Draft RFP Industry Q and A Part 1.pdf

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Attached to
Commercial Low Earth Orbit (LEO) Destination Contract (CLDC) Draft Request for Proposal Federal contract opportunity
Solicitation number
80JSC026R0021DRFP
Issued by
National Aeronautics and Space Administration Johnson Space Center

About this file

This document is a Questions and Answers compilation addressing industry inquiries regarding the Commercial Low Earth Orbit Development Capability (CLDC) Draft Request for Proposals issued on August 14, 2026. The Q&A addresses clarifications across Statement of Work (SOW), Data Requirements Documents (DRDs), requirements specifications, and contract mechanisms.

Key clarifications include: the 70% cargo reference in SOW Section 2.14 refers to volume capability, with exact volumes documented at CLIN 3 award based on the contractor's proposed vehicle traffic plan; the NASA Flight Director console is required continuously in the contractor's Destination flight control room, not at Mission Control Center-Houston; private astronauts can serve as passengers or mission specialists depending on qualifications, not limited to space-agency-sponsored individuals; and tailoring of work plans, DRDs, and standards must be negotiated before CLIN 1 contract award. DRD CLDC-124 (Utilization Integration Plan) will not require draft deliveries with the proposal and is excluded from page count. The document clarifies that incubation requirements have been moved to CLDP-REQ-1130 Appendix D as optional services. For crew accommodations, contractors should propose items meeting their unique destination and crew complement needs rather than strictly adhering to outdated reference catalogs. NASA will update SOW Section 2.19.4 to remove USG Furnished Crew Time limitations, expecting all crew to support assembly, outfitting, maintenance, and operational tasks. Regarding commercial activities, only military operations and activities related to Designated Countries Tier II & III require NASA Contracting Officer approval; other commercial activities are permitted. The document addresses numerous technical requirements, cybersecurity approaches, export control compliance, medical standards, crew selection criteria, and transportation vehicle certification pathways, with NASA committing to clarifications in the Final RFP on Government Furnished Transportation and Support Services strategy, domestic source criteria application, and commercial venture opportunities.

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CLDC Draft RFP Final Industry Questions and Answers Posted August 14, 2026

Statement of Work

1. In SOW Section 2.14, does the 70% of cargo mean 70% of cargo by mass, volume, or other?

The Final RFP will be updated to clarify the SOW statement in SOW Section 2.14 Mission Integration to be 70% of the volume capability. The exact volume will be documented at the CLIN 3 RFTOP award based on the Contractor proposed vehicle traffic plan.

2. In SOW Section 2.12, clarify intent with NASA flight director in control room. Request NASA clarify whether flight-director presence is continuous or limited to critical operations, and whether the function may be hosted at MCC-H or at a Contractor-provided control room in Houston.

The NASA Flight Director console is required continuously in the Contractor’s Destination flight control room, not MCC-H.

3. In table 1.2.5-1 of the SOW, what specifically does NASA mean by having little to no responsibility to perform a mission task for the space system?

As outlined in SOW Section 1.8.1.3 Passenger, “This role would be expected to be one where minimal training was provided and only specifically trained events were planned for the individual.” A more detailed definition for Passenger is provided in Section 1.8.1.3 Passenger.

4. In SOW Section 1.8, why has NASA chosen to use the term “Passenger” instead of “Space Flight Participant” or “Private Astronaut”?

Private Astronauts (Non-USG Crew) could be Passengers or Mission Specialists depending on their qualifications. NASA elected to not use the term Space Flight Participants to avoid conflicts with definitions of Crew and other slight differences in 14 C.F.R. §401.7 Definitions.

5. In SOW Section 1.8, to foster the growth of the LEO economy, will NASA consider using the term “Private Astronaut” instead of “Passenger” or “Space Flight Participant”?

Private Astronauts are Non-USG Crew and can be Passengers or Mission Specialists, or even Crew Commanders depending on their qualifications. NASA elected to not use the term Space Flight Participants to avoid conflicts with definitions of Crew and other slight differences in 14 C.F.R. §401.7 Definitions.

6. Table 1.2.5-1 CREWMEMBER DEFINITIONS defines the types of CLDS crewmembers. There is an implication that a High-Net-Worth Individual (HNWI) can only be considered as a "passenger" because they would not be sponsored by a space agency which then limits the ability to assign them as a "Mission Specialist" as defined in

1.8.1.2. A CLD provider could have potential customers who are HNWIs who will want more responsibility than just that of a passenger per NASA's definition. Is NASA's intent that only astronauts sponsored by a space agency would be able to be a mission specialist?

Private Astronauts are Non-USG Crew and can be Passengers or Mission Specialists, or even Crew Commanders depending on their qualifications.

DRDs

7. Please clarify for proposed tailoring of DRDs, Mission Service Work Plan, NASA Standards & Specifications, etc.;

are we to price our proposal assuming the tailoring is accepted, and if not accepted compliance/non-compliance will be negotiated before final CLIN 1 contract award, or when?

Tailoring of Work Plans are expected to be negotiated before CLIN 1 contract award. If the Contractor proposes alternative standards or “meet the intent” tailoring for NASA Standards & Specifications and other documents designated “meets the intent” and they are deemed not to meet the intent, the Contractor will be required to modify their proposed tailoring to “meet the intent.” NASA is not offering a price adjustment if proposed “meet the intent” tailoring is not accepted. Per SOW 2.10.6 Adjudication of Standards, "NASA proposes holding technical coordination meetings shortly after contract award to discuss the alternate standards adjudication process, expectations, and initiate coordination efforts.” It is NASAs intent to accept previously Approved Alternate Standards from other NASA programs if they meet applicable CLDS requirements, demonstrate equivalent environments and analysis. NASA will clarify when adjudication is required in the Final RFP.

