GAO: NASA Needs Plan to Ensure Access to ISS Due to Commercial Crew Delays

NASA Commercial Crew Program:

Plan Needed to Ensure Uninterrupted Access to the International Space Station
Government Acc0untability Office
July 2018
Full Report


Why GAO Did This Study

In 2014, NASA awarded two firm-fixed-price contracts to Boeing and SpaceX, worth a combined total of up to $6.8 billion, to develop crew transportation systems and conduct initial missions to the ISS. In February 2017, GAO found that both contractors had made progress, but their schedules were under mounting pressure. The contractors were originally required to provide NASA all the evidence it needed to certify that their systems met its requirements by 2017. A House report accompanying H.R. 5393 included a provision for GAO to review the progress of NASA’s human exploration programs. This report examines the Commercial Crew Program, including (1) the extent to which the contractors have made progress towards certification and (2) how NASA’s certification process addresses safety of the contractors’ crew transportation systems. GAO analyzed contracts, schedules, and other documentation and spoke with officials from NASA, the Commercial Crew Program, Boeing, SpaceX, and two of NASA’s independent review bodies that provide oversight.

What GAO Found

Both of the Commercial Crew Program’s contractors, Boeing and Space Exploration Technologies Corporation (SpaceX), are making progress finalizing designs and building hardware for their crew transportation systems, but both contractors continue to delay their certification milestone (see figure). Certification is the process that the National Aeronautics and Space Administration (NASA) will use to ensure that each contractor’s system meets its requirements for human spaceflight for the Commercial Crew Program.

Further delays are likely as the Commercial Crew Program’s schedule risk analysis shows that the certification milestone is likely to slip. The analysis identifies a range for each contractor, with an earliest and latest possible completion date, as well as an average. The average certification date was
December 2019 for Boeing and January 2020 for SpaceX, according to the program’s April 2018 analysis. Since the Space Shuttle was retired in 2011, the United States has been relying on Russia to carry astronauts to and from the International Space Station (ISS). Additional delays could result in a gap in U.S. access to the space station as NASA has contracted for seats on the Russian Soyuz spacecraft only through November 2019. NASA is considering potential options, but it does not have a contingency plan for ensuring uninterrupted U.S. access.

NASA’s certification process addresses the safety of the contractors’ crew transportation systems through several mechanisms, but there are factors that complicate the process. One of these factors is the loss of crew metric that was put in place to capture the probability of death or permanent disability to an astronaut. NASA has not identified a consistent approach for how to assess loss of crew. As a result, officials across NASA have multiple ways of assessing the metric that may yield different results. Consequently, the risk tolerance level that NASA is accepting with loss of crew varies based upon which entity is presenting the results of its assessment. Federal internal controls state that management should define risk tolerances so they are clear and measurable. Without a consistent approach for assessing the metric, the agency as a whole may not clearly capture or document its risk tolerance with respect to loss of crew.

What GAO Recommended

GAO is making five recommendations, including that NASA develop a contingency plan for ensuring a U.S. presence on the ISS and clarify how it will determine its risk tolerance for loss of crew. NASA concurred with three recommendations; partially concurred on the recommendation related to loss of crew; and non-concurred with a recommendation to report its schedule analysis to Congress. GAO believes these recommendations remain valid, as discussed in the report.

Recommendations for Executive Action

We are making the following five recommendations to NASA:

The NASA Associate Administrator for Human Exploration and Operations should direct the Commercial Crew Program to include the results of its schedule risk analysis in its mandatory quarterly reports to Congress. (Recommendation 1)

The NASA Administrator should develop and maintain a contingency plan for ensuring a presence on the ISS until a Commercial Crew Program contractor is certified. (Recommendation 2)

The NASA Administrator should direct the Chief of Safety and Mission Assurance, the NASA Associate Administrator for Human Exploration and Operations, the Commercial Crew Program Manager, and the Commercial Crew Program Contracting Officer to collectively determine and document before the agency certification review how the agency will determine its risk tolerance level with respect to loss of crew. (Recommendation 3)

After completing the agency certification review, NASA’s Chief Engineer and Chief of Safety and Mission Assurance, with support from the NASA Associate Administrator for Human Exploration and Operations and the Commercial Crew Program Manager, should document lessons learned related to loss of crew as a safety threshold for future crewed spaceflight missions, given the complexity of the metric. (Recommendation 4)

The NASA Chief of Safety and Mission Assurance should restructure the technical authority within the Commercial Crew Program to ensure that the technical authority for the Office of Safety and Mission Assurance is no longer dual hatted with programmatic and independent technical authority responsibilities. (Recommendation 5)

Agency Comments and Our Evaluation

We provided a draft of this report to NASA for review and comment. NASA provided written comments that are reprinted in appendix II.

