19, 2001

Dr. Daniel R. Mulville
Acting Administrator
National Aeronautics and Space Administration
Washington, DC 20546

Dear Dr. Mulville:

The International
Space Station Management and Cost Evaluation (IMCE) Task Force reported
its findings to the NASA Advisory Council (NAC) at a meeting on November
6, 2001. The IMCE Task Force was chartered to perform an independent external
review and assessment of cost and budget and to provide recommendations
on how to ensure that the International Space Station (ISS) can provide
the maximum benefit to the U.S. taxpayers and the International Partners
within the Administration’s budget request. The NAC discussed the IMCE
report at a second meeting on December 6-7, 2001. Although the IMCE Task
Force was not charged with considering the international aspects of the
ISS program, we believe that the response of the International Partners
to the IMCE report should be taken into account; consequently, the NAC
invited comments/views from the ISS Partners and others, which were presented
at the December 6-7 meeting.

The NAC unanimously
and completely endorses the findings and specific recommendations of the
IMCE Task Force report (Enclosed) and adds the comments and perspectives
listed below. We are grateful to the IMCE Task Force for their dedication,
thoughtful analysis and hard work.

The IMCE Report Proposes
a Strategy to Restore Confidence in the ISS Program

The International
Space Station is the largest and most challenging international engineering
project ever undertaken. After years of careful preparation, completion
of the ISS construction phase is imminent. Dedicated efforts by NASA centers,
industrial contractors, and the ISS International Partners have begun
to realize an impressive technical success. Nonetheless, the viability
of the entire international human space flight enterprise is being undermined
by a loss of confidence in NASA’s ability to exercise adequate management
and cost discipline in the ISS program. The deficiencies in NASA’s management
and financial control of the ISS program identified in the IMCE report
cannot be excused and must not be ignored. Resolving these deficiencies
will require major restructuring of the management, budget, infrastructure,
and staffing of NASA’s human space flight enterprise.

The NAC recommends
that NASA focus on executing the “U.S. Core Complete” configuration defined
in the President’s FY 2002 Budget Blueprint. The NAC agrees with the widely
held view that the U.S. Core Complete configuration, which supports only
a three-person crew, is far from optimal as an end-state for the ISS.
Nevertheless, no commitments to augment the U.S. Core Complete configuration
should be made until NASA’s restructuring and consolidation efforts restore
confidence within the NAC, the Administration, and Congress in the management
and financial controls of the ISS program. This “period of consolidation”
can last no more than two years.

The NAC recommends
that during the period of consolidation, NASA demonstrate to an independent
panel its progress in resolving the identified deficiencies in management
and financial control. If NASA agrees, the NAC could establish an ad-hoc
subcommittee to fulfill this independent review function. Progress should
be reported against a specific set of goals, metrics, and milestones.
The NAC recommends that the starting point for this set of metrics and
milestones be the enclosed set of “ISS Goals for the Consolidation Period.”
These goals link together the Specific Recommendations of the IMCE, the
further deliberations of the NAC, and NASA’s own “Core Values” as expressed
in its Strategic Plan.

The NAC emphasizes
that the ISS Goals for the Consolidation Period in no way are meant to
dilute or substitute for the Specific Recommendations of
the IMCE, which the NAC endorses fully. The Specific Recommendations
are the “game plan” that NASA must follow to regain program credibility,
the goals are the “scorecard” against which NASA should be judged, and
there must be an independent “scorekeeper.”

Throughout the period
of consolidation, NASA should consult with the ISS International Partners
to ensure ongoing understanding of the progress in meeting the milestones
for the U.S. Core Complete configuration as well as the associated re-establishment
of credibility.

The Goals of the U.S. International
Space Station Program Are Not Well-Defined

The NAC notes that
neither short-term nor long-term priorities for the United States’ uses
of the ISS have been firmly and clearly established. The relative priorities
of exploration, international cooperation, research, education, and commerce
have not been clarified. Given this lack of clarity, it is not surprising
that there is little public understanding of why the United States’ is
building the ISS.