8. In the DRD file, CLDC-124 is annotated as being submitted with the proposal in draft form. Request NASA confirm that this DRD is to be submitted with the proposal, where within the Mission Suitability volume it should be included, and that it is excluded from the Mission Suitability 200-page limit.

The final RFP will be updated in Section 6.0 Data Requirement List and DRD CLDC-124 Utilization Integration Plan to delete the draft deliveries of the DRD. NASA does not intend to require them for the proposal. DRDs are excluded from page count.

9. In CLDC-103, Please clarify what is meant by Subject Area in the Column 'Denote Subject Area that Standard applies to".

Offerors should fill in the discipline, system, sub-system, or technical area the Standard (or equivalent Alternate Standard) will apply to.

10. The table in the CDRL list indicated that DRD CLDC-124 Utilization Integration Plan is to be submitted with the proposal. The DRD is not mentioned in the Section L DRFP instructions. Specific questions 1) is the Utilization Plan to be submitted with the proposal? 2) if so, where should this plan be placed within the volumes?

No. The Section 6.0 Data Requirement List and DRD CLDC-124 Utilization Integration Plan will be updated to delete the draft deliveries of the DRD in the proposal.

11. In DRD CLDC-002, this section requires a list of all major subcontractors, vendors, suppliers, partners and definition of scope, status of contracts, and forward plans. What is defined as ‘major’ here? Contract value over a specific threshold? Service supplier for a specific number or amount of services per defined period? Does this definition of major subcontractor apply across all of mission suitability subfactor?

DRD CLDC-002 Commercialization Plan will be updated in the final RFP to clarify the value threshold or services that apply.

12. DRD CLDC-015 Program Management Plan states that Initial Submission is due at CBR and there are no mentions of this DRD in Section L. However, DRFP Attachment J-06 includes a placeholder for the Program Management Plan and states "(as proposed by the Offeror)". Please confirm that the CLDC-015 Program Management Plan is not due with the proposal, but due at CBR.

CLDC-015 Program Management Plan is not due at Proposal submission. The Final version of the plan is due at the Certification Baseline Review (CBR) milestone as the Initial Submission per DRD CLDC-015 Program Management Plan and upon approval will be incorporated in the contract as Attachment J-06.

13. DRD CLDC-124 Utilization Integration Plan (UIP) requires draft (Sections 1-3 and 6, DRM #1 and DRM #2 only) at Proposal submission; however, this DRD is not included in the dRFP Section L Proposal Outline (Table L.17.1-1) nor in the L.17.3 instructions for Volume II. Will the Government please clarify the requirement for submission of the UIP with the proposal? The Section 6.0 Data Requirement List and DRD CLDC-124 Utilization Integration Plan will be updated in the final RFP to delete the draft deliveries of the DRD in the proposal.

14. There are a number of DRD requirements that appear to be overly burdensome/duplicative. For example, is it necessary to have an Acoustics Noise Control Plan, Human Error Analysis Plan, MMOD Report and others be formal DRD deliveries? There are already noise, HEA and MMOD requirements within the CLDP-REQ-1130 specification that will need NASA approval through verification events and success criteria.

NASA has targeted specific areas that are high risk areas where early feedback is necessary to ensure the provider can efficiently affect the design prior to data delivery for verification events. It is NASA experience that design changes after these events are more costly and can drive development schedules. NASA plans to keep these DRDs as deliverables in the Final RFP.

15. Per DRD CLDC-131 paragraphs 1 b and c, is it expected that the contractor provide crew quarters and suit up rooms for NASA crews if/when they provide transportation services? Additionally, why aren't all the items paragraphs 1 and 2 considered part of GFS if NASA provides transportation services as stated in the applicability section of this DRD?

Per J-15, NASA has outlined the associated activities related to crew and cargo transportation and have laid out separation of responsibilities. There are some traditional areas that have been moved to the CLD provider due to key interfaces or interdependencies with other responsibilities or if the task is not directly being done by contracted services and does not substantially utilize NASA expertise. Specifically, for this question, the Contractor is responsible for Quarantine and Suit room services due to their overarching responsibility for the Health Stabilization Plan. However, these services can be requested from the government as part of a Government Task Agreement (GTA).

16. In DRD CLDC-004, has NASA considered a performance-based cybersecurity approach focused on outcomes and risk management rather than prescriptive approval and reporting requirements? NASA should adopt a performance-based cybersecurity framework focused on security outcomes rather than prescriptive tool and process approvals.

NASA's Information Security Program is founded upon industry-recognized best practices as established by the National Institute of Standards and Technology (NIST). The agency's cybersecurity strategy is structured around the NIST Risk Management Framework, as well as NIST Special Publication 800-53, which outlines comprehensive security and privacy controls for information systems and organizations. In addition, NASA utilizes other relevant NIST Special Publications to ensure that its cybersecurity requirements remain fully compliant with applicable federal statutes, executive orders, directives, policies, and regulations. The NIST Risk Management Framework is fundamentally not structured as a performance-based model; rather, it offers indicators that assess the probability that threat actors could successfully exploit genuine vulnerabilities within the information system environment, as opposed to merely measuring activity as would be typical in a performance-based framework.

17. In DRD CLDC-122, request SCV reporting scope be limited to the critical-items list and items within catastrophic/critical hazard chains, rather than all suppliers and sub-tier suppliers. Unbounded sub-tier disclosure chills commercial supplier participation and adds price without improving parts assurance where it matters.

