The White House Office of Management and Budget (OMB) sent Senate appropriators a list of complaints about actions taken on FY2020 appropriations bills so far. Among them is the Commerce-Justice-Science (CJS) bill that funds NASA and NOAA where OMB criticized underfunding of NASA’s lunar exploration budget, what rocket will launch the Europa Clipper mission, and a study about potential spectrum interference with weather satellites. Conversely, it praised funding for establishing a Space Force at DOD, although Congress has not yet passed legislation authorizing its creation.

The October 23 letter from Acting OMB Director Russell Vought warns that the bill provides too little money for the Artemis program and raises the cost of the Europa Clipper mission by insisting it be launched on the Space Launch System (SLS). It also rejects a directive that NOAA study the impacts on weather satellites of assigning frequencies for 5G mobile communications in the 23.6 to 24 Gigahertz (GHz) band of the electromagnetic spectrum.

Regarding Artemis, the letter states that insufficient funds are provided for NASA’s Exploration Research and Development account to adequately fund human lunar landers.

The Administration appreciates the Committee’s continued support for space exploration, reflected in the $22.8 billion provided in the bill for NASA, which includes an increase of $680 million for lunar-focused exploration programs. However, the $1.6 billion provided for exploration research and development (R&D) is insufficient to fully fund the lander system that astronauts would use to return to the Moon in 2024. Funding exploration R&D at the $2.3 billion level requested in the FY 2020 Budget is needed to support the Administration’s goal of returning to the Moon by 2024. — OMB Letter

The human lunar landers are essential to the Trump Administration’s goal of landing the first woman and the next man on the Moon in 2024, the last year of a Trump presidency assuming he is reelected. NASA is currently evaluating proposals from industry to build those landers as public-private partnerships and hopes to award contracts in January. The Senate version of the CJS bill provides $744 million, about half the request ($363 million in the original March 11 request plus $1.04 billion in the May 13 supplemental). The House version of the bill ignored the supplemental entirely.

The complaint about Europa Clipper is that the bill requires the mission to Jupiter’s moon to be launched on SLS. NASA has not said how much an SLS launch will cost, but in this letter OMB estimates it at “over $2 billion,” substantially more than a commercial rocket like Atlas V or Falcon Heavy.

The bill requires that NASA use the Space Launch System (SLS) rocket to launch the Europa Clipper mission. The Administration is deeply concerned that this mandate would slow the lunar exploration program, which requires every SLS rocket available. Unlike the human exploration program, which requires use of the SLS, the Europa mission could be launched by a commercial rocket. At an estimated cost of over $2 billion per launch for the SLS once development is complete, the use of a commercial launch vehicle would provide over $1.5 billion in cost savings. The Administration urges the Congress to provide NASA the flexibility called for by the NASA Inspector General and consistent with the FY 2020 Budget request. — OMB Letter

NASA’s March 11 FY2020 budget request documentation, which typically would be reviewed by OMB, states that launching on a commercial rocket would save $700 million. This OMB letter more than doubles that to “over $1.5 billion.” It did not explain why the savings estimate increased so dramatically in just 7 months.

NASA plans to use SLS only to launch humans to the Moon and Mars, but SLS advocates, including Senate Appropriations Committee chairman Richard Shelby (R-AL), want it to be part of the U.S. stable of rockets available for many purposes. SLS is managed by Marshall Space Flight Center in Huntsville, AL. The advantage of using SLS for missions like Europa Clipper is that it has enough thrust to launch larger spacecraft and send them directly to destinations in deep space instead of requiring a series of gravity assists from various planets that add substantially to how long the trip takes.

The problem is its price. There are several ways to calculate that price — marginal cost (the cost of adding one more to an existing cadence of launches), average cost (the total amount spent in a year divided by the number of launches), or full cost (the total cost of the program, including development, divided by the number of launches). OMB did not specify which of those methods was used to determine its $2 billion cost estimate, or what data were used to calculate it, but there is no question that SLS will be very expensive. Another wrinkle is that SLS is very late and the first launch is not expected until 2021. Boeing can build one SLS core stage per year and NASA needs the first three to put astronauts on the Moon by 2024. Congress previously directed in law that Europa Clipper must be launched in 2023, although this year’s Senate CJS bill does not specify a year (the House version does). It is not at all clear that an additional SLS core stage could be completed in that time frame, hence OMB’s concern that “this mandate will slow the lunar exploration program, which requires every SLS rocket available.” SLS advocates argue that Boeing soon will be able to produce them more quickly, but NASA Administrator Jim Bridenstine expressed considerable skepticism about that at a recent House Appropriations Committee hearing.

OMB also wants Senate appropriators to remove language requiring a study by NOAA about use of the 23.6-24 GHz band.

The Committee report includes language that would direct the National Oceanic and Atmospheric Administration (NOAA) to study the impacts that instruments operating in the 23.6 to 24 gigahertz bands have on weather satellites. Such a study would be directly duplicative of past Agency studies on this subject, which were fully considered by the Administration in a lengthy interagency process earlier this year, leading to a carefully-wrought compromise that balances the spectrum needs of government and private enterprise. The Administration believes that further study is unnecessary, and asks that the language be removed. — OMB Letter

Insatiable demand for mobile broadband communications has led to development of terrestrial 5G networks, which require the assignment of more and more frequencies to make them work. The electromagnetic spectrum is a finite natural resource that must be carefully managed to ensure that systems do not interfere with each other. The FCC assigns frequencies to non-government users while the National Telecommunications and Information Administration (NTIA) in the Department of Commerce does that for government agencies. Tensions are growing between government and non-government (private sector) users, and between terrestrial and satellite systems.

The FCC is assigning frequencies for terrestrial private sector 5G systems that are close to those used by government weather satellites. Meteorologists are concerned that transmissions from mobile devices in the 23.6-24 GHz band will interfere with collection of data from weather satellites, especially measurements of water vapor in the atmosphere. Despite studies by NASA and NOAA showing potential interference from out-of-band emissions in that portion of the spectrum, the FCC insists there is no problem. House Science, Space, and Technology Committee Chairwoman Eddie Bernie Johnson (D-TX) has written letters to the FCC asking for the technical analysis the FCC used to make that determination, but had not received a reply as of October 23. The Senate language would require another NOAA study. OMB objects.

OMB is, however, happy that the Senate created a new budget line item for the Space Force in the Defense Appropriations bill and provided the requested funding.

The Administration greatly appreciates that the Committee establishes an “Operations and Maintenance, Space Force” appropriation within the Department of Defense (DOD) for the first time and has provided the requested funding for the initial operations of the United States Space Force. The Administration looks forward to working with the Congress to complement the Committee’s work by modifying Title 10 of the United States Code to establish the Space Force as the sixth branch of the Armed Forces in FY 2020. — OMB letter

The request was $72.4 million. The House version of the bill provides only $15 million. President Trump wants to create a Space Force as a sixth military department within the Air Force, analogous to the Marine Corps, which is part of the Department of the Navy. That requires action in the National Defense Authorization Act (NDAA) as well as appropriated funds. The House and Senate have passed their versions of the FY2020 NDAA and are trying to reach a compromise on a final text. They have different views on Space Force — the House bill calls it a Space Corps, for example — but it is widely expected that something will be created. Differences over other parts of the bill, especially funding for Trump’s border wall, are holding up agreement on both the NDAA and the Defense Appropriators bill.