able of contentsAbouIntroductioSystems Aerospace Industries AssociationCommercial Space Insurance OvervieLaunch insurance need forCommercial Space Launch Insurance: FAA Needs toFully Address Mandated RequirementCommercial Space Launch InsurWeakness inFAA's Insurance Calculation May Expose the Federal 28Government to excess riskCommercial Space Act of 1998, Title II P
L 105-30Office of cSpace TransportationCommercial Space Transportation RegulationsCommercial Space Sector Seeks Direction in the 21stAppendix A: DetAppendix B: AcronymsAppendix C: Active Launch Site Operator licensedix D: Active launch licensesAppendix E: Presidential Directive on National SpacePolicy, February 11, 1988Appendix F: Understanding Spaceport Functions
dustry leadinge customeek alternatives like SpaceX MeEArianespace remains a steadfast provider, offering reliable services via the Ariane 5 ECA, Soyuz2, and Vega Sea Launch, for a time a key player but never a dominant one, haseased operations Finally, Japan's Mitsubishi Heavy Industries(MHI) Launch Services andhe at marktheir h-iia/bPSLV vehiclesSince about 2004 the annual number of orbital launches conducted worldwide has steadilyased This increase has primarily been diactivityide the us as usovernment launches remain relatively steady
For example, retirement of the Space Shuttleo1 decreased the number of us launce to the previousthe resulting gap, along with anticipated commercial crew missions beginning in 201 'd to fillHowever, commercial cargo missions to the International Space Station(ISS)have helpelaunches conducted by China has steadily increasedar since 2010 with a peak of 22launches in 2016 The China great Wall Industry Corporation(CGwIC) has also beenaggressively pursuing international clients via package deals that include satellite manufacturingnd launch these launches are not considered commercial since the launch contract is nointernationally competed In 2015, China introduced two new small-class launchLong March 6 and the long march 11 In 2016, China successfully launched the Long marcnd Long march 7 both of which were launched from a new launch site on hainan islandFinally, Chinas human spaceflight program continues in a deliberate fashion, with the 2016of its Tiangong 2 space station The Chinese National sy (CNSa)continuing to develop its robotic investigations of the Moon with plans for venturing furtherThese signs point to a robust future in Chinese spaceflight, expanding the chinese slice of the
Testimony of Mike French Vice President,Space Systems Aerospace Industries AssociationBefore the subcommittee on sCommittee on Science, Space, and TechnologyUS House of RepresentativesJuly25,2019Chairwoman Horn Ranking member babin, and distinguished members of the subcommitteethank you for the opportunity to provide testimony today on the coThe Aerospace Industries Association(AIA)represents an aerospace and defense(A&D)industry that is at the heart of the American economy, generating $929 billion in economicItput and a trade surplus of nearly $90 billion in 2018-the largest of any US exporting sectorOur industry is supported by more than 2
5 million dedicated employees- representing 20percent of the nations manufacturing workforce- who are responsible for the continuous streamf innovations that improve American livethe Mercury Program They enabled NASA's exploration of our solar system, put the firsr 3moreover, our members helped create the foundation of Americas space efforts, starting wihumans on the moon, and supported countless missions sinceare proud that our innovations have shaped history and haen particularly gratecognize these contributions as the world celebrates the 50th anniversary of Apollo ll But oueyes are also focused firmly on the futureEarlier this year, AIA released a report called"What's Next for Aerospace and Defense: AVision for 2050, Based on in-depth interviews with Chief Technology and Chief Strategicers across the industry, the report paints a picture of the innovations that will drive the waywe move, connect, explore, and defend our interests thirty years from now And it should notto know that many of these technoleffective partnership between government and the commercial space industryOur companies, of course, are not waiting for 2050 They are living these partnerships every dayNorthrop grumman Corporations Antares and Cygnus and Sierra Nevada Corporations DreamChaser are partnered with NASa to resupply the International Space Station(Iss
Galactic's Space ShipTwo will soon transportngers to space, while The boeingCompany's Starliner will soon launch Us astronauts to the International Space Station fromS, soil They set the stage for taking the next Americans to the moon and beyond on BoeingsSpace Launch System and Lockheed Martin Corporation's Orion spacecraft These examples arenly a glimpsleercial space companies-from smallensuring Americas space leadershipLong-standing Government and Commercial Space Linkrya $360 billionconomy that has existed for decadesunicaand has supported government space activiage Just look to the Apollo ll landing, a historic moment made possible by the contribution ofore than 370,000 contractors from industry and academia The Space Shuttle, Internationalystem, and now NASAs comncargo and crew programs are all connected to the contributions and leadership of commercialspace companiesIn recent years, there has been much discussion about " commercial space, but that discussiohas lacked consistency on what constitutes"commercial "The definition of commercial is ofteninconsistently applied across companies, programs, and contracting mechanisms while aommon perception is that commercial space companies are small start-ups with privatefinancing, governmentclal space partners hafact, spannedboratetypes-including established, publicly traded companies; recent startups funded by pricapital; and private firms supported by both private and public investmenThere is not just one model for a commercial space business