DRD CLDC-122 Supply Chain Visibility (SCV) Reporting is intended to shed light on all supply chain suppliers down to Tier 3. Restricting the data to just critical items will not inform the overall hardware development and sustainment. Per the Remark in DRD CLDC-122 Supply Chain Visibility (SCV) Reporting, "It is not expected that suppliers to the Contractor utilize the SCV reporting tool or provide data directly to NASA in support of this

DRD."

18. In SOW 2.12, "The Contractor shall provide NASA access to all electronic tools, templates and other medium necessary for NASA insight, participation and input to the planning, execution, maintenance and operation the CLDS." Request to qualify requirement to include: "...excluding non-NASA customer proprietary data and Contractor competition-sensitive business information, with access boundaries defined in the approved Insight and Collaboration Implementation Plan (CLDC-104)." Full certification and NASA-mission insight is preserved while the destination remains sellable to the commercial customers whose revenue is evaluated under MA.2.

NASA will update the SOW statement in the final RFP to: The Contractor shall provide NASA access to all electronic tools, templates and other medium necessary for NASA insight, participation and input to the planning, execution, maintenance and operation of the CLDS, in accordance with DRD CLDC-104 Insight and Collaboration Implementation Plan.

19. In DRD CLDC-115, does Interrelationship mean requirement or what?

Interrelationships in the DRD template define references to related SOW or contract clause requirements.

20. In DRD CLDC-111, is it correct to assume that requirement 3b should read part 3a?

DRD CLDC-111 Medical Operations Plan has been updated to fix an editorial error, in which “2a" should read "3a" in content Section 3.b. “Identification of contractor and NASA flight surgeon physical location(s) and roles/responsibilities during the events in part 23a”

21. In DRD CLDC-211, required only for Government Provided Crew/Cargo missions. DRD definition does not appear to make allowances for previously certified vehicles addressing requirements via delta-certification approach. Please clarify DRD content requirements for previously certified vehicles.

DRD CLDC-211 Destination to Visiting Vehicle (VV) Integration (DVVI) Documentation is required to integrate all US Government Furnished Crew and Cargo visiting vehicles to the Destination regardless of whether they are previously certified.

22. In DRD CLDC-102/106, as an applicable reference for the scope that is required the VVCP and VCN DRDs refer primarily to CLDP-REQ-1130. There is also a stated cross reference to "SOW

1.3 CLDS Requirements and Standards" which contains also the other essential standards as CLD-STD-1102, - 1106, -1150 etc. Please confirm VCNs for all CLD-STD-11XX standards are required.

One (1) Verification Closure Notice (VCN) is required for each standard called out in CLDP- REQ-1130 Requirements and Standards for the Commercial Low Earth Orbit (LEO) Development Program. NASA expects multiple verification events will be required to close out that one VCN.

23. In DRD CLDC-106, "One (1) VCN per CLDS requirement as identified in CLDP-REQ-1130..." This approach may differ from certification plans developed and presented for CLDP Phase 1 SAA milestones already executed;

updating this plan could cause programmatic delays and create overhead for documentation management.

Rewrite the requirement to allow providers to follow procedures established during Phase 1 development.

The Commercial Destination Free Flyer (CDFF) Funded Space Act Agreement (SAA) scope did not prescribe SAA partners to deliver VCNs against Commercial LEO Development Program (CLDP) requirements. Commercial approaches can be proposed and negotiated post award as part of the acceptance of the DRD delivery.

24. In DRD CLDC-103, is NASA able to make available all Standards that are applicable to proposers available in the Tech Library?

NASA does not plan to make available through the Technical Library all Standards as some are commercial standards that the Government does not have the rights to distribute. NASA has posted or plans to post all non-publicly available Applicable Documents including Standards from CLDP-REQ-1130 in the Technical Library or will provide references to where they are publicly found.

25. In DRD CLDC-005, the DRD’s “Interrelationship” field cites “SOW 2.7 Export Control Management.” The relevant SOW provision is numbered “2.6 Export Control.” Is this a typo in the DRD that should reference SOW 2.6, not 2.7?

Yes, the DRD contains a typo and should reference SOW 2.6 and not 2.7. This will be corrected in the Final RFP.

26. DRD CLDC-005 appears to describe the scope of the Export Control Plan in two different ways. Box 10, ‘Description/Use,’ frames the requirements around the Contractor’s approach to transactions, i.e., the transfer of commodities, software, technical data, technology, defense services, and/or technical assistance to foreign entities. Box 11, ‘Contents,’ however, frames the requirement around the Contractor’s export control program, requiring the plan to address the expected exports, approval process/authorities, and management of foreign nationals, structured around seven specific program elements. These two descriptions are not identical in scope or framing, and it is unclear whether the Contents section is meant to be a subset of, an elaboration on, or a separate requirement from, the Description/Use section. We request that NASA reconcile these two sections and provide a single, consistent statement of the required scope and content of the Export Control Plan.

The purpose of Box 10 is to offer a clear description of the required DRD, while Box 11 is designated to outline the specific requirements for the DRD Export Control Plan. To improve clarity for the intended audience, NASA intends to revise Box 10 by removing the references to the FAR clauses from its description.

(The Remainder of this page is left Intentionally Blank)

27. In DRD CLDC-005, Section 2.6 of the SOW requires the Contractor to ‘perform export control in accordance with’ NASA’s internal governance documents – NPR 2190, NASA Export Control Program, NAII 2190.1H, NASA Export Control Program Operations Manual (and, per DRD CLDC-005, also NPD 2190.1, JWI 2190.1, and JAII 2190.1). These are NASA’s internal policy and procedural directives, written to govern how NASA civil servants and the agency administer NASA’s own export control program. Contractors already maintain their own export control compliance program, developed and managed to satisfy ITAR and EAR regulations administered by the Departments of State and Commerce. As a result the Contractor is directly and independently accountable to State and Commerce as the controlling federal regulators. We request the SOW 2.6 be revised to require Contractor compliance with the applicable export control laws and regulations, rather than requiring conformance to NASA’s internal directives, which are designed for NASA’s own internal administration and are not appropriately imposed as compliance standards on a Contractor with its own established, independently regulated export compliance program.

