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Air Force Space Command
Impediments and New Approaches for
Leveraging Commercial Satellite
Communications in Support of the Air
Force and Department of Defense
White Paper
Distribution A: Approved for public release; distribution unlimited
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IMPEDIMENTS AND NEW APPROACHES FOR LEVERAGING
COMMERCIAL SATELLITE COMMUNICATIONS IN SUPPORT OF THE
AIR FORCE AND DEPARTMENT OF DEFENSE
16 AUGUST 2013
1. PURPOSE The purpose of this paper is to suggest a new way to leverage commercial sources to provide satellite
communications services (here after referred to as Commercial Satellite Communications or
COMSATCOM for short), satisfying warfighter requirements, from an acquisition and operational
perspective. AFSPC has studied opportunities to leverage COMSATCOM services for a number of years
and identified a path forward to realize the continued satisfaction for growing DoD satellite
communication (SATCOM) requirements in the current fiscally constrained environment. The Space
and Missile Systems Center (SMC) specifically studied the feasibility of using commercial satellite
components and systems to meet future military communications needs requiring military and
commercial frequencies. SMC has also examined innovative business arrangements to “buy”
COMSATCOM capabilities versus the widely used “lease” process employed today. This paper suggests a
complementary operational business arrangement with commercial satellite Owner/Operators that
provide SATCOM services to the Department of Defense (DoD). This operational approach takes
advantage of the respective operational strengths on both sides, military and commercial, and
recommends integrating their inherent processes and capabilities to provide synergistic effects that
ultimately benefit the warfighter. AFSPC is in a unique position with compelling airborne SATCOM
mission needs to define and advance an affordable path to a higher performing communications
enterprise.
This paper is also intended to solicit feedback with specific focus on identifying any specific conditions
which must be met in order for this concept to succeed. Commercial and military SATCOM systems are
typically associated with spectrum allocated for commercial use and exclusive federal/military use
respectively. However commercial industry is being proactive by investing their own money and
designing their COMSATCOM payloads with the ability to support users reliant on commercial or
federal/military spectrum.1 For the purposes of this paper, a COMSATCOM system that is also equipped
with federal/military frequencies will continue to labeled as a COMSATCOM system since in every other
respect it remains fundamentally a commercial system.
1 Britton, Turner, Space News, 15 July 2011, "Global Xpress satellite will each carry a commercial Ka-band
payload and a high-capacity payload that can be toggled back and forth between commercial Ka-band and
military Ka-band frequencies….”
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2. BACKGROUND Historically, the DoD’s preference for Military SATCOM (MILSATCOM) systems over COMSATCOM
services2 was driven by MILSATCOM’s superior technology and capabilities. However, after 9-11
terrorist attacks, DoD’s operations supporting overseas contingency missions triggered a dramatic
growth in COMSATCOM. COMSATCOM services were readily available on the spot market, commanding
top prices, setting the precedent to buy COMSATCOM services in the most inefficient way. After 10
years, the DoD continues to inefficiently buy COMSATCOM services on the spot market. Given the
extreme fiscal challenges that face the DoD, It is imperative to address the policies, processes, and
culture impediments that paralyze the DoD from entering into innovative business arrangements to
acquire COMSATCOM services.3
Annual Overseas Contingency Operations (OCO) funding has been appropriated by Congress for several
years to support military operations in Iraq and Afghanistan. OCO funding is above and beyond the
normal Department of Defense (DoD) base budget and not subject to spending caps under the Budget
Control Act. While appropriated for several uses, the DoD has used OCO funding to lease COMSATCOM
bandwidth. Leases are primarily secured through Defense Information System Agency (DISA) contract
vehicles to support missions Outside the Continental United States (OCONUS). OCO funding for
COMSATCOM leasing typically equates to a one year obligation period for operations and maintenance
resulting in expensive one-year contracts to lease transponders worldwide. In 2010 alone, the DoD
spent $640M on Fixed Satellite Services leased COMSACOM bandwidth.4 With OCO funding being
eliminated by FY14, it is imperative for the DoD to find more affordable acquisition models and
progressively improve service management to reduce COMSATCOM leasing costs.
In addition to the current acquisition inefficiencies induced by annual leasing, COMSATCOM resources
leased for various DoD organizations are managed in isolation from one another. Commanders have
limited situational awareness and control of COMSATCOM resources. The DoD is highly dependent on
COMSATCOM for numerous missions, these systems are vulnerable to the same jamming, cyber, and
kinetic threats as Military Satellite Communications (MILSATCOM) systems; yet there is no requirement
(e.g. contractual) or mechanism for Commercial Owner/Operators to share timely “attack” information
or balance service loads impacting their systems supporting military operations.
2 COMSATCOM services include both space and ground enterprises that can be leveraged to more affordable
value. More affordable performance can be had with common standards, managed service.
(http://digital.nationaldefensemagazine.org/i/124838/35)
3 While the focus of this paper is space leasing, significant affordability improvements are also possible
through aligned ground/space standards and the shared management of underlying communications
services.
4 Defense Business Board Task Group, “Taking Advantage of Opportunities for Commercial Satellite
Communications Services,” 24 January 2013, slide 7,
http://dbb.defense.gov/pdf/SatComFinalBriefingasApprovedattheDBBMtg24Jan13v15.pdf
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For the foreseeable future, the DoD will be dependent on COMSATCOM to fill significant capability gaps
for its warfighters. Hence COMSATCOM systems and capabilities should be integrated into the DoD’s
overall SATCOM enterprise to produce the desired effects of: access and rapid global response;
information superiority; provide timely, accessible, and reliable information on demand; and the ability
to prevent, protect, and respond to potential or direct attacks or environmental disasters on US soil. At
the same time, the DoD needs to exercise caution not to degrade the acquisition and operational
efficiencies inherent in COMSATCOM systems by imposing inflexible and restrictive statutes, policies and
processes.
The following sections (3-5) identify actions the DoD should immediately implement that can address
the fiscal reality of diminishing OCO funding for COMSATCOM. Each recommendation provides a
description of the current impediment preventing the DoD from pursuing innovative business
arrangements and suggests a corresponding remedy that will realize the needed savings for the DoD. In
essence, the recommendations support the development of unique and mutually supportive processes
for requirements, acquisition, and funding to successfully pursue and close on commercial
opportunities. Hence the suggested remedies are synergistic. To achieve the full benefit of these
recommendations requires they be implemented collectively and in their entirety.
