beginning to grow. 

Equity & 

Accessibility 

Users with less to spend may be de-prioritized. Users can provide input 

into activity selection processes but might not always be selected. 

Grants provide a low-cost pathway for research, but in a lesser capacity. 

Limited Growth 

Table 34. Fee for Service model in the limited growth future scenario scoring and highlights 

Model Evaluation 

Criteria 

Future Scenario Highlights 

Ability to Meet 

NASA’s Needs

NASA can mostly meet its needs but with significant limitations. Priority 

may be placed on mission-critical activities, and grants and data buys 

need strong alignment with NASA priorities. NASA may also be deprioritized at times due to competition from other users. 

132 
Model Evaluation 

Future Scenario Highlights Criteria 

Adaptability 

Most limitations are due to the lack of dynamics of the future scenario 

(e.g., low number of platforms, less diverse activities). The model can 

work within these, but it is not designed for a limited ecosystem. 

Opportunity for 

Collaboration 

Collaboration among OGAs is limited and likely must align strongly to 

NASA’s needs. International partners have less opportunity to 

participate and may be de-prioritized at times. 

Market 

Sustainability 

The model can enable some growth, but at slow speeds. The CLD 

provider may see some benefit in being the sole provider and can set 

costs to their preference. However, the CLD provider might need more 

commitment from a dedicated partner. 

Equity & 

Accessibility 

The model is limited in diversity of stakeholder groups. Users with the 

most commitment and most revenue-generating purchases will be 

prioritized. Grants and data buys however, help ensure others can 

participate and provide a low-cost pathway for research. 

133 
 

Appendix E: Legislative Changes to Enable Models 

To supplement the considerations involving legislative changes (briefly described in the 

“Considerations to Guide Model Selection” section of the main report), this appendix further 

details the legislative changes that we anticipate being necessary when planning for particular 

models. Table 35 summarizes these changes. 

Table 35. Summary of Legislative Considerations and Necessary Degree of Change Per Model 

Model Legislative Consideration and Necessary Degree of Related Changes 

ISSNL Management 

Science and 

Technology Goals 

Documentation 

and Reporting 

Creation of 

an ISSNL 

Advisory 

Committee 

1.1 1.2 1.3 2.1 2.2 2.3 3.1 3.2 3.3 4 

ISSNL N/A N/A Minor N/A Minor N/A N/A N/A N/A Minor 

1. Anchor 

Tenant Major Major Minor N/A Minor N/A N/A N/A N/A Minor 

2. Government 

Research 

Broker 

Major Major Minor N/A Minor N/A N/A N/A N/A Minor 

3. Innovation 

Campus 

Minor Minor Minor N/A Minor N/A N/A N/A N/A Minor 

4. Matchmaker Minor Minor Minor N/A Minor N/A N/A N/A N/A Minor 

5. Institute 

Network Minor Minor Major N/A Minor N/A N/A N/A N/A Minor 

6. Fee for 

Service Major Major Major N/A Minor N/A N/A N/A N/A Minor 

Congressional Requirements for NASA’s Role in U.S. LEO Activities

Congress routinely passes about two or three NASA Authorization Acts each decade, which 

partially guide the agency’s activities until the next act is passed. These acts contain directives 

regarding NASA’s efforts, including those in space exploration, scientific research, space 

technology development, and agency security. The acts reveal congressional opinion of what 

134 
 

 

NASA’s priorities should be in the near future. The five most recent Authorization Acts—from 

2005, 2008, 2010, 2017, and 2022—provide an understanding of Congress’s vision for NASA in

recent years. All five acts include goals related to NASA’s role in LEO activities, namely the ISS. 

The next section summarizes the current congressional requirements regarding the ISS by 

theme, followed by a section describing anticipated changes to these requirements in future 

iterations of the acts. 

Current Requirements by Theme 

We have summarized the current ISS-related requirements in the most recent five 

Authorization Acts by four themes related to ISSNL management, science and technology goals, 

documentation and reporting, and creation of an ISSNL advisory committee. These 

requirements are paraphrased and simplified. (See the congress.gov legislation database for 

exact wording.) 