The NASA Policies and Procedures, along with the Data Requirements Document (DRD), are supplemental to Section H – Special Contract Clauses of the Request for Proposal (RFP). These provisions support contractors in establishing their own export control programs in compliance with the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), which are administered by the Departments of State and Commerce. Contractors are obligated to submit an Export Control Plan as specified in the DRD, detailing the processes by which their Export Control Programs are implemented and maintained. Furthermore, the Statement of Work (SOW) imposes adherence to NASA policies and procedures when their contractors interact with NASA employees or NASA support contractors in activities that involve the transfer of commodities, software, technical data, technology, defense services, or technical assistance to foreign entities. For enhanced clarity regarding the DRD and SOW Section 2.6 Export Control as supplements to Section H, revisions are expected to be made to both documents.

28. In DRD CLDC-005, we ask that NASA relocate the NASA FAR Supplement (NFS) clauses 1825.1103-7- and 1852.225-70 currently incorporated in the DRD to Section H – Special Contract Clauses of the RFP. Our primary concern is one of placement. Section H – Special Contract Clauses is the appropriate contracting vehicle for incorporating substantive contractual obligations, such as these NFS clauses, so that they are properly applied to contractors. The DRD, by contrast, is generally understood as a document governing data deliverable rather than a source of binding contractual clauses. If NASA intends for these NFS clauses to be contractually applicable to providers, incorporating them in the DRD rather than Section H may create ambiguity as to whether they carry the force of a contractual requirement.

DRDs are binding contractual documents. The final RFP will correct the reference from 1825.1103-7 to 1825.603-70, Export Control. The inclusion of NFS 1825.603-70 and 1852.225-70 in the Data Requirements Document (DRD) served to clarify the rationale for requiring an Export Control Plan within the contract. For enhanced clarity regarding the DRD, revisions will be made to both section H and the DRD.

Requirements (DRDs, SOW and Program Documents)

29. SOW Section 1.7.2 States: "A continuously crewed mission refers to the Destination that is continuously occupied by USG Crew with no more than a 14 day lapse in USG Crew presence between crew handovers." Does that mean that the station can be completely uncrewed for 14-days or does this only apply for USG crew?

Yes, a Destination can be completely uncrewed for no more than 14-days, and still meet the requirements for a continuously crewed mission. The purpose of the 14 day allowance is to allow for an indirect handover between crews when required.

30. Under the DRFP Section J-Attachments, when will CLDP-PLN-2200 Commercial Low Earth Orbit Development Program Risk Management Plan be provided to the technical library? CLDP-PLN-2200 Commercial Low Earth Orbit Development Program Risk Management Plan is an internal NASA Plan and is not intended to be placed in the technical library. NASA plans to update the final RFP to remove the CLDP-PLN-2200 reference from the Section J-Attachments List.

31. Under SOW Section 2.12, are NASA personnel required to be in the primary Destination Flight Control Room [FCR], or is an area nearby with the same voice and data monitoring capabilities sufficient? If required in the primary FCR, please specify the number of NASA personnel and capabilities required to enable determining the required size of our flight control and support rooms to include required additional capabilities and determine associated costs.

Yes, NASA personnel are required to be in the primary Destination Flight Control Room (FCR). Details, number, and types of personnel are documented in the SOW Section 2.12 NASA Access to Partner Facilities and Tools.

NASA plans to update the final RFP to remove the CLDP-PLN-2200 reference from the Section J-Attachments List.

32. Under SOW Table 3.3.3 (Standard Service Mission Minimum Requirements), states the Number of USG crew as “2”. Should “Number of USG Crew” read “Minimum Number of USG Crew”?

Yes. Table 3.3.2 and 3.3.3 should be labeled Minimum Number of USG Crew and will be updated for the Final

RFP.

33. The crew accommodations list and SSP 50477 Joint Crew Provisioning Catalog Revision C are both out of date and do not reflect what is flown to support ISS crewmembers today. Are we to respond only to the items in these reference materials or should these be updated to reflect the items and usage rates that are currently support ISS crew?

SSP 50477, the Joint Crew Provisioning Catalog, serves as a reference and does not represent the exact list of items NASA expects the Contractor to provide. The Contractor is expected to supply a list of crew accommodations items in a similar format that meets the needs and requirements of their unique Destination and Crew compliment.

34. Under SOW Section 2.19.4, will there be USG Crew Time available to be utilized for maintenance and other recurring station operations beyond the 4th year of service?

NASA plans to update SOW Section 2.19.4, USG Furnished Crew Time, in the Final RFP to remove the USG Furnished Crew Time table, thus removing the percentages and limitations for the use of NASA Crew. NASA expects all crew, including USG crew, to support assembly, outfitting, maintenance and destination operational tasks.

35. From paragraph 2.12 of the SOW: "Provide transportation of nine (9) NASA personnel, the USG Crew, plus an additional five (5) NASA personnel per USG Crew from NASA’s Johnson Space Center (JSC) to the launch site in accordance with DRD CLDC-131 Pre-Launch and Post- Landing Operations." (~21 people if its only 2 crew flying) Is it expected the contractor provide this service while everyone is in quarantine along with accommodations for the return the complement of personnel back to JSC and have a plan for any/all these individuals at the launch site including launch scrubs? Recommend NASA provide this capability since it already exists within their capability today.

