The Space News editorial “Range Upgrades in Limbo,” [July 28, page 18] addressed long-standing issues and expressed very well the frustration of both users and leadership over the slow progress toward a customer-friendly, flexible, efficient national launch capability.

The comment that “…even with the commercial market having moved largely overseas – primarily due to the high cost of rockets…” is correct but does not go far enough. To be sure, both the cost of the ranges and the cost of launch vehicles are major factors contributing to the loss of market share for commercial launch services. U.S. Air Force Maj. Gen. Thomas Deppe, the vice commander of Air Force Space Command who is quoted in the editorial, is correct when he says that much less has been accomplished improving the ranges than should have been over the last 15 years.

However, as important as range improvements will be to the future of commercial space launch, focusing solely on range upgrades overlooks the “elephant in the closet” that has been, and continues to be, a significant impediment to a viable commercial launch industry from Cape Canaveral, Fla., or Vandenberg Air Force Base, Calif. That “impediment” is the oft-stated, but rarely executed, policy on federal launch bases and ranges that “…the government reserves the right to use such facilities and services on a priority basis to meet national security and critical civil mission requirements.” The U.S. Space Transportation Policy of , from which the quote is taken, also directs the government to provide broad support to commercial space activities.

In fact, the specific guidance that contains the quoted provisions begins with the direction that United States government departments and agencies shall: “Provide stable and predictable access to the federal launch bases and ranges, and other government facilities and services, as appropriate, for commercial purposes.”

Obviously, if the government chooses to protect its ability to launch at any time by precluding a commercial entity from “locking in” the range for a specific launch date, even many years in the future, there is no such thing as stable and predictable access for a commercial launch provider.

In the world of commercial launch of payloads such as communications satellites, where every day a satellite is delayed getting to orbit is a day without revenue, satellite owners want assurance that their ride to space will be available when the satellite is ready. When overseas providers can and do schedule commercial launches months and years in advance and often adjust government-sponsored launches to accommodate commercial ones, it is not surprising that foreign providers continue to gain market share.

I doubt anyone would question the appropriateness of a policy that allows the government to have priority access to the range and launch facilities when it is necessary to launch a national security payload to fill an existing or impending gap in capability, or a NASA payload to meet a planetary window.

However, the vast majority – if not all – national security payloads that have flown on Evolved Expendable Launch Vehicles (EELVs) were well behind schedule when delivered to the launch pad. That they were already months late in providing needed capability may be an argument to exercise priority and launch as soon as practicable.

On the other hand, if they were already months late would a delay of another month in the unlikely event that a commercial launch happened to be scheduled for the same time make a significant difference? In some cases, perhaps yes. But when on-orbit checkout and certification will add many more months before the warfighter receives the added capability, the argument for immediate access to launch loses some of its strength.

The government position is largely one of convenience. The launch bases, ranges and EELVs flying today are significantly more operable than the comparable systems were 10 to 15 years ago, when it was common practice to intermix commercial and government launches from the same facilities. To be sure, some systems such as Titan 4, never competed with commercial users for facilities or vehicles – although they did for range support.

It was a very comfortable process for Titan 4 users – and very, very expensive. Those same users are now flying on EELVs, and it is again comfortable, and again, becoming very, very expensive. In that same era, Atlas 2 and Delta 2 from the East Coast and Delta 2 from the West Coast were carrying government and commercial payloads.

It is difficult for commercial launch providers to compete, even on a level playing field, against vehicles produced in non-market economies. However, while the editorial was correct in saying that price is a primary factor, recent experience has shown that even when EELV can offer better capability and lower price, the unwillingness of the government to allow them to provide assured launch dates even several years in the future will cause a major customer to turn elsewhere.

It is reasonable to ask “why should the government bother?” The taxpayers pay for most of the infrastructure and operations, so why shouldn’t “they” always have priority?

There are several answers.