3. REQUIREMENTS, ACQUISITION & FUNDING JCSCI 3170.01H5, 10 Jan 2012, Enclosure A, paragraph 2, provides a thorough overview of the three key
processes within the DoD – the Joint Capabilities Integration and Development System (JCIDS) , Defense
Acquisition System (DAS), and Planning Programming Budgeting & Execution (PPBE) – “which must work
in concert to ensure consistent decision making while delivering timely and cost effective capability
solutions to the Warfighters.” The timeline to successfully comply with all these processes and
complete all the relevant steps can easily exceed ten years. Additional revisits and revisions of JCIDS
documents to supply an “affordable” set of requirements to match an unstable budget, resulting in
programmatic uncertainty and delays, and the timeline can potentially exceed 20 years.6
The DoD’s current process to field a SATCOM system is the antithesis to Commercial Owner/Operators
who can field a new COMSATCOM system within 3 to 4 years. There are numerous statutory, regulatory
and process constraints that impede the DoD’s ability to comply with the 2010 National Space Policy to
“promote a robust domestic commercial space industry” while minimizing “the regulatory burden for
commercial space activities.” Specifically, it is incumbent on the DoD and, where appropriate, Congress
to revise, relax, avoid or eliminate these constraints that inhibit the DoD from exercising innovative
COMSATCOM business arrangements that enable more efficient and responsive acquisition of needed
5 Chairman of the Joint Chiefs of Staff Instruction for the Joint Capabilities Integration and Development
System (JCIDS)
6 Defense Business Board Task Group, “Taking Advantage of Opportunities for Commercial Satellite
Communications Services,+ 24 January 2013, “MILSAT operates on a >10+ timeline from concept to delivery.”
http://dbb.defense.gov/pdf/SatComFinalBriefingasApprovedattheDBBMtg24Jan13v15.pdf
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COMSATCOM resources. In order for the DoD to reap the monetary and schedule savings from
COMSATCOM efficient commercial business practices, the DoD needs to make allowances.
The following paragraphs identify actions the DoD should immediately implement to develop unique,
mutually supportive processes for requirements, acquisition, and funding to successfully pursue and
close on commercial opportunities.
3.1. ESTABLISH A STABLE SET OF USER REQUIREMENTS FOR COMSATCOM. To leverage a
mature COMSATCOM Industry, it is necessary to align DoD requirements and schedules with
commercial capabilities. Industry uses its financial resources to manage risk by anticipating
government requirements, offering significant financial rewards to investors, and charging the
DoD for risk induced by the unpredictability in user requirements. A government approach that
manages this same risk -- whether requirements uncertainties, product performance
uncertainties or better service management -- can avail the government significant savings.7
Warfighter requirements uncertainty/risk can be partially mitigated if the DoD can identify
persistive requirements 8 that can be commercially satisfied. Also, users that can tolerate lesser
capabilities, constraining needs to what can be commercially satisfied, can also achieve
significant affordability benefits.9 It is quite possible to identify a firm set of COMSATCOM user
requirements that do not have to be validated and approved through the arduous JCIDS process,
whose schedule is incompatible with commercial timelines. In lieu of JCIDS, recommend using
Business Case Analysis (BCA) as governed by Air Force Instruction (AFI) 65-509. A BCA is a
“decision support document that identifies alternatives and presents business, economic, risk,
and technical arguments for selecting an alternative to achieve organizational or functional
missions or goals.” While ground operations are drawing down in the Middle East, the Air Force
will still be required to support persistent Airborne Intelligence Surveillance and Reconnaissance
(AISR) missions worldwide. Hence COMSATCOM connectivity solutions for AISR10 is an ideal
place to start with the BCA process. The AISR COMSATCOM dilemma requires an enterprise-
wide analysis, conforming with the definition of a BCA.11 The Air Force would review their
7 SMC/MCP, “Commercial Pathfinder Cost ROM Summary,” 30 July 2012 “A long term lease can reduce
equivalent $MHz/MM by 15%. A full transponder buy could reduce equivalents by over 50%. ”
8 Refers to requirements in excess of one year, standard lease duration, that can inform more affordable
capability acquisitions. Advanced business approaches (Section 6) can alleviate the single year, single
transponder constraints through access to more flexible, longer term, global transponder deals.
9 Resilient Basis for Satellite Communications in Joint Operations Study Final Report, Appendix I, para I.3.1.
10 The Air Force has established a fixed set of Remotely Piloted Aircraft CAPS for Predators and Reapers.
11 Air Force Instruction 65-509, 19 Sep 2008, Business Case Analysis, Para 1.2. “The broader sense of BCA is
the definition the Air Force uses. The term “enterprise-wide” should typically be understood to mean a cross
cutting practice that will affect the entire Air Force or MAJCOM…. Also , “business operations” should be
interpreted to mean both the business domain of the Air Force (support functions) and the operational
domain of military force projection[emphasis added].”
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current COMSATCOM leasing trends and compile a set of needs that could be satisfied by an
innovative business arrangement that in effect “buys” transponder equivalents at considerable
savings over leasing. These innovative business arrangements would be compared with leasing
alternatives in a BCA. A similar process exists for the DoD12 and should be evaluated for
approving solutions for persistent COMSATCOM requirements spanning the DoD.
3.2. ESTABLISH A STABLE BUDGET FOR COMSATCOM. In order for the DoD to be perceived by
Commercial Owner/Operators as a “good customer” worthy of a “good deal,” multi-year funding
for COMSATCOM needs to be reflected in Services’ Total Obligation Authority (TOA) and
effectively set apart from the annual uncertainties that the PPBE generates.13 Congressional
OCO funding has been liberal in past years, but it is being eliminated. Moreover OCO funds have
to be spent in the same year they were appropriated for and consequently are not conducive for
pursuing multi-year deals that would generate savings as a reliable customer with stable
requirements. Even if a Service is willing to commit its TOA to a multi-year leasing deal, it may
only reap 15% savings and obtaining Comptroller approval could be difficult.14 One option is to
establish an ongoing procurement budget line item, such as a managed service approach used to
support government terrestrial operations. “DISA has a working capital fund15 to manage and
buy bandwidth for terrestrial communications and this could be applied to satellites
communications.”16 An alternative to a working capital fund, would be to establish a
procurement account dedicated to chase opportunistic COMSAT deals. From an enterprise
12 DoD Instruction 7041.3, 7 Nov 1995, Economic Analysis for Decisionmaking.
13 COMSATCOM Industry’s “Seven Ways to Make the DoD a Better Buyer of Commercial SATCOM,” 14 January
2013, para 1, “Until and unless the DoD has a alternative funding strategy for commercial SATCOM the only
mechanism that DOD has to procure commercial satellite infrastructure is through short-term, spot-market
purchases – the most costly and inefficient method to fulfill critical DoD needs. The Navy has not only
demonstrated the value of an ongoing COMSAT budget to achieve availability and affordability benefits, but
demonstrated the related value to persistive requirements definition with the unification of end to end
acquisition support including COMSAT terminal product integration.
14 SMC/MCP, “Commercial Pathfinder Cost ROM Summary,” 30 July 2012 “A long term lease can reduce
equivalent $MHz/MM by 15%. A full transponder buy could reduce equivalents by over 50%. ”
15 Money set aside for the purchase of capital or fixed assets. Typically it is a revolving fund, an account or
fund that relies on sales revenue rather than direct Congressional appropriations to finance its operations. It
is intended to generate adequate revenue to cover the full costs of its operations, and to finance the fund’s
continuing operations without fiscal year limitation. A revolving fund is intended to operate on a break-even
basis over time; that is, it neither makes a profit nor incurs a loss.