NASA expects the Contractor to provide transportation for NASA personnel and Crew to the launch site while maintaining health‑stabilization protocols consistent with the language in the SOW. Accommodations for NASA personnel at the launch site, as well as transportation for NASA personnel and Crew from the launch site to JSC, are not levied on the Contractor and remain NASA’s responsibility.

36. In the SOW, Table 1.5-1, the SOW shows no Destination requirement for incubation (only during transportation).

Is this intentional? -1130 states incubation requirements for destination.

NASA has moved incubation requirements to CLDP-REQ-1130 Appendix D. The CLD offeror may propose to offer incubation capability under CLIN 4 but are not required.If not offered, NASA plans to provide its own incubation capability for its own use on the destination.

37. Under DRD CLDC-004, how does NASA distinguish between cybersecurity requirements necessary to protect NASA interfaces and requirements governing commercially owned systems and infrastructure? What is the mechanism to adjudicate the priorities? NASA should clearly delineate cybersecurity requirements for NASA-facing interfaces versus commercially-owned systems and establish a streamlined adjudication process.

The Information Technology Data Requirements Documents (DRDs) identify the NASA documents that establish the agency's policies, procedures, and practices, including comprehensive governance frameworks and clear definition of roles and responsibilities for cybersecurity across both NASA systems and those of contractors, including commercial partners. These referenced documents set forth the requirements essential for safeguarding NASA's information and information systems throughout their entire life cycle. For matters pertaining to governance and leadership responsibilities in the prioritization of cybersecurity, the following NASA directives and procedure are explicitly cited: NPD 2810.1, Information Security Policy; and NPR 2810.1, Security of Information and Information Systems.

38. Under DRD CLDC-107, recommend deleting CLDC-107 as a standalone Type-1 deliverable and incorporating its software management content into the Systems Engineering Management Plan (CLDC-101). Neither predecessor crewed program placed a standalone Software Management Plan under Type 1: CCtCap carried no standalone software DRD at all — its Software Development and Software Safety Plans were delivered as elements of the Certification Baseline Review Data Package (DRD 102, where unmarked content is Type 3) — and HLS Appendices P and H carried their Software Plan (1780SW-002 / 1665SW-002) and Software V&V and Certification Plan (1780SW-001 / 1665SW-001) at Data Type 2. Type 1 subjects every submittal and interim change of the provider's internal software development and sustaining processes to NASA approval before use

— a reach neither comparator required at any phase. Software management for a crewed destination remains substantial and is fully retained: NPR 7150.2D-compliant content would be delivered as a defined section of the SEMP (CLDC-101, recommended elsewhere to be re-typed to Type 2), preserving NASA visibility while eliminating a duplicative standalone approval gate. Note: Further comments are provided on the as-written scope and content of the DRD. This recommendation to delete takes precedence.

The Software Management Plan DRD CLDC-107 is part of several new Agency requirements on new contracts and will not be deleted.

39. Under DRD CLDC-107, please provide the scope/definition of "entity". COTS open source software should not be subject to an entity-specific Software Management Plan (SMP).Please confirm that the Contractor's overarching SMP can serve as an umbrella for the use of COTS software (paid, licensed, and open-source) as entity-SMPs are not practical. Please expand on the definition of "explicitly included" for an over-arching SMP to ensure that the above confirmation is clear.

The term "entity" is meant to encompass key participants that deliver software products for the CLDS, such as subcontracted suppliers, US corporate partners, and international partners if any. The term "explicitly included" is meant to ensure the party supplying the software is identified under the scope of the provider's overall SMP or has their own plan.

40. Under DRD CLDC-107, please clarify what level of detail is expected for a software Work Breakdown Structure.

The level of detail depends upon each offerors software management approach for CLDS (including Utilization).

Review SOW sections 2.10.3 Software Management, 2.11.2 Software Safety & Assurance, 2.15.3 USG Payload and Payload Facility Interface Requirements and Testing, and 2.15.4 USG Payload and Payload Facility Software and Commands/Telemetry, and adapt your companies breakdown approach as appropriate.

Contract Mechanism and Structure

41. Under Section H and Section M of the DRFP, the overall small-business subcontracting goal and category sub-goals remain TBD, although proposed goals are evaluated under M.4.3. Will NASA publish the assessed goals in the Final RFP and confirm that small-business participation embedded in mission services, logistics, research integration, and other subcontracted CLDC scope will receive full evaluation credit?

NASA will update the final RFP to clarify the assessed goals. Small Business participation will be evaluated in accordance with M.4.3 SMALL BUSINESS UTILIZATION (SBU) - MISSION SUITABILITY SUBFACTOR 3.

Pricing & Economic Adjustments

42. In DRFP Section L.17.2, "The offeror shall document any relevant assumptions that are major drivers of the price"; however, Schedule B prices will NOT be subject to future equitable adjustment based on "ground rules" or assumptions document in the proposal. If the base ground rules & assumptions upon which the bidders' estimates are changed, how are offerors to offset the risk in a manner that is commercially viable without substantially increasing the costs to the Government?

If the offeror’s self-identified assumptions or ground rules change, it is their responsibility to offset the risk without increasing the costs to the government.

43. In the Attachment L-08 Cash Flow Tab, the cash flow table has a requirement for Utilization/Habitation (Rows 11-14) and Seat Sales (Rows 16 - 19). Is "utilization/habitation" referring to payload/scientific/etc. projects on-orbit? Habitation pricing is likely included in seat sale. Suggest: (a) remove "habitation" from Rows 11-14 or include "habitation" as part of "seat sale" (Row 16-19).

Attachment L-08 Business Plan Template will be updated in the Final RFP to delineate Seat Sales cash flow by separating Transportation and Habitation as separate costs.