First, it is both law and our national policy to assist the commercial space transportation industry, and has been for two decades. Second, it makes good financial sense: more launches spread the cost. EELV was begun on the premise that the government and commercial users could share the vehicles and facilities. After the commercial market dried up in the late 1990s, we seem to have fallen back into the comfort and expense of the Titan 4 model. Third, launch rate matters. There is excess capacity in the EELV system. More customers means more launches, smoother crew operations and higher reliability. Fourth, having a robust space industrial base is an important element of national security, and launch is a major segment of that base.

The good part about this problem is that many of the things that should be done involve very little cost. They do, however, require the government to accept some launch schedule risk and the perceived inconvenience of sharing facilities with commercial users.

First, the launch planning manifest should be based on “first request, first served.” All this means is that any user can request a future launch date, and if someone else isn’t scheduled for the same period, they are assigned that date. The process should apply during the period the manifest is considered to be firm and indefinitely into the future. It should include access to the facilities needed to prepare the launch vehicle and integrate the payload and enough schedule flexibility to allow for a second opportunity if a launch is scrubbed.

Second, with today’s EELVs, that dedicated prelaunch vehicle preparation should be measured in one to two weeks, and the “second opportunity” in one or two days. Limiting any launch customer’s access to the pad and vehicle processing facilities to the time required by the launch vehicle is a major change from today’s practice, where once a national security customer is “on the pad” they often remain there until launched – even if that means weeks or even months waiting to resolve a payload or vehicle issue.

The launch sequence is nearly inviolate. A better approach is, very simply, “if you aren’t ready, get out of the way, and move into the next available launch window.”

Third, the launch bases have the insight and ability to manage this kind of process, especially if every user knows they will be treated fairly and so is willing to participate in schedule negotiations. A centrally managed, national launch manifest set one or more years in advance is attractive to those government users who are given a spot in the launch sequence. However, one of the downsides to centralized manifest preparation is that it essentially takes away the ability of the launch wing to adjust the schedule to best serve the most customers while still preserving the overall priorities and meeting mission needs.

In the very rare circumstance when there is a true national priority for a launch, and the government’s rocket and payload are ready, they would be given launch priority – for the few weeks it should take to execute the launch process. The procedures for doing this exist – although I don’t think they have ever been used. Similarly, if a “pop-up” commercial payload is “ready to go” when a government launch is scheduled but not ready, the government should step aside and let the commercial launch have priority.

As different as this sounds in today’s launch environment, not only did the government integrate with commercial launches in the 1990s, a government Atlas 2 that was launching a scheduled replenishment was swapped with a pop-up commercial launch so the commercial provider could launch sooner. EELVs were designed with this kind of “interchangeability” in mind. It would be a shame if they became “tail-number- unique” to specific users or payloads as was the case with Titan 4, although this appears to be becoming the normal practice.

When the EELV program began in 1995, most of those involved believed it would lead to a transformation of the approach to expendable launch.

It was a public-private partnership, with development costs shared between industry and government, and with the full expectation that the vehicle(s) would enable a robust government and commercial launch capability as well as assured access for the nation’s highest priority payloads.

In a technical sense, the program achieved its goals – the vehicles are significantly more operational and reliable; costs are significantly lower than if today’s satellites were being launched on the legacy Titan/Atlas/Delta families. We’ve lost ground, however, in competing for space launch business on the world market.

The recent initiative by Air Force Space Command to have commercial advocates at the two launch wings is a good step. Senior leadership involvement in accelerating the range modernization is a good step. Addressing the policy and procedural practices to assure that commercial launch is afforded the same launch opportunities that are available to competitors at their government-sponsored ranges around the world would be “major.”

It’s up to commercial providers, United Launch Alliance for the EELV and others as they reach operational status, to make available a product that is competitive in capability and price. There are commercial customers that need assured access, would welcome the reliability and capability of launch provides and would consider a reasonable competitive price premium if range launch schedule could be assured. It is incumbent on the government, and it is in the government’s own best interest, to not only eliminate barriers to commercial success, but to facilitate commercial launch whenever and wherever possible.

Robert Dickman is executive director of the American Institute of Aeronautics and Astronautics, a member of the U.S. Air Force Scientific Advisory Board, and a retired Air Force major general with more than 30 years experience in space operations, acquisition and planning. The views expressed are his own.