Re: Draft Request for Proposal for the Commercial LEO Destination (CLD) Program

July 16, 2026

The Honorable Jared Isaacman

Administrator

National Aeronautics and Space Administration

300 E Street SW

Washington, DC 20546

Dear NASA Administrator Isaacman:

The Space Frontier Foundation and the National Space Society appreciate the opportunity to comment on the draft Request for Proposal for the Commercial LEO Destination (CLD) Program. Few programs will matter more to America's future in space. We're glad NASA sought industry input before finalizing the RFP, and we offer the comments below in that same spirit of partnership.

We want to start with where we agree. The President and Congress have called for a commercial LEO economy led by the United States, and Administrator Isaacman has said NASA's mission is to "ignite the orbital economy." We share that goal fully. The ISS is nearing the end of its useful life, with a controlled deorbit planned for the end of 2030, and China continues to expand its Tiangong station and its ambitions in orbit. Getting this program right, and getting it right quickly, matters to NASA, to industry, and to the country alike.

With that shared goal in mind, we want to flag several places where the current draft, as written, may not yet deliver the outcome NASA and industry both want. Our aim is constructive. We'd like to help close the gap between the RFP's stated goals and its current mechanics, and we've tried to be specific about where that gap is and what would close it.

The requirements and standards baseline. Commercial Crew succeeded partly because NASA pared its requirements down to what was truly necessary for crew and vehicle safety, and let industry meet that bar through equivalent commercial standards where appropriate. The CLD program could build on that same discipline. As drafted, Attachment J-03, anchored by the CLDP-REQ-1130 requirements document and its associated NASA standards, imposes a baseline that various industry analyses put at nearly 3,000 individual requirements on commercial station developers. CLDP-REQ-1130 traces back to Commercial Crew's own CCT-REQ-1130, but it has grown substantially larger and more prescriptive along the way. We'd like to work with NASA to identify which requirements are essential to crew and vehicle safety and which could be relaxed or met through equivalent commercial standards, consistent with the Commercial Crew precedent.

The scope of NASA's "insight" authority. The draft gives NASA the ability to delay a provider's launch or remove crew or cargo at the provider's expense. It seats NASA as co-chair of safety review boards with approval authority over critical and catastrophic hazards, and it reserves to NASA final say on anomaly resolution, flight rules, and crew medical decisions. We understand the intent here is to protect crew safety and government assets, a goal we share fully. Our ask is that this authority be bounded more explicitly to those purposes, with objective triggers for when it applies and guaranteed schedule and cost relief when NASA-initiated actions aren't the result of the provider's own performance. NASA would keep the oversight it needs, and providers would get the predictability they need to plan and finance a program.

NASA's role relative to existing regulatory authority. Parts of the draft have NASA taking on compliance frameworks and oversight mechanisms that read as quasi-regulatory, duplicating authority Congress has already placed with other agencies. This is worth revisiting for two reasons: it could create redundant compliance burdens for providers, and it sits in tension with the Administration's broader push to streamline federal regulation. NASA's role here should be framed clearly as partner and anchor customer, working alongside the agencies that already hold statutory regulatory authority rather than layering a parallel review on top of them.

Government footprint and priority on commercial stations. The draft envisions NASA crew, crew time, and stowage aboard the stations, plus dedicated NASA consoles and offices in the ground-based Mission Control and launch centers, along with an open-ended "NASA Priority" and ISS-style oversight arrangements. NASA has real needs here, especially early in the program, and we recognize that. But a durable commercial market depends on stations serving many customers on comparable terms. We'd encourage NASA to scope its footprint and priority claims more narrowly and predictably, in a way that meets its mission needs without structurally crowding out the non-NASA customers the program is counting on providers to attract.

Pricing structure. The draft's most-favored-customer clause would entitle NASA to the lowest price offered to any customer, even though NASA's own oversight requirements are likely to add cost relative to other customers. A separate provision limits providers' ability to use the contract to help underwrite private or sovereign-astronaut seats. Meanwhile, NASA's evaluation criteria reward providers who can show a profitable business case built on substantial non-NASA revenue. These two goals are currently working against each other. Replacing the rigid most-favored-customer approach with pricing adjusted for the risk and cost differences between NASA and other customers would better support the exact commercial customer base NASA is asking providers to build.

Investor confidence and program timing. CLD companies have told us that investor interest has softened as NASA has proposed changes to the underlying program plan. That's understandable: private capital needs a clear signal of NASA's long-term commitment before it will commit at scale. Moving toward an award, or awards, as soon as NASA reasonably can, paired with early development funding and a clear long-term anchor-tenancy commitment, would go a long way toward bringing investors off the sidelines at the moment the program needs them most.

What we'd like to see in the final RFP. Before the RFP is finalized, we recommend that NASA: pare the requirements-and-standards baseline down to what is genuinely essential to crew and vehicle safety; bound NASA's insight authority to safety and the protection of government assets, with objective triggers and built-in schedule and cost relief when appropriate; replace the rigid most-favored-customer pricing provision with an approach that accounts for risk and cost differences across customers; and narrow the ISS-derived accommodations and open-ended priority provisions so they meet NASA's needs without displacing commercial customers. We'd also encourage NASA to invite industry to be ambitious in proposing changes to this draft. The more candid the dialogue between now and the final RFP, the stronger the resulting program will be.

What's at stake. The timeline is not on our side. The ISS is scheduled for controlled deorbit at the end of 2030, and China has been explicit about its plans for Tiangong: roughly doubling it, from three modules to six and from about 90 to 180 metric tons, while courting international partners and pursuing a standing UN cooperation channel. Whether America maintains a continuous human presence in orbit past that date comes down to how quickly a competitive U.S. commercial LEO sector can begin flying stations of its own, and that is largely a function of how much room this RFP gives industry to move. Administrator Isaacman has called on NASA to ignite the orbital economy. We believe the surest way to do that before 2030 is a final RFP built around the changes above, and we'd welcome the chance to help NASA get there.

We're grateful for the opportunity to comment on this important solicitation, and we'd welcome a chance to discuss any of these points further with your team, in writing or in a follow-up conversation, as NASA works toward a final RFP. Thank you for considering our input.

Respectfully submitted,

K.D. Michaelangelos Johnson Chief Executive Officer National Space Society, Inc.

Sean Mahoney Executive Director Space Frontier Foundation, Inc.