Commercial LEO Directive Clarifications 08142025.pdf

Commercial LEO Destinations (CLD) Phase 2 Directive Updates

A U G U S T 1 4 , 2 0 2 5

This document has been approved for public release via the Scientific, Technical and Research Information DiscoVEry System (STRIVES) The STRIVES # is 20250008399 Process. It has been reviewed for Proprietary, CUI, and Export Control (ITAR/EAR) and has been determined to be non-sensitive

P U R P O S E

• Provide additional clarification on Directive on Revised Commercial Low Earth Orbit (LEO)

Destinations (CLD) Phase 2 Acquisition Strategy dated December 4, 2025 based on industry questions

This document has been approved for public release per STI 20250008399

OVERVIEW

E X E C U T I V E S U M M A R Y

• On May 30, 2025, the President’s Budget Request (PBR) for FY2026 was released which included

$272.3 million for FY2026 and $2.1 billion over the next 5 years for the development and deployment of new commercial space stations.

• With the plan to end operations and deorbit the International Space Station (ISS) by 2030, a more cost-effective LEO platform replacement is required to continue human space operations in LEO.

• To reduce the potential for a gap of a crew capable platform in LEO, it is important to move quickly in the acquisition using available funds.

• To meet the goals of a commercial system within the proposed budget, a modification to the current approach for LEO platforms is required as specified in the remaining sections of this directive.

• To ensure mission continuity, affordability, and national alignment, this directive includes accountability measures, transition planning, and performance metrics for industry participation.

• The CLD Program shall support commercial viability while enabling NASA's safe and sustainable transition from ISS operations.

P H A S E 1 S U M M A RY

• Phase 1 included a firm fixed price contract to Axiom Space to design and develop commercial modules which will initially attach to ISS and then detach prior to ISS retirement.

• Phase 1 also included two funded Space Act Agreements (SAAs) for the development of commercial free-flying destinations. These funded SAAs are with Blue Origin (in partnership with Sierra Space) and Starlab Space (a joint venture between Voyager Space and Airbus). Northrop Grumman withdrew from their funded SAA and became a team member of Starlab Space.

• Phase 1 also included unfunded SAAs to advance commercial LEO space-related capabilities with Northrop Grumman, Blue Origin, Sierra Space, SpaceX, SAS, Think

Orbital, and Vast Space.

• NASA will continue to support industry efforts for Phase 1 through Phase 2 award.

Depending on budget and partner desire, NASA will reassess continuation of Phase 1 contract and agreements beyond March 2026.

R E V I S E D P H A S E 2 S T R AT E G Y

• The original Phase 2 acquisition strategy was approved on December 6, 2024, at an agency

Acquisition Strategy Meeting.

• The agency intended to issue a Request for Proposal in late 2025 to award one or more Phase 2 FAR firm fixed price contracts in 2026 that included certification and CLD services.

• Under the revised Phase 2 acquisition strategy, NASA intends to support U.S industry’s design and demonstration of CLDs with multiple funded Space Act Agreements.

• This change better aligns with enabling development of commercial platforms utilizing a process that provides greater flexibility for industry to align schedule with NASA’s needs.

• SAAs also provide more flexibility to deal with possible variations in funding levels without the need of potentially protracted and inefficient contract renegotiations.

• NASA will shift the formal design acceptance and certification from this SAA phase to a follow-on certification and services phase.

• Details on this phase will be outlined with the publishing of the Certification Transition Framework

• The framework document will also outline requirements to move from SAA to formal certification and address safety, human-rating and operational integration.

IMPLEMENTATION DETAILS

S A A P H A S E 2 F E AT U R E S

• Full and open competition to all interested parties via an Announcement for Proposal (AFP).

• Ability to award at least two providers within six months of the release of the AFP.

• 3-year base period of performance with optional milestones up to 5 years total.

• Award value may be varied based on capability to be demonstrated/offered – allows for flexibility in proposed capabilities.

• SAA proposals should include:

• Minimum milestones maturing CLD systems to critical design review (CDR) readiness and an initial in-space crewed demonstration.

• No less than 25% of total agreement value paid after successful in-space crewed demonstration

• Cost-realism assessments, affordability strategies, and co-investment plans.

• Demonstration of interoperability with commercial crew and cargo services

• Alignment with broader national and interagency human spaceflight goals.