1.ISSNL Management 

1.1. Establishment and Operation of ISSNL 

• Establish the U.S. portion of the ISS as the ISSNL and contract a non-governmental 

entity to operate it, also creating a plan for ISSNL operation (2005) 

• Establish a process to help ISSNL users develop a transportation plan to and from 

the ISS (2008) 

• Use the Space Life Sciences Laboratory at Kennedy Space Center to support ISSNL 

capabilities when appropriate (2008) 

• Allow other federal agencies to use the ISSNL for educational activities when 

appropriate (2008) 

1.2. Resource Split Between NASA and ISSNL 

• Allocate at least half of U.S. research resources on the ISS to ISSNL-managed 

experiments (2010) 

1.3. Cooperative Agreement 

• Enter into a cooperative agreement with a nonprofit, which is prohibited from 

engaging in any non-ISSNL activities, for the management of the ISSNL (2010) 

• Designate a NASA Space Operations Mission Directorate employee as the liaison 

between NASA and the cooperative agreement organization (2010) 

• Assist the cooperative agreement organization financially while it initiates 

research activities (2010) 

2.Science and Technology Goals 

2.1. Scientific Research 

• Run a microgravity research program that includes research on the ISS into how 

the human body is affected by long periods of time spent in space (2005) 

135 
• Allocate >15% of ISS research funds to studies that do not directly support NASA’s

human exploration programs (2005) 

• Maximize scientific research and development (2010) 

• Plan and manage research facilities on the ISS (2010) 

• Consider the National Academies Biological and Physical Sciences in Space 

Decadal Survey when prioritizing research and enhancing ISSNL capabilities and 

opportunities (2010) 

• Advance knowledge to the nation through a research program on the ISS (2017) 

• Use the ISS for SMD missions in LEO (2017) 

2.2. Spaceflight Technology 

• Support the development of automated docking and rendezvous capabilities to be 

used by the ISS (2005) 

• Maintain ISS capabilities such that existing activities can be continued if the Space 

Shuttle is unavailable for cargo resupply (2005, 2008) 

• Support technology and capability development on the ISS when appropriate 

(2010) 

• Maximize technology research and development (2010) 

• Use the ISS to further human presence in space beyond near-Earth orbits (2010) 

• Develop new means of flying instrument-level payloads for early demonstration, 

using the ISS as a platform from which to do so if possible (2010) 

• Use the ISS in the development of capabilities and technology for upcoming 

human space exploration beyond LEO (2017) 

• Develop an advanced space suit for ISS use (2017) 

2.3. Commercial Technology Development 

• Provide access to ISS technology, such as docking adaptors, to selected ISS 

commercial crew providers (2008) 

• Enter into a contract with any commercial provider that can adequately provide 

crew transfer and crew rescue services (2008, 2017) 

• Use commercially developed private launch and delivery systems for crew 

missions to the ISS (2017) 

• Assist in development and certification of commercial transportation of U.S. 

government astronauts to and from the ISS via the Commercial Crew Program 

(2017) 

• Run an open competition for a contract for federal government access and return 

services to and from the ISS (2017) 

3.Documentation and Reporting 

3.1. Science and Technology Plans 

136 
 

 

 

 

• Create a plan for research on the ISS by NASA and propose a final configuration of 

the ISS (2005) 

• Create a plan for any changes in the sequence of ISS assembly if they are to occur 

(2005) 

• Create a plan to address the role of the ISS in exploration risk mitigation (2008) 

• Write a report containing a list of necessary hardware, maintenance, and upmass 

and downmass requirements to keep the ISS functional through 2020 (2008) 

• Write a review of scientific equipment, vehicles, and other components on the ISS 

that are critical (2010) 

• Write a report on Orion’s ability to delivery crew and cargo to the ISS (2017) 

3.2. Independent Review Teams 

• Establish an independent task force to assess vulnerabilities of the ISS (2005) 

• Establish an independent commission to review any future events that cause the 

loss of the ISS or its viability (2005) 

3.3. ISS Organizational and Budgetary Reports 

• Write a report on expected development costs of the ISS and changes to costs 

incurred because of Space Shuttle events (2005) 

• Write semiannual reports containing details of any Russian work to complete the 

ISS (2005) 

• Submit a plan for the operation and use of the ISS until at least fiscal year 2020, 

including information about expansion of the operation of the ISSNL (2008) 

• Submit a plan for the management of the ISS, including a description of the 

selection process for research, use of crew time, and other facets of on-board 

research (2008) 