NASAs high-profile commercialargo andprovide a perfect example, as the primary partners are companhdiverse portfolios that include significant government contracting activity from three publiclyone private companyWhile commercial space has existed for decades, in recent years, several hundred privateinvestment-backed firms have entered theThese firms arelithic, and how theywithin the existing commercial space economy is important to understanding their rolecurrent and future government space activitieTo two general categories The first is a handfulapitalized companies actively engaged as direct government contractors or suppliers Theecond and much larger group of these companies remain in a pre-revenue phase and are stilldeveloping their planned space offeringsThis latter group of companies is more likely to be active in"data-buy" programs(eg, NASAand NOAA's purchase of commercial remote sensing data), the governments early stagending programs (eg, the Small Business Innovation Research and the Small BusinessTechnology Transfer, and more recent programs intended to engage with these types of firms,uch as NASAs Jet Propulsion Laboratory's space accelerator In addition to private fundnany of these newer firms have also received significant government investments a recent
ort found that, of the companies that received private capital from 2000 to 2018, they alsoeceived $72 billion in US public funedtod of firms that received bothprivate and public funding, cumulative total investment from both public and private fundingOverall, the commercial space industry is one that is diverse, including small and largecompanies and companies that receive private and public investment, and has been growingThis presents both new opportunities and risks for the government as it continues to look to themeet itsShifting Procurements Strategiese government has a series of tools available to meet these requirements in the space arena InNASAs case, these tools includeOff-the-Shelf/Low-Dollar Items: simplified acquisition methods run by the governmentServices administration other agencies or NASA itselederal Acquisition Regulation(FAR): fixed-price and cost-plus contracts to both biervices and develop new capabilitieSpace Act Agreements: a statutorily provided transaction authority that allows NAsapartner with industry in an either cost reimbursable, no exchange of funds, or fundedarrangeIn deciding which of these frameworks to use, the government typically considers therequirements it needs from a product or service and what the commercial market currentlyprovides In the case of a widely available commercial product, like printer paper for example,the government is well served to buy the off-the-shelf productConversely, as the government seeks to build a next generation stealth bomber, meeting itsgovernment will also desire a significant level of control in both the development and ultimae aequirements will involve significant new developments that are not commercially available
Tuse of a stealth bomber, givefunction and capabilities In thbest served to use a cost-plus far frameworkIn some cases, the market may have an available product, but the government may also desire ael ctrol or enhanced capabilities that cannot be met commercially Satellitecommunicaare a market example of where the government takes multiple approaches Thegovernment procures commercially available satellite bandwidth for its use from satellitesoperated by companies(essentially, buying an off-the-shelf service) The government alontracts with commercial space corfixed-pricst-plus model to buildpecialized communications satellites the government itself will use and controe space context, the government has shifted its procurement strategies in some areas basedent of whereindustrys capabandprinter paper to stealth fighter spectrum This is most visibly seen in NASAs commercial cargond crew programs In these programs, NASA used a "public investment/private service modelwhich is when government subsidizes the creation of a commercial service as the primary
customer, while also requiring companies to invest varying levels of private funds into thedevelopment of that serviceUnder this model, NASa funded the majority of the development of new launch vehicles andft bhasing the future"service " oftransporting NAsa cargo andhe International Space Station The prime companies in these two programs arepacer 8 Company, Northrop Grumman Corporation, Sierra Nevada Corporation, andThes is in contrast to a model where Nasa would fund the development of a launch vehicle orspacecraft that NASA itself would operate to transport cargo and astronauts Further nAsAcrafted the procurement to require industry to commit some level of internal investment to theThis was again based on an assessment of the market and a determination that industrywould be willing to make thisment based on the opportunity to gain commercial businessfrom the ensuing capabilitiesMarket Maturity Important to Procurement Choicepublic investment/private service model to new areas requires a nuanced understandngoreyNASA recently announced its intent to use this newer"public investment/private servithe procurement of a human lunar lander for the Artemis Program The extension ofommercial space market today and a realistic assessment of its direction to ensure overall risksmarket will allow different opportunities and risk postures than partnerships mai aand opportunitiesidered