44. In Section B of the DRFP, is it acceptable for the Offeror to provide pricing only for Mission Aend-to-end service, or must the Offeror also provide pricing for Mission A CLD-only service? Offerors must propose both CLD Only and End-to-End Service pricing.

45. Under Section M of the DRFP, clarify how NASA is conducting the unbalanced pricing analysis and what the potential outcomes are of an offeror triggering rejection at CLIN1 and at CLIN2. As outlined in M.3 PRICE FACTOR (VOLUME I), In accordance with FAR 15.404-6(b)(2), a proposal may be rejected if the Contracting Officer determines that the lack of balance poses an unacceptable risk to the Government.

Utilization

46. In SOW Table 1.5-1, for Deployable Pressurized powered payloads - is there a volume estimation for these?

There is no min or max volume estimate. The intent for deployable pressurized powered payloads is that they do not have to be of the locker form factor and are able to be soft stowed for transport. For example, they could be handheld, mounted to a multi-use bracket, or temporarily attached to a workbench or a wall. The final RFP will provide clarification definition.

47. SOW Section 1.6 states: "USG usage rate for the Glovebox is 100% ". This creates a significant constraint on CLD ability to offer commercial services. If necessary to keep in SOW, suggest language that recognizes Offeror will be able to use all idle capacity on glovebox when not actively in use for a US national project.

NASA is updating the Final RFP to address and clarify through a Section H Clause that contractors will have the ability to utilize Excess NASA Capacity.

48. SOW Section 2.14 states: "For any crew or cargo mission, the Contractor shall ensure NASA has first right of refusal of no less than 70% of the available late load and early destow capability." How does NASA define late load capability? How does NASA define early destow capability?

Late load and early destow capabilities are defined by the time-critical cargo requirements in CLDP-REQ-1130 Requirements and Standards for the Commercial Low-Earth Orbit Development Program. Time critical is defined as "Any cargo that is conditioned, limited life, contains biological samples, a powered payload, or is limited by other factors. This type of cargo may require late load capability within 24 hours prior to launch and early destow on- orbit and post landing, to preserve the integrity of the cargo. This type of cargo also may require a replacement prior to launch due to a launch scrub when necessary." Section 3.5 Commercial Cargo Transportation System.

When does NASA plan to exercise its first right of refusal of no less than 70% of the available late load capability?

Final NASA utilization needs will be negotiated as part of CLIN 3 mission task order including first right of refusal of capability.

49. SOW Section 2.17 states: "For any crew or cargo mission, the Contractor shall ensure NASA has first right of refusal of no less than 70% of the available cargo not allocated to crew or vehicle requirements. " Does this mean 70% of remaining cargo after all crew and CLD requirements such as: food, water, consumables, preventative & corrective maintenance, and other hardware required for CLD outfitting to reach full FOC capability? At what point in the process will NASA make the request? i.e., how much notice will Contractor get to know how to complete the manifest?

To clarify, the 70% did refer to the remaining cargo after all crew and CLD requirements such as: food, water, consumables, preventative & corrective maintenance, and other hardware required for CLD. . . However, NASA plans to change the 70% requirement in SOW Section2.17 Transportation in the final RFP to “no less than 25% of the total available cargo supporting the subject increment, not including cargo allocated to crew or Destination needs, for each seat purchased by NASA”.

50. In DRFP Section B and SOW Section 1.2, within the DRFP and the SOW the bidders are required to show how each will meet the capabilities associated with Category 1 - 3 missions. Will NASA require a simultaneous performance, for example, of category 1 and category 3 A, B, & standard missions? If so how many are anticipated, and what is the maximum number of NASA astronauts that could be on the CLD at one time and what is the associated duration for this level of human presence?

NASA is not requiring simultaneous performance of multiple mission types by capability category. The NASA crew and duration requirements are defined for each mission type in SOW 3.3 Mission Services Description (CLIN 3) and NASA’s intent is to only order a specific mission type, one at a time.

51. In SOW Table 1.5-1, what does NASA intend to use the total MLE for at each category level (3 at Cat 1, 20 at Cat 2, and 58 at Cat 3) and what is the intended utilization of each of these categories? Are there plans to outfit these MLE with standard user facilities (microscope, plant habitat, centrifuges etc.)? Would MLE contents and utilization be negotiable with the contractor for commercial use?

NASA's future forecast of payloads is in work. However, in general, Cat 1 was defined to ensure support for (but not limited to) Human Research efforts; Cat 2 supports (but is not limited to) Human Research, Life Science, and Tech Demos; Cat 3 supports (but is not limited to) Human Research, Life Science, Tech Demos, Physical Science, and Plant Research. If NASA develops facilities that have potential for multi-user capability and NASA has excess capacity, that may be offered to the Contractor. A new H Clause, Excess Capacity will be included in the final RFP.

52. The solicitation clearly defines the laboratory infrastructure that providers must deliver but provides little insight into NASA's anticipated utilization. Providing estimates of expected NASA-sponsored research demand—such as projected payload volume, mission cadence, or broad research areas (e.g., life sciences, technology demonstrations, physical sciences, in- space manufacturing)—would help providers optimize station designs and operational concepts.

NASA's future forecast of payloads is in work. However, in general, Cat 1 was defined to ensure support for (but not limited to) Human Research efforts; Cat 2 supports (but is not limited to) Human Research, Life Science, and Tech Demos; Cat 3 supports (but is not limited to) Human Research, Life Science, Tech Demos, Physical Science, and Plant Research.