In its response, NASA concurred with three of our recommendations, did not concur with one, and partially concurred with another.

  • NASA concurred with our recommendation to develop and maintain a contingency plan to ensure a U.S. presence on the ISS and expects to take action to close this recommendation by the end of December 2018.
  • NASA concurred with our recommendation to document lessons learned related to the loss of crew requirement and expects to take action to close this recommendation by the end of May 2019.
  • NASA concurred with our recommendation to restructure the safety technical authority so that it is no longer dual hatted with programmatic and independent technical authority responsibilities. NASA expects to take action to close this recommendation by the end of August 2018.

NASA did not concur with our recommendation that the Commercial Crew Program should include the results of its schedule risk analysis in its quarterly reports to Congress. NASA stated that it uses the contractors’ schedules as a baseline to provide qualitative statements in the NASA summary that accompanies each contractor’s quarterly reports to Congress. NASA believes that this approach is appropriate and is in accordance with the explanatory statement accompanying the Consolidated and Further Continuing Appropriations Act, 2015. NASA also stated that it will be working to ensure that the contractors’ schedules and the program’s internal assessments sync up as the program gets closer to launch. As a result, NASA explained that there will not be a requirement for a detailed NASA assessment, because the contractors’ schedule will either match NASA’s analysis or NASA will discuss its position as it has done in previous reports to Congress.

We continue to believe the recommendation is valid because the program’s schedule risk analysis would provide Congress with valuable insight into potential delays, which are likely. Both contractors have repeatedly stated that their schedules are aggressive and that the dates are ambitious. As a result, we found that the contractors frequently delay dates for key events. For example, Boeing has delayed its certification milestone by 17 months and SpaceX by 22 months since the original schedules were established. The program’s recent schedule risk analysis indicates that more delays to certification are likely, but that information is not presented to Congress in NASA’s quarterly reports. Without this information, Congress does not know the full extent of potential delays to inform decision making.

NASA partially concurred with our recommendation that the Chief of Safety and Mission Assurance, the NASA Associate Administrator for Human Exploration and Operations, the Commercial Crew Program Manager, and the Commercial Crew Program Contracting Officer should collectively determine and document how the agency will determine its risk tolerance level with respect to loss of crew before the agency certification review. In its response, NASA stated that it documented the agency’s risk tolerance level with respect to loss of crew for the program in its May 2011 safety memo. Further, NASA stated that it documented the requirement to limit risks to the loss of crew in a certification requirements document. NASA stated that ultimately the Commercial Crew Program is accountable for ensuring that the contractors’ systems meet the loss of crew value in this certification requirements document, which is a loss of crew value of 1 in 270. If a contractor’s system cannot meet that loss of crew value, or any other requirement, the program will request a waiver as part of the human rating certification process to ensure transparency.

NASA acknowledged in its response that the existence of multiple documents defining residual risk requirements and an agency threshold for loss of crew can be confusing. NASA’s response, however, does not address our finding that it does not have a consistent approach for how to incorporate key inputs, including which debris model should be used or whether to include operational mitigations. NASA stated that it had taken action to address this recommendation; however, NASA did not outline any steps it took to resolve the concern that the risk tolerance for the loss of crew requirement depends on which entity is presenting the results of its analysis. We continue to believe that, before the agency certification review, the key parties must collectively determine how the agency will determine its risk tolerance with respect to loss of crew. We believe this approach will reduce confusion and increase transparency.

  • Andrew Tubbiolo

    Well we’ve put ourselves into a real corner. We can ….

    * Abandon the US section and hope the Russians can/will tend it for us.
    * Camp the last few Soyuz crew members until either another slot can be purchased from Russia or a Dragon or a Starliner can take up the slack.
    * Declare humans self loading cargo on a Dragon v1.0 and hope for the best. No crew interactions with the craft, no escape options. Seats bolted to the deck, food, and basic life support.
    * Find out what it will take the close the gaps on Starliner or Dragon, who ever is closer and pour money into the program to close the gap between now and next year.

  • redneck

    Option 5.
    Musk or one of his children ride in every crew dragon until NASA is satisfied with all the various documentation.

    The largest stock holder in Boeing or one of their children ride in every Starliner until NASA is satisfied with all the various documentation.

    Payment for all flights due on successful completion.

  • Andrew Tubbiolo

    I’ll bet I could go with one of those genetic assay services to find out that I’m a blood relative of Musk and any of those Boeing board members you are alluding to. At some level I could be a blood hostage/flight participant.

  • Cameron

    Little surprise that the schedules continue to slip if NASA cannot even clearly define LOC criteria!! If they cannot clearly define that, it is almost certain there are other areas that they are unclear about as well.
    It is also surprising that GAO predicts Crew Dragon certification NET 2020.The first spacecraft has already shipped to the Cape this week. Unlike Boeing, they are not building it there, they are prepping for flight.

