Op-ed | ISS doesn’t have to be an FFRDC; It has to be done right
This op-ed originally appeared in the May 20, 2019 issue of SpaceNews magazine.
Few terms in space policy — save maybe “commercial” and “innovation” — are used with quite so much zest and abandon as the term “FFRDC,” or Federally Funded Research and Development Center. An FFRDC is a specific kind of independent research entity formed as public-private partnership with the federal government. There are currently 43 FFRDCs in operation and they are governed by Part 35.017 of the Federal Acquisitions Regulations.
FFRDCs have re-entered the space policy conversation once again, this time in connection to the International Space Station. One idea gaining traction is the creation of a National Microgravity Research Laboratory to manage, among other things, operations of assets like the U.S. orbital segment of the ISS. Creating some sort of organization to help the United States in the in-situ exploitation of microgravity — turning it from a challenge into a kind of “resource” — is an excellent idea. If the space environment itself yields a way to generate value, rather than just creating costs and difficulties, then maintaining a national presence in space becomes much simpler and cost effective.
Under Section 504 of the 2010 NASA Authorization Act, the U.S. orbital segment (aka ISS National Lab) is to be managed by a nonprofit organization, a role that is filled today by the Center for the Advancement of Science in Space. However, a particularly restrictive part of this law, Section 504 (a)(3), forbids the organization managing the ISS National Lab from having any sort of other priorities. A particularly strict reading of that section could be read as forbidding the managing organization from having any broader goals, like the development of a robust economy in low-Earth orbit or helping NASA manage its shift in focus to deep space exploration. Both of which have been identified as priorities in recent NASA budget requests.
This issue has spurred the discussion in which the term FFRDC has been used so freely. Colloquially, the term “FFRDC” is used to mean anything from “I wish this capability weren’t quite so expensive” to “the status quo management structure isn’t cutting it.” The problem is that “FFRDC” refers to a very specific thing. Using FFRDC as a kind of synecdoche for a more general idea like “public-private partnership” or “quasi-governmental organization” is understandable, even if a bit misleading. Unfortunately, conversational shorthand has a remarkable way of becoming conventional wisdom and accepted “fact.”
An FFRDC is a very particular legal instrument. Just as one would with any other instrument acquired for a particular space mission, one must first start with a process to define requirements before choosing the instrument. Long experience has borne out the idea that simply picking a tool, design, or product off the shelf without any real understanding of operations and objectives is usually a recipe for disaster. Arbitrarily proclaiming that an FFRDC is going to be the best organizational structure for a National Microgravity Research Laboratory absent any real understanding of what authorities it must have or roles it should fulfill is an invitation to confusion and failure.
While the Space Frontier Act is not law, its Section 303(b) — calling for a feasibility study of an FFRDC structure for a National Microgravity Research Laboratory — is still a good idea. Movement of legislation can be difficult and hard to predict. It is better to go and explore and understand an issue than to wait in ignorance for the passage of a law directing understanding. Responsible stakeholders need to start moving on this issue now, with or without instructions from on high.
The space policy community really needs to fully understand what a National Microgravity Research Laboratory might do, what authorities it needs, how it will manage its affairs and so on. Once these features have been thought out, then it will be time to figure out what legal structure is best suited to meet America’s national needs in LEO. Simply defaulting to the creation of an FFRDC and then hoping it will work is liable to be a disastrous diversion at a time when key decisions about the future of the ISS are fast approaching.
G. Ryan Faith is a policy consultant for Exocent Strategies and a former House Science, Space and Technology Committee professional staff member.