53. In SOW Table 1.5-1, the SOW shows volumes for frozen samples, but not temperatures. CLDP-REQ-1130 states frozen from -95 to -10C. Does this mean that all the liters in the SOW are for that explicit range? Are there incremental temperature selections needed? And to clarify, there is no need for -160 or snap freeze?

Yes, the liters defined in the SOW are for that explicit range. CLDP-REQ-1130, R.CLDS.579 outlines the requirements for adjustable temperature setpoints within the required temperature ranges for each utilization sample preservation capability, including frozen. Currently, NASA does not require the Contractor to provide - 160 C (snap freeze) capability.

54. Please confirm CLDC-126 obligations apply to USG payload and mission data as described in SOW 2.15.4, and exclude non-USG customer payload data.

In the Final RFP, NASA will update CLDC-126 to be applicable for USG payloads/payload facilities and other USG utilization activities.

55. In DRD CLDC-126, "(3) Ability to meet the Data Security Requirements outlined in CLDP-PLN- 1122, Section 8.1 ... ", which includes the following statement: "Sensitive data will be purged from CLD provider systems two weeks after confirmed ground receipt of data." (1) What is considered as "sensitive data" in this context? (2) We recommend restating this requirement to apply to NASA's sensitive data only: "For each type of data there will be an agreement with the customer regarding its retention on the CLD provider systems, not constrained by NASA requirement."

NASA is evaluating this comment at this time. The intention is that this is applicable to NASA's sensitive data only. Sensitive data refers to controlled technical data (ITAR/EAR), crew biomedical and personal data (PII), and high-resolution earth observation data. If any changes to this requirement are applicable, they will be reflected in the Final RFP.

56. In the DRFP Section B, ADDITIONAL SERVICES, The pricing tables on pages 12–14 appear to request pricing based on NASA utilizing 25% of the workbench and 25% of the glovebox. However, Section 1.6 (page 12) of Attachment J-01, Statement of Work (02 CLDC dSOW July 2026) states that NASA plans to utilize 100% of the glovebox and 50% of the workbench. The utilization assumptions appear to be inconsistent between the pricing tables and the Statement of Work. Please clarify the intended utilization percentages for the workbench and glovebox that offerors should use for proposal development and pricing?

The values are accurate. Section 1.6 NASA Usage of Utilization Capabilities of the SOW is related to the expected NASA use of the capabilities. The pricing tables in question are for Additional Services above and beyond Section 1.6 NASA Usage of Utilization Capabilities.

57. In the DRFP Section B, ADDITIONAL SERVICES, please clarify what constitutes a "Deployable Pressurized Powered Payload".

The final RFP will clarify this definition. The intent for deployable pressurized powered payloads is that they do not have to be of the locker form factor and are able to be soft stowed for transport.

58. SOW Table 1.5-1 lists "# of locations for gaseous O2 Access" (0 / 2 / 2 for Cat 1/2/3) right alongside GN2 Access, and the GN2 row is annotated "(CLDP-STD-1106 Section 3)." The GO2 row carries the same Note 2 pointer to CLDP-STD-1106 by implication, but Section 3 has no GO2 requirement to point to. CLDP-REQ-1130 [R.CLDS.619] changed from nitrogen and carbon dioxide in Baseline to nitrogen and oxygen in Rev D. Does NASA intend for there to be a separate gaseous oxygen resource line, not mentioned in CLDP-STD-1102 and CLDP- STD- 1106, or should this be interpreted as cabin air usage by payloads, with no specific need to provision oxygen gas interfaces?

NASA is not intending to levy more specific gaseous oxygen requirements as we believe the characteristics of the gaseous oxygen used for ECLSS could be used for payloads as needed. CLD Providers may choose to provide access to the same ECLSS gaseous oxygen resource line to fulfill R.CLDS.619 or a separate gaseous oxygen resource line.

59. The SOW Table 1.5-1 expresses Category 3 as 58 MLE locations. CLDP-REQ-1130 R.CLDS.824 caps payload power at aggregate at 8kW with 11kW peak. However CLDP-STD-1102 defines 250W as the power required for a single MLE which could imply a 58 × 250 W (14.5 kW) power requirement for MLE’s alone. We understand reconfigurable locations as not the same as simultaneous full-power draw. Can NASA please confirm in the SOW or 1130 that the MLE count is a physical-location population, bounded by the 1130 R.CLDS.824 aggregate power draw? Further, can NASA please clarify if any deployable payloads, gloveboxes, cold stowage (e.g., MLE’s providing conditioned stowage) power requirements are included in the CLDP- REQ-1130 R.CLDS.824 aggregate 9kW and 11kW peak?

Yes, NASA can confirm that the NASA MLE count is a physical-location population. These, plus the NASA deployable pressurized powered payloads combined are bounded by the values in 1130 R.CLDS.824, which show applicable values for average continuous and average peak power for the summation of NASA payloads.

CLDP-STD-1102 R.CPIS.04 is a reference for the heritage locker payload interface capability, not necessarily what the payload actually will draw. The Table 1.5-1 in the SOW are provisions NASA requires from the CLD Provider. Items in Table 1.5-1 such as on-orbit conditioned Stowage, workbench, glovebox are not provided by NASA, and as such are not considered part of what CLDP-REQ-1130 R.CLDS.824 covers.

60. In SOW Section 1.5, can NASA please define Deployable Pressurized Powered Payloads as they appear in Draft SOW Table 1.5-1? There is a quantity but no cross-reference to a 1130 or 1106 requirement, no power/thermal/data allocation, and no definition distinguishing it from a "reconfigurable locker location (MLE)" or for example a “Low Power USB device.” Are these 4/8/12 payloads a subset of the MLE locations or additive to them? Rationale: this could materially change both the power and the volume budget. If additive, Cat 3's 12 deployables plus 58 MLE locations is a larger interface population. Please clarify counts are location populations bounded by R.CLDS.824 8/11 kW aggregate totals. Please also confirm deployable payload power is intended to be the same 75–500 W configurable feed as R.CLDS.614 (not a separate higher-power interface), so bidders size the power distribution and 28 VDC feed count correctly.