16 Kenyon, Henry, Defense Systems, “DoD should rethink satellite bandwidth policies, expert says: Current
leasing methods inefficient and expensive,” 13 Mar 2012, quote by retired Air Force Lieutenant General
William Donahue, now an Xtar consultant. http://defensesystems.com/Articles/2012/03/13/Satellite-2012-
DOD-leased-satcom-networks.aspx?Page=1
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perspective, a business case analysis17 could provide illumination regarding which funding
strategy would ultimately deliver the most warfighter capability at the least cost. There are
actions the DoD can take, however unless congress takes action to allow multiyear budgeting we
won’t be able to capitalize on COMSATCOM efficient acquisition.
3.3. EMPOWER PROGRAM MANAGERS AND REQUIRERS (A5) TO MAKE “QUICK” DECISIONS.
The flexible ability for the DoD to seize rapidly changing commercial opportunities is critical to
affordable deals. Examples include end-of-life satellites, pre-launch transponder purchase and
global constellation access deal blends.18 An empowered acquirer/requirer partnership can
enable a tight coupling between commercial capability and military need. While the DAS
provides for ample oversight by senior decision makers, it is encumbered by numerous reviews,
a large amount of documentation, and subjected to frequent schedule delays. This burdensome
Mission Assurance (MA) process is not compatible with commercial best practices. A significant
portion of potential savings results from streamlined MA methods implemented by commercial
manufacturers. Hence the DoD must empower lean, highly capable onsite teams with the
authority to make quick (“quick” is defined in terms of hours to two days) decisions in order to
operate at the commercial decision-making pace, avoiding schedule delays and fiscal penalties. 19 Overall, COMSATCOM opportunities requires the DoD to shift to a schedule-driven culture
with processes that can rapidly chase commercial opportunities. In these cases extensive
government oversight does not add any risk reduction value with respect to mature
COMSATCOM products and interferes with commercial process schedule efficiencies.20
3.4. DISALLOW CONTRACT MODIFICATIONS AFTER SIGNATURE. After a Commercial Owner/
Operator signs a contract with a manufacturer they immediately begin to procure hardware and
begin building the satellite. Preliminary Design Reviews and Critical Design Reviews are not
times to make changes in the commercial sector. The DoD must resist injecting contract
modifications after contract signature. Changes at this point in the process often induce
schedule delays, trigger fiscal penalties, and jeopardize the DoD’s status as a “good customer.”
Denying contract modifications is closely linked with the first objective above to “establish a
stable set of user requirements.21
17 Air Force Instruction 65-509, 19 September 2008, Financial Management, Business Case Analysis.
18 See Section 6, Summary of Acquisition Methods table.
19 Resilient Basis for Satellite Communications in Joint Operations Study Final Report, Appendix I, para I.3.2.
20 Ibid, Appendix I, para I.3.0.
21 Ibid, Appendix H, para H.2.0.
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4. POLICIES AND REGULATIONS
The following paragraphs identify actions the DoD should immediately implement to provide the
necessary policy and regulatory foundation to enable innovative business opportunities for
COMSATCOM and ultimately advance a more robust domestic space industry that benefits both DoD
and commercial providers.
4.1. ADOPT A RAPID FEDERAL FREQUENCY FILING PROCESS FOR COMMERCIAL
OWNER/OPERATORS. The geo-belt is a very lucrative orbit for Commercial Owner/Operators
and they are looking for new ways to generate profits and meet the persistent SATCOM needs of
the DoD.22 Commercial Owner/Operators are not only offering traditional commercial services
for military use, but are equipping payloads and offering services enabled by frequencies
reserved exclusively for federal use by the U.S. Government, to include the military.23 Guidance
was recently released by Deputy Chief Information Officer24 within the DoD reasserting
regulations already in place governing any DoD contract involving spectrum reserved exclusively
for federal use, typically employed by the military. The guidance was framed by an assumption
of risk throughout all stages of the spectrum filing process; spectrum approval can easily be
elusive and even denied due to any number of inter-government decision misalignments. To
mitigate the risk, the guidance states the preferred approach is for the Commercial
Owner/Operator to use a USG sponsor “to secure international authorization *to incorporate
federal/military frequencies] by registering and coordinating frequency and orbital slot
requirements for the hosted payload with the International Telecommunications Union.”
Second choice would be for the Commercial Owner/Operator to register frequencies through
another country. The DoD guidance puts potential deals between DoD users and Commercial
Owner/Operators at significant risk, particularly when trying to close on one of the most
affordable deals from a DoD perspective, a pre-launch transponder acquisition deal. The
proscribed practice requires the USG sponsor to receive a certification by the National
Telecommunications and Information Administration (NTIA) of the Department of Commerce
22 Britton, Turner, Space News, 15 July 2011, "Global Xpress satellite will each carry a commercial Ka-band
payload and a high-capacity payload that can be toggled back and forth between commercial Ka-band and
military Ka-band frequencies….”
23 Gallagher, Michael D., Assistant Secretary of Commerce, National Telecommunications and Information
Administration, 23 April 2002, Testimony to the Subcommittee on National Security, Veterans Affairs, and
International Relations, House of Representatives. “To meet the respective needs of the private sector and
federal government, the President through the NTIA… and the FCC…have divided approximately 300 GHz of
usable radio spectrum into government exclusive, non-government exclusive and ‘shared’ bands.”
24 Wheeler, Robert E., Major General, USAF, Deputy Chief Information Officer for C4 & Information
Infrastructure Capabilities, letter dated 26 Sep 2012, Subj: Guidance for Obtaining Military SATCOM Services
from a Commercial Provider via hosted Payloads Using Military Spectrum.
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before a federal project can submit estimates for the development or procurement of major
radio spectrum-dependent communications-electronics systems25 – a process that can take as
long as seven (7) years.26 DoD risks entering into an innovative pre-launch business deal as the
frequency filing process can be twice as long as it takes the Commercial Owner/Operator to
build and launch a commercial satellite. It is also necessary to recognize the need to protect the
USG’s freedom to operate in space using spectrum reserved exclusively for federal/military use.
Without any signed DoD contract and complementary USG sponsor, Commercial
Owner/Operators will pursue the more responsive path and file for frequencies through a
foreign government. Non-USG filings risk warfighter freedom of action to surge space assets on
need, particularly if a local commercial deal fails, or market/international factors block access.
Before the USG loses the ability to control the placement of federal/military spectrum in the
congested geo-belt, employed by military and commercial satellites alike, it is imperative to find
a new way. The USG should immediately position itself to be Industry’s sponsor of first choice
in order to obtain commercial use of federal/military frequencies. To retain freedom of use, the
DoD should pursue a deliberate contracting and spectrum use strategy to offer Commercial
Owner/Operators a significantly streamlined process for geo orbital slot approval employing
federal/military frequencies. Since these commercial satellites would be occupying orbital slots
of high operational value to the DoD (as predetermined by the USG strategy), these Commercial
Owner/Operators would receive preferential contracts from the DoD, while the USG maintains
control of the filing process. A win-win for both sides.
