NASA: It's Our Space Station – Not Yours

Keith’s note: NASA held a ISS National Lab Public Day CAN meeting on 10 December 2010. The purpose was to explain the pending Cooperative Agreement Notice and how interested parties should structure their proposals. The main speaker was NASA’s Mark Uhran.
It is quite clear that while NASA is going through the motions of trying to expand the user base for its portion of the International Space Station, that it is still falling back on bad habits i.e. limiting how much of these resources anyone other than NASA will ever be able to tap.
More than once, Uhran stated rather emphatically that any group looking to run the ISS National Laboratory organization who proposed to conduct human life science would find their proposal deemed “non-responsive”. Alas, Uhran has yet to provide the formal justification for this stance – one based on law and advisory committee recommendations.
Indeed, at one point Uhran bragged that he had written 5 papers on discoveries that had been made on the ISS, but he was not going to tell anyone where to find them – challenging the attendees to go dig these papers up themselves. That is certainly an odd stance for a NASA official to take – especially one who is charged with promoting the value of the ISS as a platform for scientific research.
As for the unsubstantiated declaration by Uhran regarding research that is verboten, this is also repeated in the quietly released Reference Model for the International Space Station US. National Laboratory:

Page 58 “HUMAN SPACE FLIGHT – NON NASA. Exposure of humans to the reduced gravity environment of space accelerates some changes in the body, including bone loss, muscle wasting and balance disorders. This provides the unique opportunity to take advantage of microgravity conditions as a screening test for therapeutics with applications in both space and on Earth. This was part of the strategy used by Amgen to test its anti-bone wasting drug Prolia(TM) (denosumab), which was approved by the FDA in June 2010 to treat patients at risk for osteoporosis. The NPO would not have a biomedical research pathway for human performance in space, but the value of this NASA research could be maximized by coordination of research synergies for other applications.”
As to where the ISS National Laboratory organization is supposed to get its guidance, according to PUBLIC LAW 111-267–OCT. 11, 2010 124 STAT. 2827 – SEC. 504. MANAGEMENT OF THE ISS NATIONAL LABORATORY – (d) RESEARCH CAPACITY ALLOCATION AND INTEGRATION OF RESEARCH PAYLOADS.
“(3) RESEARCH PRIORITIES AND ENHANCED CAPACITY.–The organization with which the Administrator enters into the cooperative agreement shall consider recommendations of the National Academies Decadal Survey on Biological and Physical Sciences in Space in establishing research priorities and in developing proposed enhancements of research capacity and opportunities for the ISS national laboratory.”
Taking a look at the NAS report mentioned by Public Law 111-267 i.e. Life and Physical Sciences Research for a New Era of Space Exploration An Interim Report one can see that the clear value to doing human-based research is mentioned:
“The International Space Station provides a unique platform for research, and past studies have noted the critical importance of its research capabilities to support the goal of long-term human exploration in space. … * Behavioral research to mitigate the detrimental effects of the spaceflight environment on astronauts’ functioning and health; * Human and animal biology research to increase basic understanding of the effects of spaceflight on biological systems and to develop critically needed countermeasures to mitigate the negative biological effects of spaceflight on astronauts’ health, safety, and performance;”
Nowhere does this report state that only NASA should do this research and that the ISS National Laboratory organization should be barred from doing so – at the risk of having any proposal that makes this suggestion deemed non-responsive. If the expressed intent of the National Lab concept is to allow the broadest possible number of users to make the greatest utility of the ISS, then it seems to be contradictory to take one of the more important aspects of the ISS and prohibit that same large research community from utilizing it. Maybe a private consortia might want to fly someone to the ISS ala Soyuz (or Dragon) passengers specifically for the purpose of biomedical research? Indeed a number of Soyuz customers have done their research on themselves already – much of it self-funded and initiated.
According to Public Law 111-267 there is no prohibition upon using other reports, recommendations or guidance from other sources – including commercial and educational entities. Nor is this new National Lab entity it precluded from simply soliciting them from the general public. Yet NASA makes no mention of this in the CAN. Public Law 111-267 goes on to state:
“(4) RESPONSIBILITY FOR RESEARCH PAYLOAD.–NASA shall retain its roles and responsibilities in providing research payload physical, analytical, and operations integration during preflight, post-flight, transportation, and orbital phases essential to ensure safe and effective flight readiness and vehicle integration of research activities approved and prioritized by the organization with which the Administrator enters into the cooperative agreement and the official or employee designated under subsection (b).”
Again, these words do not say that only NASA can do these things or that research conducted by the ISS National Laboratory contractor is to be prohibited from doing so. In addition to prohibiting the ISS National Laboratory contractor from getting its hands on human-based research. Mark Uhran also stated that any proposal that proposed to do anything with spacecraft systems or engineering would be similarly deemed non-responsive.
In other words two of the most interesting things you can do on the ISS – the sorts of thing you’d want a larger research base to focus on (assuming you are really interested in outside participation) are off limits due to executive fiat.
Where is NASA’s justification for limiting the ability of the private and educational sectors from making full utilization of the amazing capabilities that are offered by the ISS? Answer: NASA made it up. Truth be known, NASA was dragged kicking and screaming into supporting this National Laboratory concept. Congress had to enact a law to make them do it.
At one point in the CAN Public Day meeting Mark Uhran stated that NASA had been trying to do this sort of thing for 20 years. The fact that NASA has never managed to pull something like this off on its own while it banged its head against the wall and ran in circles for 20 years speaks volumes to the agency’s lack of interest in allowing anyone to use the ISS other than itself.
That selfishness is not going to go away any time soon.
Related stories
Summary of the ISS National Laboratory CAN (not so) “Public Day”
How NASA Plans to Drag Its Feet in Implementing the ISS National Laboratory