The Government Accountability Office (GAO) issued a new report today raising more warning flags about delays in the commercial crew program that could imperil NASA’s ability to ensure U.S. astronauts are always aboard the International Space Station (ISS). GAO made five recommendations to NASA. The agency agreed or partially agreed with four, but rejected a fifth that called for informing Congress about NASA’s own schedule analysis rather than just repeating estimates provided by the companies building the systems, Boeing and SpaceX. GAO is also concerned about inconsistencies in how different parts of NASA view the Loss of Crew safety metric.

NASA has had to rely on Russia to take crews to and from the ISS on Russia’s Soyuz spacecraft since it retired the space shuttle in 2011. It currently pays the Russian government $82 million per seat, but that contract is ending. Five additional Soyuz seats became available through a financial settlement between Boeing and the Russian space company Energiya over an unrelated matter and NASA bought those seats from Boeing. All together, November 2019 is the last seat NASA has on a Soyuz to bring a crew member home. Negotiating a new contract could be difficult and, in any case, Russia has said in the past it takes three years to build a Soyuz so there is insufficient time.

Boeing and SpaceX were selected by NASA in 2014 to build commercial crew transportation systems so the United States can once again launch its own astronauts. The availability dates for Boeing’s CST-100 Starliner and SpaceX’s Crew Dragon have been slipping each year. Each company is expected to make an uncrewed test flight followed by a crewed test flight that will then allow NASA to certify the systems for routine flights. Although NASA’s Commercial Crew Program (CCP) website lists dates for the uncrewed and crewed test flights, NASA officials have hinted for months that new dates will be announced soon.

GAO’s assessment is that the systems will not be certified until the end of 2019 or early 2020, after the Soyuz seats no longer are available. It warned in a February 2017 report, in testimony to Congress in January 2018, and again today that NASA needs a contingency plan for ensuring that U.S. astronauts can remain aboard ISS if the commercial crew systems are not ready by the time the Soyuz seats run out.

In today’s report, GAO cites NASA officials as saying that “sustaining a U.S. presence on ISS is essential to maintain and operate integral systems, without which the ISS cannot function.” Nonetheless, NASA Associate Administrator for Human Exploration and Operations (HEO) Bill Gerstenmaier has said to GAO and in public only that he is “brainstorming” options. Among them is the possibility of extending the duration of the U.S. missions aboard ISS so fewer trips back and forth are needed or using test flights essentially as operational flights.

GAO again recommended that NASA decide on a contingency plan. NASA agreed, but provided no details other that saying it would complete the action by December 31, 2018.

Congress requires NASA to report quarterly on the progress of the program, but GAO said NASA only provides the Boeing and SpaceX schedule estimates, not NASA’s own schedule risk analysis (SRA), which places the certification dates much later than the companies’ data. For example, GAO says that the contractors have notified NASA that their certification milestones have slipped to January 2019 for Boeing and February 2019 for SpaceX, while NASA’s analysis concluded there is “zero percent chance” those dates will be met.

GAO recommended that NASA provide the results of its analysis to Congress together with the companies’ assessments. NASA did not agree. In their response to the report, published as an appendix, Gerstenmaier, NASA Chief Engineer Ralph Roe, and NASA Chief of Safety and Mission Assurance Terry Wilcutt wrote that NASA uses the companies’ schedules as a “baseline and to provide a qualitative statement regarding milestone schedules” and considers that to be “appropriate” and sufficient to meet congressional requirements.

“NASA is protecting for future schedule adjustments,” they continued, and will work to “ensure the partners’ schedules and NASA’s internal assessments are in agreement” as the systems get closer to launch.

GAO rejoined that it considers its recommendation valid because such information would “provide Congress with valuable insight into potential delays, which are likely. Both contractors have repeatedly stated that their schedules are aggressive and that the dates are ambitious.” So far, “Boeing has delayed its certification milestone by 17 months and SpaceX by 22 months since the original schedules were established.”

One of the issues highlighted in today’s report is that the companies and various parts of NASA have inconsistent views of the Loss of Crew (LOC) requirement that the companies must meet. LOC is a statistical probability that one or more crew members could die or be permanently disabled because of the system’s performance. The contracts with the companies require their systems to meet a 1 in 270 LOC threshold. That value is used by the companies and NASA’s Commercial Crew Program (CCP) office. However, NASA’s certification review uses a less stringent 1 in 150 threshold and NASA’s Chief Safety and Mission Assurance (SMA) Officer uses 1 in 200.

Complicating it further, NASA has updated its models of space debris, one of the factors that feed into the probabilistic risk assessment, and some LOC estimates take account of mitigation steps while others do not. GAO provided a chart comparing how the the agency certification process, the CCP program office, the contracts with the companies, and NASA’s SMA Office set the requirement, whether the updated or former debris model is used, and whether mitigation measures are taken into account.

Consequently, “NASA does not have a consistent approach for how to incorporate key inputs to the probabilistic safety analysis” and the “risk tolerance NASA is accepting with loss of crew varies based upon which entity is presenting the results…”

GAO recommended that the NASA Administrator direct the Chief of Safety and Mission Assurance, the Associate Administrator for HEO, the Commercial Crew Program Manager and the Commercial Crew Contracting Officer “to collectively determine and document before the agency certification review how the agency will determine its risk tolerance level with respect to loss of crew.”

Gerstenmaier, Roe and Wilcutt partially concurred in their letter. They argued that it is already documented and listed the documents that variously set the threshold at 1 in 150, 1 in 200, or 1 in 270. They agreed it is “confusing.” Their bottom line is that it is the CCP program office’s responsibility to see that the commercial crew systems meet the 1 in 270 threshold and, if they cannot, to request a waiver from NASA Headquarters as part of the certification process.

That ties in with another GAO concern — that the individual in charge of independently ensuring NASA is abiding by safety requirements (the “technical authority”) is dual-hatted with programmatic responsibilities. GAO raised this issue last year with regard to how NASA’s human exploration program is organized.

In today’s report, GAO said “[w]e have found that having the same individual simultaneously fill both a technical authority role and a program role created an environment of competing interests” that undermines impartial and objective assessment.

It therefore recommended that the technical authority and programmatic responsibilities be separated. NASA agreed and said it would complete that action by the end of August.