• Submit a budget plan for upcoming ISS-related activities through 2020 (2008) 

• Write a report on the ways in which NASA encourages international collaboration 

on the ISS (2010) 

• Write a report on means of return of research samples and equipment from the 

ISS that have been commercially developed (2010) 

• Write a report summarizing lessons learned from contracts for commercial 

resupply services that should be applied to crew transfer services to and from the 

ISS going forward (2017) 

• Write biennial reports through 2023 on achievements on the ISS furthering deep 

space human exploration, future research goals for LEO platforms, LEO 

commercialization, ISS cost estimates, and evaluations of feasibility and impact of 

the ISS’s lifetime through 2028 and beyond (2017) 

4.Creation of an ISSNL Advisory Committee 

• Establish the ISSNL Advisory Committee to advise on the utilization of the ISSNL 

(2008) 

137 
Anticipated Future Requirements 

Revisions to past Authorization Acts can be established by adopting new language in upcoming 

Acts. Given the frequency of the passing of Authorization Acts, NASA’s Office of Legislative and 

Intergovernmental Affairs (OLIA) predicts that two Acts will be sanctioned this decade: one 

passed in August of 2022, and the other will likely pass toward the end of the 2020s. Congress 

publishes calls for proposed legislative changes to government agencies yearly, and as such, 

OLIA submitted the following four proposed changes for the 2022 NASA Authorization Act 

based on the IRT recommendations delivered to NASA in February 2020.4,7,35 

1. Replacement of “cooperative agreement” language when referring to the

arrangement between NASA and the ISSNL nonprofit 

• Confining the contract to existing as a cooperative agreement only limits NASA’s

flexibility in adjusting this relationship with time 

• Given the congressional definition of the cooperative agreement, the nonprofit 

role is somewhat unclear and redundant, and thus OLIA suggests replacing 

“cooperative agreement” with “arrangement,” a less stringent phrasing, when

citing the contract between NASA and the non-governmental ISSNL manager 

2. Clarification of NASA and nonprofit responsibilities 

• NASA science and exploration research will fly under NASA allocation, rather than 

ISSNL allocation 

3. Removal of the prohibition on the ISSNL management nonprofit conducting 

activities unrelated to the ISSNL 

• This prohibition limits the options of entities that can be considered for ISSNL 

management and constrains the business models of said entities 

• Instead of this prohibition, OLIA suggests a requirement that the nonprofit create 

a conflict-of-interest plan 

4. Removal of the requirement to establish a ISSNL Advisory Committee (INLAC) 

• An INLAC has never been seated, but many of its responsibilities have been taken 

on by an established ISSNL User Advisory Committee, established based on IRT 

recommendations 

This new act did not address the four updates suggested by OLIA, nor did it contain any other 

changes relevant to this study. That is, the current congressional requirements still stand, 

noting that OLIA will continue to propose yearly changes likely similar to those outlined above 

to anticipate future requirements. 

138 
Impact of Authorization Acts on this Study 

The Authorization Acts are potentially a major limiting factor for NASA moving forward, for 

some models more than others. Considering the decommissioning of the ISS and the 

subsequent future of LEO, we see that many requirements set by the Authorization Acts will no 

longer be applicable. Congressional requirements for NASA will have to undergo some changes, 

particularly with regards to how the future LEO ecosystem will be established. NASA has an 

opportunity now to consider what updates to suggest for the expected second Authorization 

Act of the decade. 

The following statements summarize whether a theme warrants concern with respect to the six 

LEO ecosystem models and, if so, how future NASA Authorization Acts need updates to 

maintain legality and congruence between NASA’s plans and congressional requirements. Note 

that all direct references to the ISS will instead use language similar to “CLDs” or “LEO

platforms,” to reflect the transition from ISS usage to one of the new LEO models; this change 

will not affect intent of past acts. 

1.ISSNL Management 

1.1. Establishment and Operation of ISSNL 

• This requirement is a significant consideration for the six models, both regarding 

language and intent. 

• The language of a National Laboratory as it currently exists for the ISS is fairly 

flexible, with the 2005 Authorization Act stating, “the United States segment of the 

ISS is hereby designated a national laboratory.”1 

• A National Laboratory is undefined with reference to the ISS, and definitions that 

exist for other agencies are agency-specific.