A partnership in an area with a robust, competitivred nascent marketsThe existence of a multi-billion-dollar commercial satellite launch market was criticalNASAderegarding theandxistence of this market, NASA weighed the present capabilities of US industry with thethe market and determined this was an area where the""public investment/privateservicenodel procurement strategy was viableAt the time, NASa understood this presented a risk Although the market was established andlaunch solutions existed, NASa would not be buying an"off-the-shelf"capability Launcvehicles and spacecraft would still have to be developed by industry to provide the procuredervicesFurther, NASa assessed industry would be willing to put in some level of internalent, with the rationale that the ensuing launch vehicles could be used by the companiegain commercial business apart from NAsAs NASa considers using the "public investment/private service"procurement model morewidelyess the market in emerging areas and whether theyexpected to be revenue generating From a NASa procurement perspective, using a"publicinvestment/private service "model framework creates a different risk posture if used in areas thatack a current of near nuture marke
Looking at the global space economy, there is not an active commercial lunar market The lacka current market in deep space activity presents three primary risks in using a"publicvestment/private service"model procurement strategyFirstmarkestablishedommercial services for NASA to buy today Therefore, the service of landing humans on theloon will require a great deal of development before it can be provided to NAsA Theseservices today are far from"off the shelfSecond, requiring commercial companies to invest internal funds in an area with limited marketay prevent firms that are otherwise highly capable from competing to provide theerviceAs the future market is more speculative, the risk of investment and the potential time tosee a return increases Depending on the level of required investment by NASA, this couldespecially impact medium and smaller companies that are unable to take these risks, even if theyThird, purchasing these capabilities as services will require a detailed assessment and cleapredefined determins industry responsibilities toprogram is integrated successfully
Determining these responsibilities required significantooperation between government and industry in the commercial cargo and crew programs, andthere is the risk this will be increasingly complex in a deep space programFrom NASAs perspective, these risks will require the agency to make a robust assessment ofwhether the technical, schedule, and price proposed by industry will close present capability gapsto meet NASAs technical and schedule requirements Further, NASA will have to considerwhether any proposed industry investment is supported by a realistic assessment of futureed the market anddered these factors, there may be areas wherNASA determines a different procurement path is necessaryFinally, no matter the procurement model, NASa will require clear human safety requirementsas well as a level of insight, oversight, and transparency into the development ofratedsystems Currently, it will be nasa asflying on theseand the governerving as primary funder and customer To the extent the "public investment/private servicemodel is extended to lunar activity, NASA is likely to be held responsible for safety at the end ofthe day In this regard, Congress can learn from what worked well and where NAsa ran introadblocks during the commercial crew development processCongress as a Space allyCongress'review of the commercial space landscape and its policy decisions will shape bothgovernment action and the corAs you consider NASAs next authorization and appropriations bills, Congress should providedirection about the motivation and objectives of our deep space exploration investments and thele of NAsa and its commercial partners in these arrangeInfind a set of space activities are core national capabilities, similar to assets owned and operated
by the Department of Defense, while in others, it may find industry-ownership and controbeneficOf course, Congress'actions are not limited to procurement policy, but have impacts across thedomain An often fon andommercialrootthe need for reliable, interference free, radio frequency spectrum for everything from launch ande-entry to accurate, timely, and reliable weather forecasting data Spectrum is spaces invisiblenervous system, allowing critical data to be transmitted to and from Earth
without access to thie assets and capabilitial space landscape requires a comprehensive approach to our nations future spectrumat ensures adequate and globally-harmonized spectrum for a full range of space usesal, civil, and national securityThese are just a few examples of the many roles-from passing a multi-year NASAauthorization to investing investment in Stem education and ensuring we have the mostalented workforce- where Congress should be an active ally in ensuring a thriving spaceenterpriseThe commercial space industry has been a partner with government since the earliest days of theedhepace challenges
