[amsat-bb] Re: ITAR is interesting to me

[Greg D.]

I wonder if we could hook up with a university somewhere?  Become part of their graduate program in Astro-something, even get some graduate students to help with the design and manufacture...  What sort of restrictions do they have on the definition of a "student"?  

Just a thought,

Greg  KO6TH


> Date: Sun, 25 Oct 2009 12:14:38 -0700
> From: bill at hsmicrowave.com
> To: tosca005 at tc.umn.edu
> CC: amsat-bb at amsat.org
> Subject: [amsat-bb] Re: ITAR is interesting to me
> 
> Hi John,
> 
> The completed satellite is usually exempt. This is how AO-51, as a 
> completed satellite, went to Russia and was launched on a Dnepr. AMSAT 
> has in the past and will in the future, apply for an export license for 
> a satellite. It's when you try to export satellite components or 
> technology, like the IHU, the SDX for the P3E, or engage in dialog 
> regarding a satellites thermal performance the the AMSAT-DL folks to 
> assist them, that you run afoul of ITAR.
> 
> There's a big different between sharing technology and components than 
> it is to export a complete satellite for launch. Often the State Dept. 
> will require that a representative(s) of the satellite builders (and 
> sometimes the State Dept. itself) accompany the satellite at all times, 
> insuring that no one can get a closer look than just the outside, right 
> through the launch.
> 
> Yes, a bit confusing and frustrating, but workable.
> 
> Regards...Bill - N6GHz
> 
> John P. Toscano wrote:
> > Bob McGwier wrote:
> >> ANY aspect dealing with a satellite, software, hardware, ground stations 
> >> (hardware, software, protocols, etc.), ideas, random ejaculations from a 
> >> diseased mind or whatever that deals with spacecraft or ground stations 
> >> are DEEMED EXPORTS when they depart a U.S. citizen and are delivered to 
> >> a non-U.S. citizen.  It is a nearly impossible task to abide by and one 
> >> that really makes me want to throw my hands up in despair and walk away.
> >>
> >> There are exceptions for classrooms and courses taught in U.S. 
> >> university's.  A person, even a non-U.S. citizen, who can pay for taking 
> >> a course, may go and involve themselves in course work, even if it is 
> >> dealing with the design, construction, and control of spacecraft during 
> >> the course work.  Some of this applies to your earlier questions but for 
> >> US service academies,  there are very few non-U.S. citizens in them.
> > 
> > Bob:
> > 
> > I would not dream of second-guessing you for a moment, since you are 
> > fully engaged in this stuff and I am simply an interested observer.
> > 
> > However, why doesn't the following quotation directly from the ITAR 
> > regulations provide the exemption we need? The quotation comes from the 
> > section that defines what are the items that are covered by ITAR:
> > 
> > ITAR Part 121 - The United States Munitions List
> > 
> > -----------------------< begin quote >-------------------------------
> > 
> > Category XV - Spacecraft Systems and Associated Equipment
> > 
> > *(a) Spacecraft, including communications satellites, remote sensing 
> > satellites, scientific satellites, research satellites, navigation 
> > satellites, experimental and multi-mission satellites.
> > 
> > *NOTE TO PARAGRAPH (a): Commercial communications satellites, scientific 
> > satellites, research satellites, and experimental satellites are 
> > designated as SME only when the equipment is intended for use by the 
> > armed forces of any foreign country.
> > 
> > -----------------------< end quote >---------------------------------
> > 
> > Note that SME refers to "Significant Military Equipment"
> > 
> > Paragraph (a) seems to cover everything and anything having to do with 
> > satellites, but the asterisk and "NOTE" attached to it seems to say that 
> > an Amateur radio satellite for use by Amateurs instead of foreign armed 
> > forces should be exempted, doesn't it?
> > 
> > Granted, I realize that we have already lost one argument with ITAR 
> > about our past cooperation with AMSAT-DL, but is there some compelling 
> > reason why the lawyers didn't point out this exception?
> > 
> > Just wondering...
> > If I had to guess the answer myself, after looking at the horribly 
> > convoluted language of the small piece of the ITAR regulations that I 
> > have looked at, there is probably another paragraph elsewhere that 
> > effectively says, "we were just kidding when we said that it had to be 
> > used by foreign armed forces, we really mean it to cover everything"
> > 
> > John
> > W0JT
> > 
> > 
> > _______________________________________________
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> 
> _______________________________________________
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