  • windbourne

    in fact, the crewed dragon occurs in early 2019.
    Why will it take another year to cert it?

  • Cameron

    Lagging bureaucratic paper pushers is the only explanation that comes to mind.

  • Emmet Ford

    Or, given the arbitrary and capricious nature of the certification process, which NASA appears unwilling to address, Musk could say, “Thanks, but no thanks,” and walk away. NASA needs SpaceX more than SpaceX needs NASA. It’s not 2008.

  • Tom Billings

    Or more possibly, miniscule funding for the paperpushers’s numbers of personnel, and massive amounts of paperwork demanded.

  • Tom Billings

    Option 6.) Admit that the 5th(4th?, 3rd?) most powerful man in D.C. does not want commercial crew to fly anytime before his monster rocket, and NASA cannot afford to piss him off?

  • Cameron

    I’ve no doubt that the INDIVIDUALS at NASA are doing their best with what they have been given.
    At any rate, I don’t see anyone who believes that SpaceX is causing the delays. They’ve built to NASA requirements at the rate NASA has funded and approved, and therefore notably slower than any of their other projects. SpaceX has no future plans for Crew Dragon beyond their commitment to NASA. They’re all-in on BFR for everything.

  • Tom Billings

    “NASA needs SpaceX more than SpaceX needs NASA. It’s not 2008.”

    True, but they need Senator Shelby’s goodwill more than they need SpaceX. Musk is not the one with his hands on NASA’s throat.

  • Henry Vanderbilt

    I have a plan to ensure uninterrupted Station access:

    Fire the entire lot of eternally-vacillating “Certification” bureaucrats, test-fly both ships ASAP, and as soon as either (or both) flies with no immediate loss-of-crew problems, put people on board and start flying to Station.

    I called this one years ago, when they first started trying to switch the program from COTS-style Space Act Agreements to FARS-based contracting. I am not at all pleased to be proven right in this. We need the !@#$! crew transports.

    Pry the small army of “Certification” drones away from this program and FLY those ships.

  • Emmet Ford

    Yeah, I’m not even buying my suggested course of action. I was just responding to redneck’s overheated option 5 with something having a similar temperature but a different perspective.

  • Kirk

    An “early 2019” crewed Dragon test flight (SpX DM2) is based on vendor supplied target dates, and as Kirk Shireman made clear during the CRS-15 preflight press conference, a lot more information (some of which isn’t even available quite yet) needs to go into setting realistic launch dates. If any Dragon2 flies in early 2019, it will be the uncrewed DM1 mission (the one which just arrived at the Cape from Plum Brook), though a December DM1 is possible. Look to mid-2019 for DM2. Too many people are reading too much into the vendor supplied target dates for both Dragon2 and Starliner.

  • Kirk

    One problem with option 2 is that the Soyuz is used as a lifeboat, so if the last crew is to camp beyond the Soyuz’s deorbit date, they would need to do so without an awaiting return vehicle.

  • Tom Billings

    Yes, your suggestion is so eminently workable, Henry. That’s the problem with doing it. If CC is certified before SLS/Orion flies, then Orion will die. If Orion dies before SLS flies, then SLS has a much better chance of dying as well. If that happens, then who in Alabama will think that the Chair of the Appropriations Committee is a sufficiently powerful man?

    No one.

    The LBJians of the NASA Center districts live and die for power. It is their drug and their breath of life.

  • Andrew Tubbiolo

    If that can’t be waived, that’ll apply more pressure for option 1. Something is going to be waived. Americans won’t be on station, certification for Dragon 2 or Starliner will be waived to one extent or another, or Dragon 1’s lack of human rating will have to be waived. Something is getting waived and I expect we’ll find out around years end what NASA will consider as an option set.

  • redneck

    That would be caving in to reality.

    It’s been a decade and a half since Columbia. and about half that since the last Shuttle flight. If the various were sincere about manned spaceflight, there would have been a capsule for one of the EELVs before the last landing.

  • therealdmt

    Given that the flight Dragon II capsule has already shipped to the Cape and it’s only mid-July, SpaceX seems likely to launch DM1 this year, and then the inflight abort test should proceed a few months thereafter. Assuming that there aren’t big problems with the software or ECLSS, expect DM2 next year. In a pinch, that itself can be a crew rotation mission (as NASA has already studied doing with Boeing’s manned demo).

    The whole certification aspect is a bit of a red herring — once the manned demo has flown successfully, we would clearly have access to the space station available upon issuance of the necessary waiver to the certification requirements.