The focus of the ISS
program must now change from development and construction to operation
and utilization. Indeed, this change is overdue. The IMCE recommended
that scientific research be the primary driver of U.S. ISS usage. The
IMCE stated that of the many scientific areas where the ISS can make a
contribution, the investigation of the biological, physical, sociological,
and psychological limits on long-term, complex human activity in space
is the one area that uniquely requires the ISS. The NAC believes that
if intelligently led by a broad research program on the ground, this area
of research can form the core of a widely accepted primary rationale for
ISS operations.

The NAC recommends
that NASA announce a small number of ordered priorities for U.S. scientific
usage of the ISS immediately. The priorities should be addressed in order
of importance in the operations of the ISS and should be used in the design
of the management approach to the operations and utilization phase. The
IMCE recommended that science be represented in ISS management as the
Deputy Program Manager, and the NAC concurs with this recommendation.

The IMCE Strategy Raises Serious
Issues for the ISS International Partners

Since the Terms of
Reference for the IMCE did not include international considerations, the
discussions and recommendations below are those of the NAC.

The strategy proposed
in the IMCE report raised issues for the ISS International Partners (hereinafter,
Partners) that go beyond NASA’s ability to address alone. The Partners
have unanimously declared that the U.S. Core Complete configuration does
not fulfill the U.S. commitment to the “Assembly Complete” configuration
defined in the Intergovernmental Agreement reached by the Partner nations,
and in the Memoranda of Understanding between NASA and the Partner agencies.
The Partners characterize the U.S. commitment to a period of consolidation
aimed at executing only the U.S. Core Complete configuration as a material
change, thereby requiring formal consultation. In addition, the Partners
have expressed a desire for the United States’ to “signal” its intentions
to return eventually to a six/seven-person crew capability. In this regard,
the NAC recommends that NASA seek clarification of the U.S. Government’s
position concerning the possibility of an eventual enhancement of the
capabilities of the ISS beyond U.S. Core Complete and of possible paths
by which such enhancements might be achieved.

The NAC recommends
that NASA continue ongoing formal and informal discussions with all of
its Partners. The discussions should include plans to inform the Partners
of NASA’s progress in restoring credibility in its management of the ISS
as well as plans to consider cooperative strategies to augment the U.S.
Core Complete configuration. The NAC believes that the three-person U.S.
Core Complete configuration is a seriously inadequate end-state, and recommends
that NASA and its Partners seek ways to realize the full potential of
the ISS for research and other uses.

The NAC recommends
that throughout the period of consolidation, NASA preserve the option
of an eventual return to the capabilities represented by the Assembly
Complete configuration. This will require continued funding of certain
key elements that would otherwise be deleted in the U.S. Core Complete

NASA Cannot Afford to Delay

NASA is facing an
urgent management challenge. The IMCE report communicated its seriousness
and proposes a strategy forward. We believe that if the IMCE strategy
is supported by Congress and the Administration, NASA could indeed restore
confidence in its management and financial control of the ISS program,
but only if it acts on the IMCE recommendations without delay. Otherwise,
the ISS could well end up being viewed by the United States and world
public as not meeting its extraordinary full potential.

We have never known
NASA to fail to rise to a challenge once it becomes clear. The challenge
is clear.


Original Signed

Charles F. Kennel

NASA Advisory Council


IMCE Report

Enclosure to Letter from NASA Advisory Council Regarding
the International Space Station Management and Cost Evaluation (IMCE)
Task Force Report

ISS Goals for the Consolidation

The table below lists
14 goals for the ISS program, against which its performance should be
evaluated during the period of consolidation. The goals are organized
into four categories, aligned with NASA’s Cross-Cutting Processes, and
are linked to the IMCE Task Force’s Specific Recommendations
(S.R.), the further deliberations of the NAC, and NASA’s own Core Values
as expressed in its Strategic Plan. [While the Specific Recommendations
form the “game plan,” the goals are the “score sheet.”]

