AMSAT, ITAR, More AMSAT-NA Volunteers & Such . . .
Ladies & Gentlemen,
Here's the main thing to think about ITAR. ITAR regulates OUTFLOW of information, it doesn't care about INFLOW of information. If you build or design it by a non-US Person (Citizen or Legal Permanent Resident) and you bring it INTO the US, ITAR does not care. So AMSAT-NA can use designs from P3E, but cannot design parts of P3E.
So the logical thing to do is have all "major" future AMSAT spacecraft be AMSAT-NA managed spacecraft with design elements (camera systems, experiments, etc.) contributed by other AMSAT organizations. The only main technical interaction between the AMSATs would be via a standard, open-sourced, well-published-in-technical-journals interface specification. Money could be contributed from other AMSATs to fund launch & development costs.
As for the mantra of "no one being able to develop the equipment in the US" . . . The volunteer base is not capped, just expand the size of the volunteer base and organize it better. None of the experienced engineers should be directly building hardware, we should all be supervising teams of engineering students who actually build the equipment. There are over 250 University Engineering programs in the US. Each of those programs have at least 50 students in each graduating class. Let's say that we can get 15% of the students interested in working on a satellite project (my personal observations are more like 75% of the students are interested).
Let's do the Math: Worse Case: 250 Schools x 50 students per graduating class x 15% = 1875 POTENTIALLY INTERESTED STUDENTS IN THE US Best Case: 250 Schools x 50 students per graduating class x 75% = 9375 POTENTIALLY INTERESTED STUDENTS IN THE US And this is just talking about COLLEGE SENIORS - EE's, ME's, CE's, CS's, SE's . . . double the number if you include the Juniors.
Anywhere near this load of students would completely overload the current AMSAT-NA volunteer base. But talk about the potentially available volunteer base!
With Binghamton University, I had 7 Hardware Engineering slots available on the team. There are 200 Hardware Engineers in the BU graduating class - about 168 of the students wanted to be on the Satellite Project Team, a 24x over-subscription. That's pretty impressive. I could have had more teams, but we need to crawl, the walk, then run with this activity - EVOLUTIONARY not REVOLUTIONARY (but let's just make sure evolution works quickly . . .)
The current BU student team is "stoked", they are really excited to be working the project. Every week I get thanked by the students for bringing the project to their attention. They have done some really great work and they have a great faculty advisor, Dr. Roger Westgate. I expect that there will be more than 1 project team next year working on an AMSAT satellite, assuming AMSAT is interested in sponsoring more.
So stop crying into your beer over ITAR. The world is not coming to an end. Let's work to launch spacecraft within the ITAR limits. In the meantime, let the AMSAT-NA BoD navigate it's way through the byzantine structure of the US Govt to try to bring about change in ITAR.
Alex Harvilchuck, N3NP
Alex,
A good post. We are indeed adapting to the Brave New World of ITAR, and we are not alone in that. At a recent SmallSat meeting I attended, there was even a tutorial for companies large and small, large being the size of Boeing. It was about how to work with and around ITAR if you are involved with the Operationally Responsive Space initiative. Doable it is, but easy it isn't. Even at the university level, the consequences of not doing it right can be considerable. An emeritus professor associated with a major state university in Tennessee was just sentenced to several months in jail for not following the rules with his consulting company and personnel.
While some of us feel like pounding our heads against the wall in frustration, few if any are crying in their beer about ITAR at the level where things actually get done. However, it has taken a longer time than any would have wished to determine exactly what paths are going to be open. Some past paths are definitely(?) closed, and others are being opened. Still, all of us are going to need to understand how those paths can be worked efficiently and productively. The IBM and SUNY-Binghamton are just the beginning of that process.
Alan WA4SCA
-----Original Message----- From: amsat-bb-bounces@amsat.org [mailto:amsat-bb-bounces@amsat.org] On Behalf Of Alex, N3SQ Sent: 16 November, 2009 11:35 To: amsat-bb@amsat.org Subject: [amsat-bb] AMSAT, ITAR, More AMSAT-NA Volunteers & Such . . .
Ladies & Gentlemen,
Here's the main thing to think about ITAR. ITAR regulates OUTFLOW of information, it doesn't care about INFLOW of information. If you build or design it by a non-US Person (Citizen or Legal Permanent Resident) and you bring it INTO the US, ITAR does not care. So AMSAT-NA can use designs from P3E, but cannot design parts of P3E.
So the logical thing to do is have all "major" future AMSAT spacecraft be AMSAT-NA managed spacecraft with design elements (camera systems, experiments, etc.) contributed by other AMSAT organizations. The only main technical interaction between the AMSATs would be via a standard, open-sourced, well-published-in-technical-journals interface specification. Money could be contributed from other AMSATs to fund launch & development costs.