4.2. MONITOR TRANSFER OF COMSATCOM FROM ITAR USML TO CCL. International Traffic in
Arms Regulations (ITAR) is a set of United States government regulations that control the export
and import of defense-related articles and services on the United States Munitions List (USML)
including, until recently, the export of U.S. satellites and components. ITAR was intended to
safeguard U.S. national security and further U.S. foreign policy objectives, but it did not produce
the desired outcomes. Complying with overly restrictive ITAR regulations was costly,27 and
actually eroded the domestic space industry.28 The ITAR-induced trade restrictions, spurred
non-U.S. aerospace companies to advertise “ITAR-free” as a major selling point for their
25 OMB Circular A-11 Section 31.12 (c)
26 OMB Circular A-11, Section 3307, requires filing certification before a federal project receives funding.
27 In American Academy of Arts & Sciences article “United States Space Policy: Challenges and Opportunities
Gone Astray,” 2009, pages 5-6, reported “export control regulations carries a high price tag for U.S. companies
and harms their global competitiveness. . . . export control compliance costs in the United States averages $49
million per year industry-wide.”
28 Hill, Jeffrey, Satellite Today, 26 Dec 2012, “U.S. Congress Relaxes Satellite ITAR Regulation,” stated “Seakr
Engineering President and COO Eric Anderson cited research from the Center for Strategic Internation
Studies (CSIS), which showed that prior to the restrictions, U.S. company slaes made up more than 73 percent
of the global military and commercial satellite market – a statistic that fell to 25 percent of the world market
by 2005.”
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products.29 The “United States stringent export policy has essentially allowed global
competitors to catch up in the global aerospace marketplace and develop capabilities that, in
many instances, are similar to those developed in the United States. . . .U.S. components and
technology are slowly but surely being designed out of systems from satellites to rocket
motors.”30 Fortunately, Congress passed, and President Obama signed into law on 3 January
2013, the fiscal year 2013 National Defense Authorization Act (NDAA), which returns
responsibility to the President to determine technology export control requirements for
commercial satellites and their subsystems. This will allow most commercial satellite technology
to move back to Commerce Control List (CCL) of the Export Administration Regulation (EAR)
managed by the U.S. Department of Commerce Bureau of Industry and Security. While more
relaxed than ITAR, CCL is still robust enough to govern the export of technologies.31 This
welcome change requires continued oversight to ensure it helps revitalize the U.S. COMSATCOM
industry as intended.
4.3. ADDRESS APPLICATION OF U.S. SPACE LAUNCH POLICY FOR COMSATCOM. President
Bush authorized a new U.S. Space Transportation Policy on December 21, 2004, which stipulates
that USG payloads could only be launched on space launch vehicles manufactured in the U.S.,
unless exempted.32 Several of the solutions proposed later in this paper transcend the grey zone
of “what is a USG payload?” The recommendation is to stipulate that a pre-launch purchase of a
single transponder (on a non-USG satellite which features multiple non-US transponders) is still
a non-USG payload. Hence the payload featuring the USG-owned transponder would not be
subject to the requirement for a US launch vehicle.
Another suggested solution is for the USG to purchase a single satellite out of a constellation in
order to share a percentage of the entire fleet’s bandwidth. If in the event a requirement for
US launch 1) applies and 2) causes increased costs, then either the launch will require an
exemption for a U.S. launch requirement or the USG organization making the COMSATCOM
purchase incurs additional cost. An alternate recommendation (to purchasing a satellite
outright) is to purchase a share of a constellation (or a share of a consortium of satellites
supplied by different Commercial Owner/Operators). In this situation, the USG neither owns
the payload, the satellite, the company, nor the fleet; it simply owns a share of access to the
fleet’s capabilities.
Assured Access to Space (space launch) is a critical requirement for national security. It is
expected that the new Economic Order Quantity acquisition strategy for launch services will
29 American Academy of Arts & Sciences article “United States Space Policy: Challenges and Opportunities
Gone Astray,” 2009, page 5.
30 Ibid, pages 6-7.
31 Kurtin, Owen D., Satellite Today, 1 Feb 2013, “Satellite Export Reform Moves Forward.”
32 U.S. Space Transportation Fact Sheet, 6 January 2005, Implementation Guidelines, para 1.4 a)
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bring down cost of US Launches while preserving mission assurance; however for now the cost
remains high. Imposing these costs on COMSATCOM solutions could neutralize some savings.
In order for the DoD to realize all potential cost savings afforded by COMSATCOM innovative
business arrangements33 (e.g. single commercial satellite, transponder purchases) while
continuing to provide connectivity to warfighters, it’s necessary to consider exemptions to
launch policy to permit foreign launch to enable industry best value. However, this approach
may be detrimental to the launch side of the national security space enterprise and decreases
potential savings while weakening the industrial base. Exemptions may be necessary for
specific scenarios such as transponder purchase (similar to a hosted payload) or a single
satellite purchase (which provides USG access to the entire fleet). Besides singular exemptions,
the Air Force could explore an option to adhere to existing policy and agree to pay the
difference if it is determined that a domestic launch costs more than a foreign launch.
5. OPERATIONS COMSATCOM supplies 40% of the DoD’s SATCOM needs, and DoD’s dependence on COMSATCOM will
continue to increase over the next decade.34 While COMSATCOM is integral for delivering theater and
global effects in support of national and combatant commander objectives, current military space
operations has little interaction and coordination with COMSATCOM Owner/Operators providing
resources to the DoD.
Prepared by the Joint Chiefs of Staff, the Capstone Concept for Joint Operations: Joint Force 202035
describes how the Joint Force should prepare for the security environment of tomorrow. Globally
integrated operations is dependent upon eight key elements, including flexible, low-signature
capabilities like space, requiring a more pronounced role in future joint operations providing flexibility,
global responsiveness, operational reach, and persistence. However these effects will be diminished
since current space operations lacks even basic space situational awareness (SSA) information on
COMSATCOM systems used by the DoD.
While this paper identifies how to rectify shortfalls with requirements, acquisition and policies, it is
equally important to identify opportunities to strengthen space operational relationships with
Commercial Owner/Operators that are supplying a significant portion of SATCOM resources for the DoD.
The following paragraphs identify tasks that will strengthen Military Space Operations by partnering
with commercial providers in order to deliver integrated and synergistic operational effects to the
warfighter. This list is not intended to be all inclusive, recognizing additional operational issues
34 Results from Defense Business Board Task Group, Taking Advantage of Opportunities for Commercial
Satellite Communications Services, 24 January 2013, slide 11.
http://dbb.defense.gov/pdf/SatComFinalBriefingasApprovedattheDBBMtg24Jan13v15.pdf
35 Capstone Concept for Joint Operations: Joint Force 2020, 10 September 2012
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impacting commercial and military SATCOM systems alike will also need to be addressed in the near
future.
5.1 OFFER BLUE FORCE STATUS (BFS) TO COMMERCIAL OWNER/OPERATORS. BFS
provides an appealing safety net that can passively and objectively evaluate the status of
operational satellites. COMSATCOM and MILSATCOM satellites collectively face the same
threats, both reversible and irreversible. BFS autonomously detects, tracks, and characterizes
abnormal conditions, logs them, collects statistics, notifies the operator, and in the future will
provide real-time cause and attribution. An anomalous condition could indicate a satellite
failure, space weather event, or an attack by an adversary. Knowing and sharing this
information in a timely manner would allow space operations centers like the Joint Space
Operations Center (JSpOC) to build a better operations picture of our assets in space and
respond more readily to observed threats. For example, the ubiquitous SSA supplied by BFS
would be invaluable for identifying a broad, coordinated electronic warfare attack on any
SATCOM asset supporting DoD operations. Recognizing any form of attack from the onset will
enhance the warfighter’s ability to operate effectively in a degraded environment.
