It was with some dismay that I read the “Guidance for Obtaining Military SATCOM Services from a Commercial Provider via Hosted Payloads”, issued by the DoD’s CIO office in September 2012. The tone and direction provided within this document come across as extremely proscriptive; risking the conclusion that hosted payloads for DoD users would be inadvisable altogether. Since my company provides capacity solely to Government users, any deterioration in the ability to do so greatly concerns us.
At a time when we are all searching for more cost-effective ways to deliver force-enabling technologies to the warfighter, hosted payloads represent a significant step in the right direction. Industry has been successfully employing them for over a decade – the value proposition is undeniable!
XTAR is uniquely familiar with the hosted payload model. Our fleet is comprised of both a hosted and a host payload, each having demonstrated an excellent track record. XTAR-LANT, at 30 degrees West, is a hosted payload on SpainSat. On XTAR-EUR, at 29 degrees East, we host a specific payload configuration for a long-term customer. Both payloads have operated at 100% of capability since their respective launches in 2005 and 2006.
I attended a meeting with the DoD CIO office staff in February this year. USG representatives explained that the intent of their memo was to generate discussion with industry, not to provide hard-and-fast rules. If this was the goal, the guidance as written misfires severely. Instead, it provides one-size-fits-all guidance on extremely complex areas of spectrum and orbital slots. It does so without recognizing the wide range of financial and operational practicalities for both government and industry partners in the myriad hosted payload scenarios. On balance, the memo as written actually puts more obstacles in the way of a successful Government hosted payload strategy, contrary to the National Space Policy’s urge to explore such arrangements.
The CIO-issued guidance unnecessarily dictates that the Government take positions on issues at the policy level that should clearly, more appropriately and more successfully be dealt with at a contractual level. The guidance doesn’t reflect the possibility of certain terms being applicable and negotiable in one instance, and then being entirely inappropriate in the next. Each hosted payload opportunity is unique; policy should foster and enable insertion of new technologies and new business models, not hinder them!
Finally, if accepted at face value, the CIO’s hosted payload guidance lays down some extremely difficult parameters for a potential commercial satellite operator partner to swallow. Among other things, the satellite operator is expected to permanently cede the right to frequencies at an orbital slot to the U.S. Government and give it the right to launch a replacement satellite into that orbital slot at any time. This unfairly limits the commercial operator’s opportunity for future revenue.
I urge the CIO to withdraw this guidance memo and replace it with a more open and inclusive document that could then pave the way to harnessing the value proposition of hosted payloads. Not doing so in this period of stiff financial constraints would be a huge missed opportunity. The DoD Deputy CIO, Maj. Gen. Wheeler, could signal a revived and genuine desire to engage with industry in a collaborative and constructive manner by encouraging industry dialogue and input on a new guidance memo.
Engagement between DoD and industry in a meaningful and cooperative manner could yield far more appropriate guidance that complies with all national and international regulations, and can still be consistent with National Security interests. I remain optimistic that, working together, industry and DoD can find the right way to structure a productive and collaborative path that delivers the greatest value of hosted payloads to the U.S. Government.