1. NASA must
maintain a focus on technical excellence and crew safety.
NASA Strategic
Plan – Core Values
2. NASA must
develop a process to identify, report and balance the tension between
near and longer term program goals.
S.R.3b and
manage the ISS Program to cost and schedule as well as fiscal year
3. NASA must
adopt a management approach for ISS, which allows for direct program
control of personnel resources, as well as streamlined management
visibility, reporting, control and accountability.
S.R.1 Establish
the ISS Program Office separate from, but residing at JSC, reporting
to a new Associate Administrator (AA) for the ISS.
4. NASA must
adopt a contractor management approach that simplifies the contract
relationships, and allows the program direct visibility into and control
of contractor performance.
S.R.2 Consolidate
prime and non-prime contracts into a minimum number of resulting contracts
all reporting to the program office.
5. NASA must
develop a robust process, supported by modern MIS tools, to create,
update and make visible cost and earned value estimates independent
of contractor proposals.
S.R.3 (included
within) Establish a state-of-the-art management information system.
Establish a state-of-the-art planning and control system, including
independent cost estimating capability.
Aerospace Products and Capabilities
6. NASA must
identify, standardize and control the design baseline for U.S. Core
Complete, and [independently] verify the associated budget and schedule.
S.R.3a Develop
a life cycle technical baseline
7. In the absence
of events beyond the control of the program, NASA must execute the
program to U.S. Core Complete over the next 2 years.
S.R.4 Consider
revising the ISS crew rotation period to 6 months and reducing the
Space Shuttle flight rate accordingly. S.R.5 Continue to examine Strategic
Resource Review and Institutional cost reductions.
8. NASA must
clearly define an achievable expanded end-state capable of achieving
the full science and research potential of the ISS, and develop an
independently verified budget and schedule to accompany that expanded

S.R.6 Develop
a credible roadmap starting with U.S. Core Complete and leading
to an end-state that achieves expanded research potential. Include
gate decisions based on demonstrated ability to execute the program.

S.R.7 Identify
funding to maintain critical activities for potential enhancement

9. NASA must
respect the provisions for design interfaces and operational accommodations
of the International Partners, as stipulated in the IGA and MOUs,
and as negotiated and interpreted by the U.S. Government.
NAC deliberations.
10. NASA must
develop and implement approaches to maximize the science and research
utilization of the ISS for the U.S. Core Complete station.
S.R.11 Provide
additional crew time for scientific research through the use of extended
duration Shuttle and overlap of Soyuz missions.
11. NASA must
establish a science and research utilization management structure
and process that ensures that the interests of the science and research
users – whose activities are the driving purpose of the ISS – have
a strong voice in management decisions.
S.R.12 Create
a Deputy Program Manager for Science position in the ISS Program Office.
Assign a science community representative with dual responsibility
to the Program and the Headquarters Office of Biological & Physical
12. NASA must
establish the science and research priorities for the ISS, and develop
a plan allocating available financial resources for research infrastructure
consistent with these priorities.

S.R.8 Establish
research priorities. The Task Force is unanimous in that the highest
research priority should be solving problems associated with long-duration
human space flight, including the engineering required for human
support mechanisms.

S.R.9 Provide
the Centrifuge Accommodation Module (CAM) and centrifuge as mandatory
to accomplish top priority biological research. Availability as
late as FY08 is unacceptable.

S.R.10 Establish
a research plan consistent with the priorities, including a prudent
level of reserves, and compliant with the approved budget

13. NASA must
develop and implement a plan to communicate the results of the ISS
to the scientific and research community, and more generally to the
American public.
NAC deliberations.
14. NASA must
communicate progress towards accomplishment of these goals to the
NAC, the Executive Office of the President, and to the Congress.
NAC deliberations.