Furthermore, analysis of anomaly records should help us design more resilient systems in the
future, military and commercial systems alike. Recognizing and attributing attacks as well as
tracking fragility in components and system design are equally valuable to DoD and Commercial
Owner/ Operators. To realize the full advantages of BFS and provide a more complete
operations picture, the DoD should invest in BFS for all SATCOM systems. There is no specific
requirement for Commercial Owner/Operators supporting warfighters to supply SSA
information to the DoD. However BFS could be another valuable bargaining chip for the USG
when negotiating commercial deals, since the information would be valuable for Commercial
Owner/ Operators as well.
5.2 DEVELOP INFORMATION ASSURANCE (IA) PROFILES FOR COMSATCOM SYSTEMS
TYPES AND MISSION PROFILES. While BFS focuses on counterspace threats, similar
cooperation is required by the DoD and Commercial Owner/Operators on the cyberspace front.
Capabilities such as cyber defense are typically not a standard commercial offering by
COMSATCOM providers.36 Commercial industry can feasibly support DoD IA requirements, but
fully accredited DoD IA requirements are outside the profile of standard commercial offerings
and would likely kill a COMSATCOM deal. IA (cyber) accreditation and approval for military
space and ground enterprise elements, an example of a long lead MILSATCOM type product, is
time consuming and will require advanced work to mitigate the potential for disruption to
COMSATCOM system solution negotiations and subsequent development schedule/timelines.
There are solutions for cyber vulnerabilities within commercial systems, but all come with
acquisition cost implications. Closing on a commercial deal requires definition of a firm fixed
price digestible standard that can be easily executed at contract definition on a commercial
36 Some operators have been making significant strides to improve their cyber capabilities.
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timeline. Recommend developing a set of COMSATCOM IA requirements pre-award as they
relate to typical COMSATCOM architectures supporting various missions. These IA
requirements for COMSATCOM systems would represent a standard, affordable set of
boilerplate IA requirements to use when purchasing future COMSATCOM systems. 37
5.3 IMPROVE SSA SUPPORT TO COMMERCIAL OWNER/OPERATORS IN PEACETIME AND IN
CONFLICT. Today, Commercial Owner /Operators supporting the USG are not required to sign
an SSA Sharing Agreement, but are required to submit separate Orbital Data Requests (ODRs)
for advanced services. Advanced services include but are not limited to conjunction
assessment, launch support and deconfliction, deorbit and re-entry support, disposal/end-of-
life support, collision avoidance support, anomaly resolution support and electro-magnetic
interference resolution support. While current procedures to request and share orbital data
appear adequate38 to meet Commercial Owner/Operators needs in peacetime, the SSA Sharing
Process as outlined in STRATCOM Instruction (SI) 534-339 is onerous and unlikely to be
responsive in a highly contested space environment. With so many critical DoD missions
supported by COMSATCOM, it is imperative COMSATCOM assets receive similar visibility and
support as MILSATCOM assets. For example, Commercial Owner/Operators may have the
ability to perform a collision avoidance maneuver if conjunction warning information is
accurate and received in time.40 An alternative would be to provide Commercial
Owner/Operators data from the High Accuracy Catalog so they could perform their own
Conjunction Assessment (CA) and Collision Avoidance (COLA), freeing up the JSpOC to perform
numerous other duties. Possibly a better alternative could be for the U.S. Government to
supply SSA data to the Space Data Association (SDA),41 that “standardizes and compiles SSA
37 Resilient Basis for Satellite Communications in Joint Operations Study Final Report, Appendix I, para I.2.4.
38 Secure World Foundation (SWF) concludes differently in their article entitled “Space Situational Awareness
Sharing Program: An SWF Issue Brief,” 22 September 2011, page 8, “the [SSA Sharing] program faces many
issues, concerns, and complaints ranging from dissatisfaction with the quality and timing of information it
provides to concerns about national security.”
39 STRATCOM Instruction 534-03, Space Situational Awareness Information, 18 Jan 2013.
40 Secure World Foundation, “Space Situational Awareness Sharing Program: An SWF Issue Brief,” 22
September 2011, page 8, “Because the SSA Sharing Program is administered by the U.S. military, it comes wih
an assortment of limitations and restrictions. The limited information provided through the program can be
untimely and inaccurate. The only positional information currently available on Space Track, in the form of
TLE [Two-Lined Element] sets, is imprecise and unsuitable for CA [Conjunction Assessment] and COLA
[Collision Avoidance].”
41 The Space Data Association (SDA) is a formal, non-profit association of satellite operators that supports the
controlled, reliable and efficient sharing of data that is critical to the safety and integrity of satellite
operations. The SDA was formed in 2009 by Inmarsat, Intelsat and SES to share data. In April 2010,
Analytical Graphics, Inc. (AGI) won the contract to design and operate the Space Data Center, SDA’s
14
data in a uniform and confidential format and shares this information with its members. . . .The
system provides the most accurate information and analysis available because it comes straight
from the source.”42
6. INNOVATIVE BUSINESS OPPORTUNITIES A great deal of work has already been performed in identifying innovative business opportunities in
order to take advantage of the efficiencies inherent in commercial practices. The most comprehensive
work done to date was conducted by the Advanced Concepts Division within Space and Missile Systems
Center, SMC/MCX, in support of the Resilient Basis for Satellite Communications in Joint Operations
Study, or RBS for short. The COMSATCOM results and recommendations for RBS were based on six
Phase 1 Broad Agency Announcement (BAA) study contracts to the COMSATCOM industry in 2011 as
part of the effort to develop efficient and resilient options for meeting future MILSATCOM
requirements. The major objectives were to (1) determine the degree to which “minimally modified”
COMSATCOM systems could address selected assured43 MILSATCOM requirements (i.e., benign
environment broadband communications operating at Mil-Ka and X-band frequencies), and (2)
investigate viable acquisition options for the DoD to procure “commercial-like” SATCOM systems as non-
developmental items (NDI), commercial off-the-shelf (COTS) products or via other favorable business
arrangements.44 The initiative continues via robust industry/stakeholder outreach, and continued
dialogue/modeling of acquisition alternatives to resolve acquisition and operations road blocks.