The intent for deployable pressurized powered payloads are that they do not have to be of the locker form factor and are able to be soft stowed for transport. They could be handheld, mounted to a multi-use bracket, temporarily attached to a workbench or a wall, etc. These are in addition to the 4/8/12 MLE payloads. These total counts are indeed bounded by the R.CLDS.824. The deployable power feeds may be the same feed as R.CLDS.614 or a different feed (USB power, 120Vac, etc.) and NASA does not intend to mandate exact implementation. CLDP-REQ-1130 has R.CLDS.693 for power inverter and converter capability as well.

61. DRD CLDC-208 (Payloads Interface Requirements Document / IRD, Data Type 1, p. 224). A payload-hosting destination requires disciplined interface control, so the function is warranted — but CLDC-208 and DRD CLDC-209 (Unique Payload Interface Control Document, Data Type 1, p. 229) split per-payload interface control across two Type-1 deliverables covering a single function. CLDC-209 applies only to interfaces “not covered by the Payloads IRD,” and standard payloads under CLDC-208 are closed via a per-payload Applicability Matrix

— two overlapping vehicles for the same per-payload agreement. Recommend consolidating CLDC-208 into CLDC-209 as a single per-payload interface deliverable (retaining the Blank Book IRD as the standard-interface baseline within it). The recurring per-payload products — each Applicability Matrix and each unique-payload ICD — warrant a time-limited NASA disapproval right (Type 2), not approval prior to release (Type 1). Type 1 places NASA in the approval path of every individual payload's interface documentation, a recurrence multiplier that scales with utilization tempo. The closest predecessor analogue, CCtCap DRD 206 (Internal Cargo Interface Control Agreement), managed per-cargo-item interface definition at Data Type 2. Recommend Type 2 for the consolidated per-payload deliverable. (Companion comment addresses CLDC-209's own data type.)

Note: Further comments are provided on the as-written scope and content of the DRD. This recommendation to delete takes precedence.

CLD Providers may choose to provide a single per-payload interface deliverable as proposed, which will fulfill the 2 DRDs. NASA did not want to mandate that methodology. NASA is considering all DRD recommendations and will respond in Final RFP.

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62. In DRD CLDC-124, recommend making it clear in the DRD that CLDP-PLN-3017 DRMs inapplicable to the Contractor's offered configuration, for example external or unpressurized payload DRMs where that capability is a later or optional service, may be marked not applicable at baseline and added when the capability is offered.

Rationale: The SOW makes certain mission types optional based on the Contractor's configuration. Requiring fully developed integration plans for missions the provider is not offering or offering later in the program produces speculative content NASA must review without a utilization customer who benefits. Marking them reserved keeps the plan accurate and NASA's review effort focused. NASA is updating DRD CLDC-124 Utilization Integration Plan (UIP) in the final RFP to indicate that CLDP-PLN-3017 CLDP UIP is solely to be considered a reference document at this time. CLD Providers are to propose their own utilization integration plan with regards to how they plan to integrate NASA utilization. NASA plans to update the CLDP-PLN-3017 CLDP UIP document to align with the CLD Provider DRD CLDC-124 UIP. The Offeror should include all Additional and Optional Services expected to be available during the period of performance outlined in SOW sections 3.4 Pre-Priced Additional Service Description (CLIN 4), 3.4.1 Additional Services and 3.4.2 Optional Services. The Offeror is not required to propose all NASA identified Optional Services or may include a subset along with what timeframe the items are available. If the services in 3.4.2 Optional Services are not offered or included in the award, they cannot be evaluated. In accordance with Section H clause titled “TASK ORDERING PROCEDURES – SUPPLEMENT”, “After completion of CLIN 1, contractors may propose major changes to the transportation cost, additional enhancements/capabilities …”., and price reductions as part of the CLDC RFTOP process. Contractors are required to provide sufficient detail for NASA to determine required justification to the previously accepted CLDC services and/or a CLDC Configuration Change (e.g., a new Configuration).

63. In DRD CLDC-124, recommend that NASA's own input milestones, in particular delivery of the payload/facility list for a given increment and research planning data, be assigned committed need dates in Launch-minus terms in CLDP-PLN-3017 or the contract. This may be clarified by Figure 6.3.1.1-1 DRM #1, which is missing from CLDP-PLN-3017 Rev B, which should also be corrected. Rationale: The UIP begins at the Design and Analyze phase, triggered by NASA's delivery of the increment payload list, and every downstream contractor commitment (the CLDC-208 six-week Applicability Matrix, the CLDC-125 schedule template, safety review dates) is keyed to that start. Contractor Launch-minus commitments are only executable if NASA's inputs carry equivalent commitments; a bilateral schedule protects the increment for both parties and gives NASA a defensible basis for holding contractors to the downstream dates.

NASA is updating DRD CLDC-124 UIP in the final RFP to indicate that CLDP-PLN-3017 CLDP UIP is solely to be considered a reference document at this time. CLD Providers are to propose their own utilization integration plan with regards to how they plan to integrate NASA utilization including when NASA data is required for integration and planning. NASA plans to update the CLDP-PLN-3017 CLDP UIP document to align with the CLD Provider DRD CLDC-124 UIP.

64. In SOW Table 1.5-1, how does NASA intend to provide sufficient powered-locker capacity during launch and return to support projected research demand, including investigations that…

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