1 

• With this flexibility, different components of each model could serve as a National 

Laboratory and the regulation around these determinations would need to be 

clarified in an upcoming Authorization Act. 

• A National Laboratory could be space- or ground-based, depending on the LEO 

model. 

• In the Anchor Tenant and Government Research Broker models, NASA could lease 

a space on a platform or conduct research on an orbital transport vehicle and 

dedicate some of that space to a National Laboratory. 

• In the Matchmaker, Innovation Campus, and Institute Network models, the 

overseeing nonprofit could be the National Laboratory. 

• In the Fee for Service model, NASA could coordinate research grants and data 

buys to serve as a National Laboratory. 

• Regarding intent, Congress should evaluate if a National Laboratory is necessary 

to accomplishing national goals, or if activities currently conducted by the ISSNL 

could be more effectively completed through other means.

4 

139 
 

 

1.2. Resource Split Between NASA and ISSNL 

• The split of ISS resources equally between NASA- and ISSNL-run activities is a 

concern for all six models. 

• Depending on whether a National Laboratory will be created and, if so, who will 

operate it, an even split of resources may not be possible or necessary. 

• This requirement as it currently stands is overly restrictive and will become more 

so if NASA is no longer the sole overseer of U.S. LEO platforms, as would be the 

case in all six models. 

• Congress should evaluate this intent and language and update Acts accordingly if 

there is a continued intent for such stringent resource sharing. 

1.3. Cooperative Agreement 

• The language used for describing the arrangement between the ISSNL operator 

and NASA is specifically a “cooperative agreement,” but this phrase is restrictive 

and thus is a concern for all six models. 

• If Congress decides to apply the intent of establishing a National Laboratory to 

future LEO ecosystems, this language should be updated to be more general, such 

as “arrangement,” as is included in OLIA’s recently proposed Authorization Act

updates. 

• In addition, OLIA’s suggestion to remove the prohibition on the ISSNL

management entity of non-ISSNL activities and replace it with a conflict-ofinterest plan requirement could be problematic for the Institute Network model. 

This model relies on the ability of commercial companies to compete for 

contracts, so this particular attribute of congressional language would have to be 

rethought to ensure that this model could function as intended. 

• If Congress does not confer this intent, then this language should be removed 

completely. 

2.Science and Technology Goals 

2.1. Scientific Research 

• Future scientific priorities will be driven by the National Academies’ decadal 

surveys, regardless of which model is adopted. 

• As such, Congress should update language regularly in accordance with decadal 

findings. 

2.2. Spaceflight Technology 

• Requirements set by the Authorization Acts related to spaceflight technology are 

general and can be accomplished within the ecosystems of all six models. 

• The only desired change in language is a clarification on past requirements 

regarding the Space Shuttle given its retirement in 2011. 

140 
 

2.3. Commercial Technology Development 

• Past acts require that NASA take certain efforts toward commercial technology 

development and a commercial future in LEO, which will be realized within any of 

the six models. 

• No updates are needed with respect to this theme. 

3.ISS Documentation and Reporting 

3.1. Science and Technology Plans 

• Regardless of the model selected, science and technology plans mandated by 

Congress can be written and submitted. 

• No updates are needed with respect to this theme. 

3.2. Independent Review Teams 

• All six models allow for independent review teams mandated by Congress to be 

established and produce a report. 

• No updates are needed with respect to this theme. 

3.3. ISS Organizational and Budgetary Reports 

• None of the six models would hinder the writing or submission of organizational 

or budgetary reports. 

• No updates are needed with respect to this theme. 

4.Creation of an ISSNL Advisory Committee 

• Though Congress instructed that an INLAC be established in the 2008 

Authorization Act, it never was. 

• Congress should reevaluate intent of requirements that fall under this topic. 

• If the intent of establishing a National Laboratory remains post-ISS, the concept of 

an Advisory Committee should be replaced with a User Advisory Committee, as 

has occurred with the current ISSNL.

4 

• If a National Laboratory will not be established, language regarding the INLAC 

should be removed. 

Conclusion 

With the current legislation, the only viable model for the post-ISS LEO ecosystem is a 

reflection of the current ISSNL model, assuming the definition of the ISSNL merely transfers to 

a CLD or other designated platform. If NASA leadership prefers a different model or 

combination of models for future activities in LEO, NASA must propose legislative changes to 

Congress for consideration before the retirement of the ISS. 