, from thecontinued support of Us national security to returning to the Moon and going beyondbout the editorel Erbschloe has worked for over 30 years performing analysis of the economicsnformation technology, public policy relating to technology, and utilizing technology ineengineering organization processes He has authored several books on social and managementissues of information technology that were published by mcgraw hill and other majohas also taught at several universities and developed technology-relatedcurriculum His career has focused on several interrelated areas
Technology strategy,and forecastingPublishing and editinganysIsaluationBooks by michael ErbschloeSocial Engineering: Hacking Systems, Nations, and Societiesxtremist Propaganda in Social Media: A Threat to Homeland Security(CRC PressThreat Level Red; Cybersecurity Research Programs of the US Government(CRC PreWalling Out the Insiders Controlling Accesprove Organizational Security(CRo Press)Physical Security for IT(EScienemplementing Homeland Security in Enterprise IT(Digital Press)The essonDisaster Recovery( Course Technology)Graw Hill)(McGraw Hillcy: A Guide to Developing Implementing an e-business Privacy PcRaw hill
introductioHow is it that we are able to enjoy live national or worldwide television and radio broadcasts?Make international telephone calls? Use high-speed Internet and nationwide paging servicesReceive weather forecasts? Manage natural resource use? Respond to emergencies and disastersPay by credit card at a retail store? Satellite technology is the short answer But how do thosesatellites make it into spacethe function ofThirty years agowas no commercial space transportation industry By 2009, UScommercial space transportation and the services and industries it enables accounted for morethan $208 billion in economic acOver one million peoplevities This lelikely tthe futuredependent onommercial space transportation emergeThe FAA is responsible for ensuring protection of the public, property, and the national securityand foreign policy interests of the United States during commercial launch or reentry activities,facilitating, and promoting Us commercialtransporTo dateA019) the FAA Office of Commercial Space Transportation has licensed or permittedore than 370 launches, reentries and launch sitesUS commercial space transportation industry had its most productive year ever in fiscal32 FAAsed launches, three reentries, and two new launch sites, bringingthe total number of Us launch sites to 12 The FAa is forecasting as many ascommercial space transportation activities in fiscal year 2019Between 1963 and 1982, US expendable launch vehicle (elv) manufacturers producedehicles only under contract to the National Aeronautics and Space Administration (NAsa)the Department of Defense (DOD)
In the early 1970s, when private companies and foreigngovernments purchased communications satellites, they had to contract with NAsa to launctheir payloads Through NASA, launches could be procured on any one of four ELVs: Titan,built by Martin Marietta; Atlas, built by General Dynamics; Delta, built by mcDonnell Dougand Scout, built by LtV Aerospace Corporation NASA would purchase a launch vehiclough traditional government procurement practices, and the launch would be conducted by avate-sector contractor under Nasa supervisionFor a long time the US government essentially served as the only provider of space launchservices to the Western world Seeing an opportunity to provide launch services, the EuropeanSpace Agency developed its own ELv, Ariane, which became the first competitor to NASA forcommercial launches The first Ariane launch occurred in 1979, and in 1984, a private company,Arianespace, took over commercial operation of the vehicleIn the late 1970s thegovernment decided to phase out all ELVs, except Scout, in favor ofthe Us space shuttle The shuttle would take all US government satellites, as well asrbit nasa deI the shuttlemade its first flight in 1981perational in 1982, and government funding of elv production ceased in 1983became evident, however, that the flight schedule of the shuttle could not meet all of the u sand commercial launch requirements As the need grew for more launches than
Asa could handlefacturers expressed interestnch servicesIn 1982 the first successful private launch in the united States took placSStype Conest:ket The proceduresfor thatlaunch, however, proved time-consuming and led to the introduction of legislation to makeasier for companies to pursue commercial launch activitiesintroduced in theHouse by Congressman Daniel Akaka(D-HI)would have designated the Department oflead agency, while the Senate bill(S 560), introduced by Earnest"Fritz " HollingsD-SC), intended to give the lead role to the Federal Aviation Administration(FAA) Othersuggested the lead go to the Department of State or NASA While Congress debated the efficacyof its legislation, on July 4, 1982, President Ronald Reagan issued national security decisiordirective(NSDD)42, National Space Policy, stating that expansion of US private sectorspace activities was a national goalThe Presidents Senior Interagency Group on Space subsequently reviewed the policy andoncluded a commercial ELV capability would offer substantial benefits to the nation byMaintaining a high-technology industrial baseProviding jobs for thousands of workers, thus adding to the federal tax baseSpawning numerous spinoff and supporting activitiesStrengthening the Us global positionProviding a potential market for excess flight hardware, special-purpeequipment, and propellants; andCreating a market for US government and facilitiesOn May 16, 1983, the President issued NSDD 94, " Commercialization of Expendable LaunchThis stated the“US
