Is NASA Going To Break The Law By Not Delivering An ISS Transition Plan To Congress?

Keith's note: NASA HEOMD AA Bill Gerstenmaier was speaking at the NASA Advicory Council Human Exploration and Operations Committee meeting today. It certainly seems that he has decided that NASA is not going to comply with S.442 - National Aeronautics and Space Administration Transition Authorization Act of 2017 - which is now law. In that law Congress told NASA that they are to deliver a ISS Transition plan no later than 1 December 2017 - this Friday. All indications I get from NASA - and Gerstenmaier's statement - make it clear that there is no plan to be delivered.

Per 2017 NASA Transition Auth Act, NASA must submit an ISS Transition report by Dec 1, 2017 (Friday).
Was a long disc at NAC/HEO today about how NASA thought about that report.
Gerst said it's not a "plan" but "considerations" in order to start a dialogue.

— Marcia Smith (@SpcPlcyOnline) November 29, 2017

According to S.442 - National Aeronautics and Space Administration Transition Authorization Act of 2017 (Public Law No: 115-10 (03/21/2017))

"(1) ((NOTE: Coordination.)) In general.--The Administrator, in coordination with the ISS management entity (as defined in section 2 of the National Aeronautics and Space Administration Transition Authorization Act of 2017), ISS partners, the scientific user community, and the commercial space sector, shall develop a plan to transition in a step-wise approach from the current regime that relies heavily on NASA sponsorship to a regime where NASA could be one of many customers of a low-Earth orbit non-governmental human space flight enterprise.

(2) Reports.--Not later than December 1, 2017, and biennially thereafter until 2023, the Administrator shall submit to the Committee on Commerce, Science, and Transportation of the Senate and the Committee on Science, Space, and Technology of the House of Representatives a report that includes--"

Full section below

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