141 
Appendix F: Acronyms 

AFRL Air Force Research Laboratory 

ASGSR American Society for Gravitation and Space Research 

BPS Biological and Physical Sciences 

CASIS Center for the Advancement of Science in Space 

CLD Commercial LEO Destination 

CSDA Commercial Smallsat Data Acquisition 

CSP Commercial Service Provider 

DoD Department of Defense 

DOE Department of Energy 

EVA extravehicular activity 

FAA Federal Aviation Administration 

FFRDC Federally Funded Research and Development Center 

GAO Government Accountability Office 

GEO geosynchronous orbit 

INLAC ISSNL Advisory Committee 

IP Implementation Partner 

IRT Independent Review Team 

ISS International Space Station 

ISSNL International Space Station National Laboratory 

JPL Jet Propulsion Laboratory 

JWST James Webb Space Telescope 

142 
LEO low-Earth orbit 

LSII Lunar Surface Innovation Initiative 

MII Manufacturing Innovation Institute 

MOU memorandum of understanding 

NASEM National Academies of Sciences, Engineering, and Medicine 

NIAC NASA Innovative Advanced Concepts 

NIH National Institutes of Health 

NRL Naval Research Laboratory 

NSF National Science Foundation 

OGA other Government agency 

OLIA Office of Legislative and Intergovernmental Affairs 

OSAM on-orbit servicing, assembly, and manufacturing 

OTPS Office of Technology, Policy, and Strategy 

RFP request for proposals 

ROI return on investment 

SBIR Small Business Innovation Research 

SDA Space Development Agency 

SMD Science Mission Directorate 

STEM science, technology, engineering, mathematics 

STRI Space Technology Research Institute 

TRISH Translational Research Institute for Space Health 

UARC University Affiliated Research Center 

143 
Appendix G: Stakeholder Discussants 

NASA 

Name Title, Affiliation 

Camille Alleyne Deputy Manager, Commercial LEO Development Program 

Kevin Engelbert Manager, In Space Production Applications (InSPA) Portfolio 

OZ/ISS Business & Economic Development Office 

Jenn Gustetic Director, Early-Stage Innovations and Partnerships 

Shea Kearns Policy Analyst, SMD Policy 

Jacob Keaton Senior Policy Advisor, ISS Division 

John Kelly Flight Opportunities Program Manager 

Joe Kroener Director, Partnership Office 

Craig Kundrot Director, SMD Biological and Physical Sciences Division 

Alex MacDonald Chief Economist 

Phil McAlister Director, Commercial Space Division 

Elaina McGhee Quality Engineer, Launch Services Program 

Joel Montalbano Program Manager, ISS 

Julie A. Robinson Deputy Director, SMD Earth Science Division 

OGA 

Name Title, Affiliation 

Brad Chedister Chief Technology & Innovation Officer, Defensewerx 

144 
Name Title, Affiliation 

James Frith Space Domain Awareness Lead, AFRL - Space Vehicles 

Directorate 

Ronald Joslin Program Director, Fluid Dynamics Program - Chemical, 

Bioengineering, Environmental and Transport System - NSF 

Bernard Kelm Superintendent, Spacecraft Engineering Division, NRL 

Barry Kirkendall Technical Director, Space - Defense Innovation Unit 

John Labarge Director, Office of Laboratory Policy, Office of Science - DOE 

Lucie Low Translational Partnerships Scientist, National Center for 

Advancing Translational Sciences - NIH 

Christopher Paul Program Manager (Formerly), AFRL Space Vehicles Directorate 

Anonymous FAA Office of Commercial Space Transportation 

Jaime Stearns Director, Space Vehicles Directorate, AFRL 

Karl Stolleis Program Manager, Autonomous Robotics - AFRL Space Vehicles 

Directorate 

Paula Trimble Policy Chief and Legislative Affairs Director, SDA 

J.F. Turner Technical Director, SDA, U.S. Space Force 

Commercial 

Name Title, Affiliation 

Brett Alexander Vice President, Civil Sales - Blue Origin 

Tejpaul Bhatia Chief Revenue Officer, Axiom Space 

Mary Lynne Dittmar Chief Government & External Relations Officer, Axiom Space 

Robbie Harris Director of Advanced Concepts, Nanoracks 

145 
Name Title, Affiliation 

Christian Maender Executive Vice President, In-Space Solutions, Axiom Space 

David Marsh Acting Director, George Washington Carver Science Park; 