Most COMSATCOM is obtained with a 1-year operating lease, administered by DISA with Future
COMSATCOM Services Acquisition (FCSA) contracts. Through DISA FCSA contracts, DoD users are able to
quickly obtain communication services for unplanned needs using annual Operation and Maintenance
funding or using OCO funding when available. When services are needed for more than 1 year, they are
leased using flexible one year leases with up to 4 one year fixed price options without termination
liabilities. The costs of these deals are set by markets, gambling over which DoD requirement would
emerge. The cost for unused transponders is a factor within the commercial business case. This year by
year approach is used rather than a more cost effective multi-year lease approach because DoD policy is
biased to favor purchasing satellites over long term lease contracts (i.e., DoD policy makes it very
difficult to get multi-year O&M approval). The RBS recommended that DoD continue to investigate
approaches to streamlining the approval for multi-year funding obligations for COMSATCOM
automated space situational awareness system designed to reduce the risks of on-orbit collisions and radio
frequency interference. http://www.space-data.org/sda/about/sda-overview/
42 Secure World Foundation (SWF), “Space Situational Awareness Sharing Program: An SWF Issue Brief,” 22
September 2011, page 12.
43 Assured requirements are those statured in requirements documents such as the Joint Space
Communication Layer (JSCL) Initial Capability Document (ICD), 28 Sep 2010.
44 Resilient Basis for Satellite Communications in Joint Operations Final Report, Appendix I.
15
applications where a long term lease or capital lease is considered to be the more cost effective
approach.45
Purchase is the traditional DoD acquisition approach for assured MILSATCOM systems. A purchase deal
implies DoD takes on requirements and product delivery (i.e. mission assurance) risks. The approach has
been used to meet unique DoD requirements in military frequency bands. Purchase may also be used
for COMSATCOM that has been modified to operate in a federal/military frequency band under USG
control or for continued DoD use of commercial frequency bands on commercial resources. For
COMSATCOM operating in commercial frequency bands there is an NTIA policy which implies that the
DoD is precluded from being an owner and operator of a satellite in the commercial frequency bands.46
The policy however does not preclude DoD from being an owner and the commercial satellite operator
to retain radio control (operations) of the satellite. DoD hence has a range of aligned spectrum variants:
(1) DoD purchase of COMSATCOM with satellite operation by a commercial operator, (2) Filing for NTIA
approval of DoD operations in commercial bands, but with toleration of interference47, (3) Capital lease
and operation by a commercial operator, (4) other blended ownership variants such as CRAF. The first
approach (1) is a desired path finding approach if the risks associated with international filing48 and filing
support for DoD operated terminals is found acceptable.
Table 6-1 below is a summary of acquisition methods analyzed for RBS. For a complete discussion of the
topic, go to the RBS final report on SIPRNET,49 Appendix I.
45 Ibid, Appendix I, Para I.4.1.
46 After more than a decade of prodding by AF, DoD and NTIA, FCC released a Notice of Proposed Rulemaking
(NPRM) to allow Federal agency use of commercial satellite capacity with equitable regulatory protection
offered to commercial entities in commercial satellite bands. (Reference FCC 13-65, ET Docket 13-115,
Released: May 9, 2013).
47 Resilient Basis for Satellite Communications in Joint Operations Final Report, Appendix I, Para I.4.2.
48 Per discussions with Senior CIO Spectrum and Policy officials, the USG would need to assess the
stature/status of a commercial filing that could be leveraged for DoD use. Similarly, an assessment of
commercial filing compatibility with terminal transmission parameters needs similar performance/risk
assessment.
49 RBS Final Report, Appendix I:
http://www.intelink.sgov.gov/inteldocs/action.php?kt_path_info=ktcore.actions.document.view&fDocumentI
d=11484431
16
Table 6-1: Summary of Acquisition Methods50
Acquisition Method Summary Feasibility Assessment
Conventional Lease, Future COMSATCOM Services Acquisition (FCSA) Conventional short term (1 year) lease with priced options. Responsive to urgent unplanned, non-Assured USG military need.
Executable – Mature COMSATCOM acquisition approach directed by policy and administered by DISA.
Purchase, Standard approach to acquire modified COMSATCOM products modified to operate on military frequencies meeting “assured” military needs
Executable - Limited to Militarized COMSATCOM (i.e., COMSATCOM products operating on military frequencies)
Long Term Lease, Multi-year lease commitment and typically requires a termination liability/cost
Non-executable - Currently cannot be implemented due to appropriations policies that do not support multi-year funding for leasing services. Recommend future work addressing policy biases toward purchasing
Capital Lease and Lease
Purchase,
Lease wherein exclusive rights of use of the capital asset is transferred to the leasee. Lease Purchase variant includes option for transfer of ownership to the leasee at the end of the lease.
Executable – applicability may be limited by appropriations disbursement constraints as discussed. Recommend future work to investigate approaches to address limitations imposed by disbursement constraints.
Multi-Year Authority over
service contracts (USC 2306c),
Industry acquires purpose built satellites for DoD use, and charges a fee for the provision of services. Flexible ownerships, operations and business arrangements. Special case of a Long Term lease.
Not Definitive - May be possible but no precedence example. . Recommend consideration in the context of Long Term lease future work
50 RBS Final Report, Appendix I, Table 2-I.
17
Acquisition Method Summary Feasibility Assessment
Buy to Lease, DoD partnership with Commercial Owner/Operator that is analogous to Australian MoD and DoD partnership wherein Aus MoD purchased WGS satellite and traded for access to global WGS constellation. In this application the DoD purchases the satellite and trades for global constellation access.
Not Definitive - May be possible but no precedence example for DoD contract with Commercial entity.
Recommended for further investigation. Wideband Provisioning Follow-On (WPFO) concept is an example of this acquisition method.
Anchor Tenancy, DoD pays upfront cost prior to satellite contract for guaranteed access to services at favorable leasing rates. Typically applies to industry where commercial market is not developed.
Non-executable For the DoD to use an anchor tenancy approach for COMSATCOM requires statute change. Furthermore, given the maturity of the COMSATCOM market place it is thought to be unlikely that Congress would support an anchor tenancy arrangement.
Not recommended for further consideration.
Other Transaction Authority, A special vehicle used by federal agencies for obtaining funding for advancing research and development (R&D) or prototypes. DoD pays upfront cost prior to satellite contract for guaranteed access to services at favorable leasing rates.
Non-executable. It would take a liberal reading of the statute for the DoD to show that the acquisition of COMSATCOM meets R&D or prototype criteria.
Not recommended for further consideration.
Table 6-2: Additional Business Alternatives Identified since the Resilient Basis for Satellite Communications in Joint Operations Study
Acquisition Method Summary Feasibility Assessment
Inclined Satellites (Industry Suggested)
COMSAT operators have the choice of maintaining station keeping through the end of life of the satellite, or allowing satellites to drift North/South based on solar forces. North/South inclination increases reduce prospects for service to commercial customers with fixed antenna. DoD customers, AF, Army, Navy possess equipment tolerant of inclination, affording a unique opportunity for affordable service. Deals could be for all or part of inclined satellites. The circumstances for this type of deal are rare – but
Executable – Entirely executable. An investment based, Commercial FAR Part 12 acquisition is assumed. Issues to be resolved include use of investment dollars and enabling commercial operations for investment-deal satellites using commercial spectra. Recommended: This alternative could be of particular value as a low cost initial pathfinder to demonstrate resolution of above limited issue set. It’s also an example of one (of many) recurring, emergent business deals that could be the focus of continuing
18
Acquisition Method Summary Feasibility Assessment
could be very affordable. They emerge based on factors independent of DoD deals. Execution of these deals requires DoD to operate on a very fast decision cycle as business case availability would be commercially time constrained.