Gfully endorses and will facilitate thecommercialization of US Expendable Launch Vehicles The US Government will licenseupervise, and/or regulate US commercial elV operations only to the extent required to meeits national and international obligations and to ensure public safetyThe directive created an interim space working group on commercial launch operation cochaired by the Department of Staa faa and the Federal communicationsCommission also had representatives in the group Among other things, the President mandatedthe group develop and coordinate the requirements and processes for the licensing, supervision,and/or regulations applicable to commercial launch operations and recommend the appropriateagency with thegovernment responcommercial launch activitiesThe group submitted its report on September 15, 1983 It did not recommend a lead agency, butinstead, deferred to the Cabinet Council for Commerce and Trade at a meeting of the councildepartenf Transportation(DOt) as the agency with principal responsibility for fostering the privatemmercialELV business His rationale centered on the fact that DOT, as a department thatunderstood the regulatory process and with experience as a deregulator(airline, railroad, etciquely suited to remove regulatory barriers and to streamline regucreate a commercial space industry
In a January 1984 speech, Secretary of Transportation Elizabeth Dole explained the Presidentwanted to stimulate interest in commercial space ventures by removing regulatory barriers Shesaid that companies trying to operate in space must go through as many as 17 agencies to getappropriate permits and licenses
DOTdthrough the thicket of clearances, licenses, and regulations that keep industrial space vehiclthered to their padsOn February 24, 1984,Ee Order 12465 formally designated DOT as the leadencouraging facilitating, and licercommercial elv activities, dot entrusted these dto a new Office of Commercial Space Transportation Dole appointed Jennifer"Jenna "Dorn asthe first director of the new office Prior to her appointment, she had served as Elizabeth Dolesspecial assistant
Congress affirmed and expanded these actions through the Commercial Space Launch Actenacted on october 30 1984 This legislation addressed three substantive areas: licensing andgulation; liability insurance requirements; and access of private launch companies togovernment facilities Despite the legislation, US launch firms remained largely uninterestedch services, finding it difficultpete against the goverubsidized space shuttle US policy changed in the wake of the January 28, 1986, space shuChallenger tragedy The government reversed its policy of phasing out ELVs and insteadadopted a mixed-fleet approach where both el Vs and the shuttle were available for commercialOn August 15, 1986, Reagan issued NSDD 254, United States Space Launch Strategy, whichlimited NASAs role in providing commercial launches to only those satellites that required theunique capabilities of the shuttle or for which there were unusual foreign policy considerationsThe resulting unavailability of Nasa as a domestic civilian launce, coupled with theady enacted legislation led to the emergence of thecommercial launch servicesdustry On February88, President Reagan issued the"Presidential Directive on Nationalace Policy, which required US government agencies to purchases launch services fromThe USlicensed commercial space industry made its firstin March 1989 when Spacerbital trip altarfire rocket
Later in 1989McDonnell douglas made the first Us -licensed commetal launch on august 27 usingDelta i launch vehicleOn August 7, 1995, DOT announced that the Office of Commercial Space Transportation wouldmove from the Office of the Secretary to FAA, effective October 1, 1995, as part of a largerDOTThe transfer of the office was delayed, howevil sanctioned bylegislation The fiscal year 1996 DOT appropriations bill, signed by President Bill Clinton orNovember5, cleared the way for the transfer of the office of Commercial Spaceransportation from DOTs Office of the Secretary to FAA The transfer became effective onNovember 16 of that yearThe Federal Aviation Administration(FAA)Office of Commercial Space Transportation(AST)is the us government organization responsible for regulatinre operations ofommercial space transportation industry and facilitating its international competitiveness Iaccomplishes its task by licensing and permitting these activities, which include expendable andble orbital launch vehicles, and suborbital launch vehicles The ast innovativeexperimental launch permitting process is designed for the testing, development, and reentry oeusable suborbital launch vehicles As private industry comes closer to testing vehicles that willbe capable of taking passengers and tourists on suborbital flights, companies and organizationsposing to offer training in human spaceflight training and several organizations haveprovide thiserviceSpace transportation is the movement of, or means of moving objects, such as satellites andvehicles carrying cargo, scientific payloads, or passengers, to, from, or in space Commercialarried outbital and suborbital vehicles owned and operated byprivate companies or organizations for profit, procured through a competitive bidding processThe Us space transportation industry operates in almost half the states in the United States