    After that, at some point NASA is going to have to suck it up and officially certify these vehicles. Either that or keep flying on waivers indefinitely (CYA), or, well, just give up

  • SamuelRoman13

    SpaceX has done 12? Dragon-1s. They know what it takes to get ready. They may be wrong, but next month should not be a problem. It will be up to NASA to launch in Aug. or not. Getting ready to launch crew is unknown to them though and may be some slips. The access arm will not be installed. It is in a tent being worked on though. No new car smell, since it has been in a vacuum. Unless the inside was not exposed. If not they can vent it once in space I hope.

  • Steve Ksiazek

    This was a 2014 contract award, that was supposed to be complete by 2017. One of the reasons SNC lost was because they thought the other vendors were ahead. Both vehicles had already completed CDR back in 2014. With both vendors missing dates and almost 3 years late, the finger can only be pointed to NASA management. Let’s not blame Congress for this disaster. The program was fully funded. In fact, the plan probably calls for development funding to start tapering off this year, because both vendors were supposed to be in the operational phase.

  • Paul451

    The program was fully funded.

    How soon we forget.

  • Paul451

    Especially when their was meant to be a CRV in flight before the ISS was manned.

  • Steve Ksiazek

    Name 1 year the CCiCAP program wasn’t fully funded since 2014. If the expenditures seem low, it’s only because the vendors aren’t completing their milestones.

  • Paul451

    {laughs} Care to narrow it down any more? Perhaps only budgets in a leap-year?

    Commercial crew was under-funded for its first four years. It’s two years behind. Do the freakin’ maths.

  • 76 er
  • Steve Ksiazek

    Blame Obama and the OMB for developing a budget that was DOA upon reaching Congress in those years. That still doesn’t hide the fact that these vendors are 3 years late on a 3 year program. If that doesn’t scream mismanagement to you, I don’t know what does. In fact, those budget requests in FY 2011 thru FY 2014 were when the Congressional oversight committees were telling the NASA mis-management to reduce the number of participants in the CC-Dev2 program. A down select was coming and Congress wanted it sooner than later. Since the only control Congress has over NASA is thru the purse strings, the budget seemed to reflect that direction. The budget more than covered the Boeing and SpaceX CC-Dev2 contracts.

  • Douglas Messier

    I’m told the first Crew Dragon has some serious issues that SpaceX has to fix before it flies. Will take quite a while to address. In the meantime, Starliner could leap frog it and make the first flight to ISS.

    From the NASA point of view, a lot of the certification issues have been on the SpaceX side of things.

  • envy

    Jan 2020 is the mean date, not the NET. The NET is officially still early 2019.

  • envy

    The F9 hasn’t left Hawthorne yet. August isn’t happening for DM-1.

  • envy

    What kind of issues?

    Also, has Boeing ever built a crew capsule before Starliner?

  • envy

    SNC was definitely behind, and would almost certainly be lagging further now. They aren’t expected to fly the cargo DC until both crew vehicle are operational.

  • Steve Ksiazek

    I just read an article today about the person who bought SNC. At one point they were declared bankrupt, and didn’t pay their employees for 3 months. They really didn’t have the financial resources to complete Dream Chaser in a timely manner.

  • envy

    That’s not at all convincing that they could have finished Crew DC in time. They were awarded CRS-2 missions only a little more than a year after the crew awards to SpaceX and Boeing, and are unlikely to catch either despite cargo being much easier than crew to certify.

  • redneck

    I guess that means SpaceX is further behind that they are old. I had no idea that Musk had a time travel company too.:-)

  • Paul451


  • Robert G. Oler

    I would be curious to know what they are. the notion that crewed dragon is that big a leap from cargo dragon is well in my view not a valid one

  • Robert G. Oler

    well said

  • Robert G. Oler

    the scene from Marooned comes to mind…you know the one where Gregory Peck gets out his pen at the launch site 🙂 its not that hard fellows

  • redneck

    The CRV was due years before SpaceX was founded. It being the fault of SpaceX that there isn’t one according to some, it must be time travel.

  • Paul451

    Ah, just clicked. I thought you were sarcastically objecting to my comment. You were instead riffing off my comment to sarcastically mock the hatred for SpaceX.

  • Steve Ksiazek

    It was the shuttle’s job to deliver the CRV to the ISS. We should have kept the shuttle in service until the CRV was ready.

  • passinglurker

    Boeing has bought companies that have basically.

  • Search

    Chair warmers. Its always easy and safe to say do nothing and sit on the ground cooking up new LOC/LOM numbers and adding yet more certifications and oversight. Here is a group of people who share no responsibility whatsoever if exactly NO progress towards commercial crew is ever made.

  • Henry Vanderbilt

    “We can demonstrate specific failure mechanisms” issues, or “SpaceX didn’t do things the way WE would have” issues? Be very careful with these people.