DoD pursuit as part of normal business.
Pre-Launch Transponders (Industry Suggested)
COMSAT operators can have available SWAP51
within pending launch vehicles. This SWAP can be leveraged for hosted payloads, or hosted function. A hosted function, such as a transponder, is the inclusion of military requirements with commercial requirements at the time of satellite manufacturing award
52.
Executable – Entirely executable. An investment based, Commercial FAR Part 12 acquisition is assumed. Issues to be resolved include resolution of issues associated with an Inclined Satellite pathfinder. A particular challenge is satellite mission assurance (MA). Commercial style MA/risk management techniques (detailed earlier) will require acquisition vetting. Recommended: Building on an inclined satellite pathfinder, rhis alternative could be of particular value as a second low cost pathfinder to demonstrate resolution of mission assurance and other COMSAT functions (cyber/IA, ground integration, CONOPs definition). It’s a robust step on the path to a more blended, global deals.
Wideband Provisioning Follow-On (WBPFO) (Industry Suggested)
The WBPFO concept mimics the Australian WGS deal with the US. A satellite, a commercial satellite, is purchased by the USG and offered to an operator for revenue bearing service. In turn, the operator affords global access across its constellation. The WGS deal is not a one for one transponder no cost swap, nor would this sort of deal. Access to global resources is also limited. It would however enable more resilient, better available access to global transponders than leases. Its long term roots would enable better global
Executable – Requires resolution of the issues associated with the above 2 pathfinder candidates, and would necessitate additional resolution of appropriations issues associated with investment aperture sharing and the movement of services within an investment deal (quid pro quo). Moderate risk. Of note, the satellite launch community follows a similar model for it’s products
53. An investment based, Commercial FAR Part 12
acquisition is assumed. Recommended: This industry/operator suggested approach provides possibility for a very high resiliency solution fully exploiting their large commercial constellations. It enables
51 Size Weight and Power (SWAP)
52 During commercial SATCOM BAA, none of the manufacturers saw value with hosting commercial transponded payloads. Such payloads would better
be included within the basic satellite deal “off the shelf”.
53 Launch and range programs acquire launch vehicles, but deliver a service. DD-250 title is not taken for boosters. This offers precedent for DoD
COMSAT deals where vehicles are acquired via investment funds (same as launch vehicles) but flexible services are solicited across a fleet.
19
Acquisition Method Summary Feasibility Assessment
affordability. transportable requirements across the global arc, positions long term deals for better affordability, and positions contingency resources within various AoRs for immediate access. Industry has expressed willingness to fashion commercial, pre-emptable business cases that align with this blended MIL/COMSAT vision (similar to backup capabilities employed for major television networks where backup resources are “re-leased” and available for secondary repurposing, but are immediately pre-emptable when the primary network customers demand).
Civil Reserve Air Fleet (CRAF) applied to satellites (Industry Suggested)
Satellite manufacturers have the capability to offer military and commercial capabilities (Ka) on the same apeture. This affords a means for a highly resilient and shared COMSAT AND MILSAT service. It also opens the door for “time sharing” the aperture based on need and specialized business case arrangements. Use of the apeture for approved commercial revenue generating service likely would be at a discount in view of DoD’s preferred use risk. Such revenue generation however could afford prospects for alternative “quid pro quo” affordable business deals facilitated by revenue generation. Proliferation of these sorts of transponders further increases resiliency in a manner a fixed number of MILSATs may not.
Executable – the context of this sort of deal would build on a WBPFO acquisition. (Moderate to High risk) The same acquisition challenges would be in play. Additional challenges would be associated with alignment of parallel military and commercially generated spectral filings in the same location. That likely to be a challenging schedule alignment for a competitive acquisition. Recommended: With a more robust resiliency model, this alternative could be a vision for a globally diverse, affordable MIL/COMSAT vision. A future excursion could call upon commercial adoption of switchable protected features and systems within satellite designs, further increasing value, and minimizing MIL/COMSAT divisions.
20
The following insights were gleaned from the BAA:
Substantial insight was obtained into the cost estimating practices utilized by commercial
manufacturers and operators, including their underlying models and assumptions. This insight
has improved the Government’s understanding of commercial schedules, basis-of-estimates,
assumed acquisition efficiencies (i.e. bulk purchases of material, “hot” manufacturing lines,
streamlined flow), and the role of insurance. These will improve future Government estimates
of commercial-like systems by enabling more realistic and credible cost estimates.54
Commercial acquisition approach is applicable to many (but not all) Government satellites—any
commercial-like approach/system should reside within the commercial “sweet spot” for
technology, performance, size, etc.55
Commercial cost efficiencies require full adoption of commercial practices (i.e. high technology
readiness levels (TRLs), reduced customer oversight, stable design upfront reduces engineering
change orders, non-developmental items reduce non-recurring engineering).56
While ownership of assured communication systems has advantages, it is not always the most
cost effective option. Depending on the date, duration and type of capability needed, leasing
can offer cost advantages for more limited service. The cost differences between an owned and
leased capability are primarily time and the duration of costs incurred (driven by inflation, local
market, financing, and risk).57
For payloads with equivalent capability, hosted payloads generally cost less than free-flyers
supporting the same capability; however many supplemental (i.e. bus accommodation,
compensation to host, ground integration) costs can drive this total significantly higher.58
A commercial manufacturer generates all of their profit from on-orbit operation of the satellite.
A satellite that fails to achieve its intended performance/lifetime will directly impact the
bottom-line of the manufacturer through increased insurance charges and potentially drive
away future business; therefore commercial manufacturers are highly motivated to ensure
every satellite operates as designed [emphasis added].59
7. SUMMARY AND RECOMMENDED NEXT STEPS Taken all together there are a myriad of formidable obstacles that appear insurmountable. To
overcome these challenges, it will require senior leaders to champion a government space procurement
54 Resilient Basis for Satellite Communications in Joint Operations Study Final Report,, Appendix I, para 5.0
55 Ibid
56 Ibid
57 Ibid
58 Ibid
59 Ibid
21
culture shift60. It is unrealistic and counterproductive to expect that innovative business arrangements
to procure COMSATCOM for the warfighter can be subsumed by existing JCIDS, DAS, and PPBE
processes. Commercial opportunities and savings will continue to bypass the DoD if the government’s
mindset does not change. The Assured SATCOM Services in a Single Theater (ASSIST) is a prime example
of an innovative approach championed by seasoned DoD personnel, but failed because it relied on older
purchasing methods and was afforded insufficient time to resolve many acquisition issues.61 Lessons
learned from ASSIST, concerted leadership across the DoD to change what does not work, and executing
pathfinders are imperative to achieve the requisite COMSATCOM savings.
Moving forward, the goals are to provide the DoD with the COMSATCOM acquisition capabilities to: (1)
exploit schedule and cost benefits of commercial satellites, (2) resolve a USG approach to viably acquire
commercial satellites. Follow-on work suggestions are numerated below for each of the major obstacle
areas identified in paragraphs 3, 4 and 5 above.