• In-space crew demonstration duration of 1 month with 4 crew as a minimum.

• Longer duration missions can be proposed; Shorter duration missions can be proposed as additional demonstrations leading to final in-space Crewed Demonstration of 1

• Assumed to be non-NASA crew but NASA Crew may be considered if appropriate and do not impact schedule

• Include affordable and scalable design approaches

• Final in-space demonstration architecture should be utilized as part of the proposed end capabilities.

S A A P H A S E 2 I N D U S T R Y F L E X I B I L I T Y

• Industry has flexibility in the following proposal areas:

• Determination on proposed utilization capabilities and demonstration objectives above minimum requirements

• The previously defined Full Operational Capability and the LEO Microgravity Strategy will NOT be binding as written.

• The minimum capability of 4 crew for 1-month increments is levied for the Phase 2 SAA specifically.

• NASA is still evaluating if there will be a minimum desired utilization capability

• NOTE: Revised utilization needs and design requirements based on previous industry comments will be uploaded to sam.gov for reference purposes

• Proposals can include multiple demonstrations leading to final crewed mission demonstration

• Demonstration length may be longer than 1 month

• Determination of what functions to be included as part of future end-to-end services, i.e transportation and other supporting function or capabilities

• Partners will be responsible for procuring demonstration transportation

• Proposals may include requests for government provided services and equipment

P H A S E 3 S U M M A RY

NOTE: The specific acquisition strategy is still under consideration for follow-on Certification and Services.

• CLDP will continue to work plans for future Certification and Services and will deliver NLT December 4, 2025 a Certification Transition Framework to outline requirements for moving from SAA to formal certification, including safety, human-rating, and operational integration.

• As part of this plan, a multi-phased approach is expected with NASA utilizing Phase 2 SAA milestone data to inform future human rating/risk assessment for NASA crews and utilization.

• Formal certification will be conducted under a follow-on Phase 3: Certification and Services

Contract

• A modified certification approach is expected to be required as development milestones will not be repeated (i.e CDR)

• The Certification Phase is expected to be a separate, full and open competition for one or more providers.

• Award is expected to be made BEFORE final demonstration completion (Schedule TBD)

• The use of FAR-based contracts will enable application of NASA safety requirements to the commercial developed systems. The specific acquisition strategy is still under consideration.

F U N D E D S A A T O D E M O + P A R A L L E L AW A R D O F S E R V I C E S C O N T R A C T E X A M P L E

NOTES:

• Phase 1 Contracts and Agreements will be supported through Phase 2 contract award with decisions to continue longer based on budget and other factors

• Phase 2 Funded Space Act Agreement with two or more vendors, culminating in on-orbit CLD demonstrations of destination capabilities, performance, and operations with provider crews

• NASA will utilize Phase 2 SAA milestone data to inform future human rating for NASA crews and utilization.

• Formal certification will be conducted under a follow-on Phase 3: Certification and Services Contract

• Phase 3: Certification and Services Contract is expected to be awarded before the final demonstration milestone

(Schedule TBD)

CDISS Contract

Funded SAAs

Unfunded SAAs

6 companies (1 Contractor + 5 Partners)

Minimum 2 Awards

Minimum 1 AwardFSAA - AFP

Agreement Selection(s)

- Contract Award

- Min-Buy Guarantee Provided

- Formal Certification Milestones/ Min Requirements levied

Phase 3: Certification & Services Contract FAR 12 RFP

Phase 2: Funded SAA – Design, Development, & Demonstration

Phase 1: CLD Design to PDR +

Phase 2: CLD Design, Development & Demonstration

Phase 2: Certification Insight Phase 3: Formal Certification

Phase 3: Mission Services

Phase 1 continuation decision gate

A D D I T I O N A L I N F O R M AT I O N

• CLDP will develop a CLD Performance Metrics Plan to document readiness timelines, success criteria, key development benchmarks and other metrics to be utilized to assess the performance of the Phase 2 SAA. Minimum details will be included in the AFP/model SAA.

• The final plan will be published after SAA negotiation and will be based on NASA/partner agreements.

• CLDP will develop and post with the AFP a Public-Private Support Guide identifying NASA infrastructure, facilities, and data available to assist CLD SAA partners.

S PACE OP E RATIO NS M IS S IO N D IRE CTO RATE