Today, there are several companies around the world that offer orbital comilaunchervices Additionally, some companies are being established to offer suborbital services forpaying passengers In recent years, commercial launches have comprised about one-third ofAnother, growing part of the commercial space transportation industry in the United States is theed launch recommercial spaceports(PDF) These spaceports can provide alternatives to government launchsites operated by the US Air Force or NASA AST licenses the operation of commercialspaceports in the US By 2018, AST had issuednses in eight statesCommercial Space Transportation Advisory Committee(COMSTAC) was established in 1984provide information, advice, and recommendations to the Administrator of the Federal AviationAdministration(FAA)on critical matters concerning the us commercial space transportationThe economic, technical, and institutional expertise provided by COmstAC members has beinvaluable to our work in developing effective regulations that ensure safety during commerciallaunch operations and policies that support international competitiveness for the industryCOMSTAC membership consists of senior executives from the codustry; representatives from the satellite industry, bothfacturers and users: state and localovernment officials; representatives from firms providing insurance, financial investmentlegal services for commercial space activities; and representatives from academia, spaceadvocacy organizations, and industry associationsNASAS role in fostering the emerging Commercial Space sector is shared with the FAa officeof Commercial Space Transportation and the office of Space Commercialization of theDepartment of Commerce
At the first Ccial spacrksheJune 2010 nasastablished 5 working groups that focus on mapping the barriers for Commercial Space andidentify potential solutions to these barriers During a follow on workshop in July, the workinggroups have addressed these issues and are working on mapping the barriers and possiblelutions This will ultimately drive the prioritization of where nasa technology developiand investment willresident Obama issued a National Space Policy directive providingcomprehensive guidance for all government activities in space, including the commercial, civil,and national securityce sectors The new policy leaned farther forwardport ofbusiness interests than any previous space policy The principles section of the policy statesThe United States is committed to encouraging and facilitating the growth of a US commercialspace sector that supports US needs, is globally competitive, and advances US leadership inThe first of the six stated policy goals is to "Energize competitive doindustries toparticipate in global markets and advance the development of: satellite manufacturing; satelliteased services; space launch; terrestrial applications; and increased entrepreneursThe policy includes a set of Commercial Space Guidelines directing the Us Government to
Purchase andialbilitd services to the maximum practical extenthen such capabilities and services are available in the marketplace and meet United StatesGovernment requirementsModify commercial space capabilities and services to meet government requirements wherilities anddo not fully meet theslirements and theotential modification represents a more cost-effective and timely acquisition approach for thegovernmenActively explore the use of inventive, nontraditional arrangements for acquiring commercialspace goods and services to meet United States Government requirements, including measuresand purchasing scientific or operational data products from commercial satellite operatorsuch as public-pIrtnerships, hosting government capabilitiesupport of government missionsDevelop governmental space systems only when it is in the national interest and there is nouitable cost-effective us commercialappropriate, foreign commercial service or systemhat is or will be availableefrain from conducting United States Government space activities that preclude, discourageUS commercial space activities, unless required by national security or publicsafetyPursue potential opportunities for transferring routine, operational space functions to thecommercial space sector where beneficial and cost-effective, except where the government haslegal, security, or safety needs that would preclude commercializationCultivate increased technological innovation and entrepreneurship in the commercial spaceector through the use of incentives such as prizes and competitionsEnsure that United States Government space technology and infrastructure are made availacommercial use on a reimbursable, noninterference, and equitable basis to the maximumpractical extentnuch as possible, the regulatory burden for commercial space activities andenvironmentg spely and respoFoster fair and open global trade and commerce through the promotion of suitable standardsEncourage the purchase and use of U
S commercial space services and capabative arrangements; andActively promote the export of Us commercially developed and available space goods arservices, including those developed by small-and medium-sized enterprises, for use in foreignnsistent with US technology transfer and nonproliferation objectivesThe guidelines define""commercial"space as referring to goods, services, or activities providedby private sector enterprises that bear a reasonable portion of the investment risk andperate in accordance with typical market-based incentives for