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: [email protected] To: [email protected] CC: [email protected] 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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