7.1. FUND AND EXECUTE COMSATCOM PATHFINDER DEMONSTRATION. Develop, fund and
implement a COMSATCOM pathfinder roadmap that will tackle different types of innovative
business deals demonstrating the feasibility of viable alternative processes for one or more of
the impediments identified above. Each phase will increase the DoD’s understanding of the
changes that need to be permanently adopted in order to successfully enter into a commercial
deal that results in the requisite savings while meeting DoD mission needs. Lessons learned
from the pathfinder demonstration would ultimately be codified in a regulation(s) that
addresses the unique requirements, acquisition, and funding processes necessary for a
successful commercially aligned deal.
60 Defense Business Board Task Group, Taking Advantage of Opportunities for Commercial Satellite
Communications Services, 24 January 2013, concluded “the DoD does not have the capability to corporately
ingest these proposals: the main roadblock is in terms of policy, culture, and process.”
http://dbb.defense.gov/pdf/SatComFinalBriefingasApprovedattheDBBMtg24Jan13v15.pdf
61 Kenyon, Henry, Defense Systems, “DoD should rethink satellite bandwidth policies, expert says: Current
leasing methods inefficient and expensive,” 13 Mar 2012, “The government has tried to develop more efficient
models, said Andrew Ruszkowski, Xtar’s vice president for global sales and marketing. One example is DISA’s
Assured Satcom Services in Single Theater program, an innovative attempt to dramtically reduce the $500
million DoD spends on annual satellite communications and support services in theater, but fell short because
it relied on older purchasing methods.” http://defensesystems.com/Articles/2012/03/13/Satellite-2012-
DOD-leased-satcom-networks.aspx?Page=1
22
Table 7-1: Notional COMSATCOM Pathfinder Roadmap
LEGEND Degree of achieving objectives to rectify impediments for leveraging COMSATCOM in support of the AF and DoD
Does not meet Partially meets Meets Exceeds
COMSATCOM Issues Today End-of-Life Pathfinder62 Pre-Launch Transponder
Requirements
As identified to DISA to put on contract, i.e. FCSA
Purchase an inclined COMSATCOM satellite to satisfy AISR needs met today with annual leases
Finance the addition of a satellite to the provider constellation in exchange for assured worldwide service rights in that constellation, an assured constellation capacity. Use BCA to justify.
Acquisition
Primarily inefficient annual leasing through DISA’s Future COMSATCOM Services Acquisition (FCSA)
Empowered program manager as delegated by USD (AT&L) in Acquisition Decision Memorandum
Empowered program manager
Funding
Primarily funded by diminishing OCO funds
As determined by USD (AT&L)
Working capital fund or procurement account (use BCA to justify funding stategy)
Spectrum
Federal policies “protect” federally allocated spectrum, but not easily adaptable to innovative commercial deals
Advances spectrum policy development when DoD purchases a satellite supplying commercial frequencies.
Advances spectrum policy development by DoD purchasing a commercial satellite and receiving in return constellation wide access to commercial and military spectrum
62 SMC MILSATCOM Directorate, Commercial & International Concepts Branch, “MILSATCOM-COMSATCOM Transponder Demonstration Utility Plan,”
Feb 2013, para 2.1.2
G
Y
B R
Y
R
G
G
B
Y
B
G
R Y G B
23
COMSATCOM Issues Today End-of-Life Pathfinder62 Pre-Launch Transponder
Launch
United States Government (USG) payloads can only be launched on space launch vehicles manufactured in the U.S., unless exempted
N/A. Satellite already on orbit
If needed, expeditiously exempt launch policy for COMSATCOM satellite purchased by DoD to allow for efficient proposals
Information Assurance/Cyber
Fully accredited DoD IA requirements are outside the profile of standard commercial offerings
Accept what’s in place by Commercial Owner Operator (no change from today).
Apply IA profile on contract as developed under CSEF (reference paragraph 7.2)
Space Situational Awareness
Dominated by conjunction assessment and collision avoidance under benign conditions. Limited SSA that is shared not geared for a contested environment.
Execute on contract a limited amount of SSA to help illuminate contractual issues.
Execute on contract recommendations from DoD-Commercial Industry SSA Working Group (reference paragraph 7.3)
R
R
R
R Y
Y
R Y
Y
24
7.2. TASK THE COMMERCIAL SPACE ENGAGEMENT FORUM (CSEF) TO IDENTIFY SPECIFIC
CHANGES TO CURRENT FEDERAL AND DOD POLICIES. The CSEF is an outcome-oriented
interface forum between the DoD Executive Agent for Space Staff (EA4SS-SAF/SP) and the
Satellite Industry Association (SIA) to improve the capabilities and resilience of the commercial
space sector supporting the DoD and U.S. National Security. Through purposeful interaction
these parties could put forth a set of concrete policy recommendations to be approved by
appropriate offices within the DoD. An important agenda priority should be developing IA
profiles for typical DoD missions that are compatible with COMSATCOM acquisitions (refer to
paragraph 5.2 above). However given other CSEF agenda priorities and the extensive work
required to successfully tackle IA issues, recommend a sub-working group be formed under the
CSEF to develop IA profiles under AFSPC leadership that would meet more frequently than the
CSEF itself in order to provide a timely deliverable. A task of the IA sub-working group would
include a robust risk/vulnerability assessment to ensure COMSATCOM circuits have sufficient
integrity, reliability and availability to support assigned missions, including Remotely Piloted
Aircraft (RPA) requirements for aircraft control and data transfer.
7.3. TASK THE COMSATCOM OPERATIONS WORKING GROUP (COWG) TO IDENTIFY
SSA RECOMMENDATIONS. USSTRATCOM, HQ AFSPC, the Satellite Data Association and
Commercial Owner/Operators should actively participate in a working group to address SSA
issues that impact the entire SATCOM enterprise, focusing on the benign and contested
environments. The working group should provide a set of specific recommendations that
benefit both the DoD and the Commercial Industry, leveraging the inherit capabilities
possessed by each side. Naturally any desire for ubiquitous knowledge must be tempered with
fiscal realities. A possible deliverable would be a phased approach with the first phase
identifying near-term, low-cost recommendations that would provide SSA benefits to both
sides. This group would also be responsible for assessing the potential benefits of BFS to
Commercial Industry and other SSA related issues, e.g. computer network defense. The
recently formed COMSATCOM Operations Working Group (COWG), chaired by JFCC-Space,
USSTRATCOM and SIA, may be the right working group to address SSA.
In conclusion, it is imperative for the DoD to assign definitive delivery dates for any and all actions
addressing expensive COMSATCOM leases and develop a viable, near-term plan that will provide the
necessary fiscal relief and not jeopardize mission continuity. In most cases, impediments to viable
commercial deals are well known, have been thoroughly studied by multiple organizations within the
DoD, and now only require commitment and action from the DoD. Some impediments, such as IA, do
require further study, but the DoD should not put off confronting these difficult issues. Time is of the
essence; while some recommendations may not be perfect, it is better to start with a reasonable set
recommendations and modify them as we learn more with each deal executed between the DoD and
Commercial Industry.
