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

Sun Oct 25 22:35:39 PDT 2009

Ah, so our universities can *teach* foreign nationals how to design and build everything needed to make a satellite, we just can't engage them in the "research of satellites"?  I give up.

Greg  KO6TH

> Date: Sun, 25 Oct 2009 17:38:12 -0700
> From: bill at hsmicrowave.com
> To: ko6th_greg at hotmail.com
> CC: tosca005 at tc.umn.edu; amsat-bb at amsat.org
> Subject: Re: [amsat-bb] Re: ITAR is interesting to me
> 
> Greg, the same rules apply to Universities (even our military schools, 
> ie. West Point el al.). This continues to be a real sore spot with 
> University research programs on things related to satellites or any of 
> the areas subject to ITAR. It's get especially tricky when students, 
> which are foreign nationals, try to become involved.
> 
> But, as I keep saying, if you're involved with "munitions" controlled by 
> ITAR and many things related to satellites are, them become familiar 
> with the rules and follow them. If your in doubt, them become familiar 
> with the rules and follow them.
> 
> Regards...Bill - N6GHz
> 
> 
> 
> Greg D. wrote:
> > 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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