Strategy Lead, Nanoracks 

Rick Mastracchio Director Of Business Development, Northrop Grumman Space 

Systems 

Todd Mosher Customer Experience Leader, Space Destinations - Blue Origin 

Elizabeth Reynolds Managing Director, Starburst Aerospace 

Janice Starzyk Vice President, Government Operations - Virgin Orbit 

Erika Wagner Senior Director, Emerging Space Markets - Blue Origin 

Academic and Nonprofit Community 

Name Title, Affiliation 

Matthew Bernards 

Associate Professor of Chemical Engineering and Director of 

NASA Idaho Space Grant Consortium & Idaho NASA EPSCoR, 

University of Idaho 

Elizabeth Cantwell Chairperson of the Board, CASIS ISSNL 

Keith Crane Economist, Science and Technology Policy Institute - Institute 

of Defense Analyses 

Pascale Ehrenfreund 

President, International Space University; Research Professor, 

Space Policy & International Affairs at Space Policy Institute, 

George Washington University; President, Committee on Space 

Research 

Rob Ferl Distinguished Professor and Assistant Vice President for 

Research, University of Florida 

Ray Lugo Chief Executive Officer and Principal Investigator, CASIS 

146 
Name Title, Affiliation 

Douglas Matson Chair of the ISSNL User Advisory Committee 

Ian Miller Chief Science and Innovation Officer, National Geographic 

Society 

Alexander Moen Chief Explorer Engagement Officer, National Geographic Society 

Jim Pawelczyk Associate Professor, Penn State; Board of Directors, CASIS 

ISSNL 

Michael Roberts Chief Scientist, CASIS ISSNL 

Victoria Samson Washington Office Director, Secure World Foundation 

Steve Swanson Distinguished Educator in Residence, Boise State University 

Krystyn Van Vliet Associate Provost and Associate Vice President for Research, 

Massachusetts Institute of Technology 

Brian Weeden Director of Program Planning, Secure World Foundation 

Mark Whorton Deputy Director, Chief Technology Officer, Georgia Tech 

Research Institute 

147 
Appendix H: Acknowledgements 

In its role as an independent office, OTPS relies on the inputs of a broad community of internal 

and external subject matter experts and stakeholders involved in NASA’s future. For the study

described in this report, OTPS considered many inputs while shaping the study itself and 

interpreting and reporting our findings. We thank NASA’s International Space Station Division,

Center for the Advancement of Science in Space, report reviewers, and over 40 stakeholder 

discussants who shared these invaluable inputs. Taking the next steps to prepare for a post-ISS 

LEO ecosystem requires the diverse perspectives of all those involved, and the study team 

gratefully acknowledges all those who contributed. 

148 
 

 

 

Appendix I: Endnotes 

1 National Aeronautics and Space Administration Authorization Act of 2005, Public Law 109-155, 

https://www.congress.gov/109/plaws/publ155/PLAW-109publ155.pdf. 

2 National Aeronautics and Space Administration Authorization Act of 2010, Public Law 111-267, 

https://www.congress.gov/111/plaws/publ267/PLAW-111publ267.pdf. 

3 “Charter of the International Space Station National Laboratory User Advisory Committee,”

ISS National Laboratory: Center for the Advancement of Science in Space, 2001. 

4 “A Strategy for the Future of the International Space Station (ISS) National Laboratory (ISSNL)

and Commercial Low-Earth Orbit (LEO) Development,” National Aeronautics and Space 

Administration, February 4, 2020, 

https://www.nasa.gov/sites/default/files/atoms/files/iss_cooperative_agreement_irt_final_re 

port.pdf. 

5 “International Space Station Transition Report,” National Aeronautics and Space 

Administration, March 30, 2018. 

6 “NASA Plan for Commercial LEO Development,” National Aeronautics and Space 

Administration, June 7, 2019, 

https://www.nasa.gov/sites/default/files/atoms/files/commleodevt_plan_6-7-19_final1.pdf. 

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