As for the mantra of "no one being able to develop the equipment in the US" . . . The volunteer base is not capped, just expand the size of the volunteer base and organize it better. None of the experienced engineers should be directly building hardware, we should all be supervising teams of engineering students who actually build the equipment. There are over 250 University Engineering programs in the US. Each of those programs have at least 50 students in each graduating class. Let's say that we can get 15% of the students interested in working on a satellite project (my personal observations are more like 75% of the students are interested).
Let's do the Math: Worse Case: 250 Schools x 50 students per graduating class x 15% = 1875 POTENTIALLY INTERESTED STUDENTS IN THE US Best Case: 250 Schools x 50 students per graduating class x 75% = 9375 POTENTIALLY INTERESTED STUDENTS IN THE US And this is just talking about COLLEGE SENIORS - EE's, ME's, CE's, CS's, SE's . . . double the number if you include the Juniors.
Anywhere near this load of students would completely overload the current AMSAT-NA volunteer base. But talk about the potentially available volunteer base!
With Binghamton University, I had 7 Hardware Engineering slots available on the team. There are 200 Hardware Engineers in the BU graduating class - about 168 of the students wanted to be on the Satellite Project Team, a 24x over-subscription. That's pretty impressive. I could have had more teams, but we need to crawl, the walk, then run with this activity - EVOLUTIONARY not REVOLUTIONARY (but let's just make sure evolution works quickly . . .)
The current BU student team is "stoked", they are really excited to be working the project. Every week I get thanked by the students for bringing the project to their attention. They have done some really great work and they have a great faculty advisor, Dr. Roger Westgate. I expect that there will be more than 1 project team next year working on an AMSAT satellite, assuming AMSAT is interested in sponsoring more.
So stop crying into your beer over ITAR. The world is not coming to an end. Let's work to launch spacecraft within the ITAR limits. In the meantime, let the AMSAT-NA BoD navigate it's way through the byzantine structure of the US Govt to try to bring about change in ITAR.
Alex Harvilchuck, N3NP
_______________________________________________ Sent via AMSAT-BB@amsat.org. Opinions expressed are those of the author. Not an AMSAT-NA member? Join now to support the amateur satellite program! Subscription settings: http://amsat.org/mailman/listinfo/amsat-bb
Alex et. al, I would like to add in a comment that according to the latest SBIR release from DoD (many organizations), ITAR compliant persons who are not US Citizens can also be included in DoD funded commercial research projects, as long as they are correctly registered and supervised under the ITAR regulations. This means that if a student from a US university who is NOT a US Citizen, but rather a US LPR green card holder or beneficiary of a protected class of visitor able to be employed, can potentially:
* work as a student intern in a commercial company * work in projects that require ITAR clearance subject to supervision * work alongside with other US Citizens.
This is pretty good opportunity for all in my opinion. I am sure this would be the same case for STTR opportunities as well. Some of these projects can involve aerospace projects, or materials/processes useful for future aerospace projects.
I quote from the SBIR preface at : http://www.acq.osd.mil/osbp/sbir/solicitations/sbir101/index.htm * Export Control.* The International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120 through 130, and the Export Administration Regulations (EAR), 15 CFR Parts 730 through 799, will apply to all projects with military or dual-use applications that develop beyond fundamental research, which is basic and applied research ordinarily published and shared broadly within the scientific community. More information is available at * http://www.pmddtc.state.gov/regulations_laws/itar.html*http://www.pmddtc.state.gov/regulations_laws/itar.html. NOTE: Export control compliance statements found in the individual component proposal instructions are not meant to be all inclusive. They do not remove any liability from the submitter to comply with applicable ITAR or EAR export control restrictions or from informing the Government of any potential export restriction as fundamental research and development efforts proceed.
Sample text from an SBIR:
The technology within this topic is restricted under the International Traffic in Arms Regulation (ITAR), which controls the export and import of defense-related material and services. Offerors must disclose any proposed use of foreign nationals, their country of origin, and what tasks each would accomplish in the statement of work in accordance with section 3.5.b.(7) of the solicitation
I would hope AMSAT-NA would consider teaming with universities to apply for research grants like these.
-samudra N3RDX
On Mon, Nov 16, 2009 at 12:35 PM, Alex, N3SQ amsat@elkmtn.org wrote:
Ladies & Gentlemen,
Here's the main thing to think about ITAR. ITAR regulates OUTFLOW of information, it doesn't care about INFLOW of information. If you build or design it by a non-US Person (Citizen or Legal Permanent Resident) and you bring it INTO the US, ITAR does not care. So AMSAT-NA can use designs from P3E, but cannot design parts of P3E.
So the logical thing to do is have all "major" future AMSAT spacecraft be AMSAT-NA managed spacecraft with design elements (camera systems, experiments, etc.) contributed by other AMSAT organizations. The only main technical interaction between the AMSATs would be via a standard, open-sourced, well-published-in-technical-journals interface specification. Money could be contributed from other AMSATs to fund launch & development costs.
As for the mantra of "no one being able to develop the equipment in the US" . . . The volunteer base is not capped, just expand the size of the volunteer base and organize it better. None of the experienced engineers should be directly building hardware, we should all be supervising teams of engineering students who actually build the equipment. There are over 250 University Engineering programs in the US. Each of those programs have at least 50 students in each graduating class. Let's say that we can get 15% of the students interested in working on a satellite project (my personal observations are more like 75% of the students are interested).
Let's do the Math: Worse Case: 250 Schools x 50 students per graduating class x 15% = 1875 POTENTIALLY INTERESTED STUDENTS IN THE US Best Case: 250 Schools x 50 students per graduating class x 75% = 9375 POTENTIALLY INTERESTED STUDENTS IN THE US And this is just talking about COLLEGE SENIORS - EE's, ME's, CE's, CS's, SE's . . . double the number if you include the Juniors.
Anywhere near this load of students would completely overload the current AMSAT-NA volunteer base. But talk about the potentially available volunteer base!
With Binghamton University, I had 7 Hardware Engineering slots available on the team. There are 200 Hardware Engineers in the BU graduating class
- about 168 of the students wanted to be on the Satellite Project Team,
a 24x over-subscription. That's pretty impressive. I could have had more teams, but we need to crawl, the walk, then run with this activity - EVOLUTIONARY not REVOLUTIONARY (but let's just make sure evolution works quickly . . .)
The current BU student team is "stoked", they are really excited to be working the project. Every week I get thanked by the students for bringing the project to their attention. They have done some really great work and they have a great faculty advisor, Dr. Roger Westgate. I expect that there will be more than 1 project team next year working on an AMSAT satellite, assuming AMSAT is interested in sponsoring more.
So stop crying into your beer over ITAR. The world is not coming to an end. Let's work to launch spacecraft within the ITAR limits. In the meantime, let the AMSAT-NA BoD navigate it's way through the byzantine structure of the US Govt to try to bring about change in ITAR.
Alex Harvilchuck, N3NP
Sent via AMSAT-BB@amsat.org. Opinions expressed are those of the author. Not an AMSAT-NA member? Join now to support the amateur satellite program! Subscription settings: http://amsat.org/mailman/listinfo/amsat-bb
Resent from AMSAT address to AMSAT-BB list.. sorry if this is a duplicate posting. Could someone confirm directly if I posted twice? 73 de N3RDX
---------- Forwarded message ---------- From: Samudra Haque Date: Mon, Nov 16, 2009 at 1:50 PM Subject: Re: [amsat-bb] AMSAT, ITAR, More AMSAT-NA Volunteers & Such . . . To: "Alex, N3SQ" amsat@elkmtn.org Cc: amsat-bb@amsat.org
Alex et. al, I would like to add in a comment that according to the latest SBIR release from DoD (many organizations), ITAR compliant persons who are not US Citizens can also be included in DoD funded commercial research projects, as long as they are correctly registered and supervised under the ITAR regulations. This means that if a student from a US university who is NOT a US Citizen, but rather a US LPR green card holder or beneficiary of a protected class of visitor able to be employed, can potentially:
* work as a student intern in a commercial company * work in projects that require ITAR clearance subject to supervision * work alongside with other US Citizens.
This is pretty good opportunity for all in my opinion. I am sure this would be the same case for STTR opportunities as well. Some of these projects can involve aerospace projects, or materials/processes useful for future aerospace projects.
I quote from the SBIR preface at : http://www.acq.osd.mil/osbp/sbir/solicitations/sbir101/index.htm * Export Control.* The International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120 through 130, and the Export Administration Regulations (EAR), 15 CFR Parts 730 through 799, will apply to all projects with military or dual-use applications that develop beyond fundamental research, which is basic and applied research ordinarily published and shared broadly within the scientific community. More information is available at * http://www.pmddtc.state.gov/regulations_laws/itar.html*http://www.pmddtc.state.gov/regulations_laws/itar.html. NOTE: Export control compliance statements found in the individual component proposal instructions are not meant to be all inclusive. They do not remove any liability from the submitter to comply with applicable ITAR or EAR export control restrictions or from informing the Government of any potential export restriction as fundamental research and development efforts proceed.
Sample text from an SBIR:
The technology within this topic is restricted under the International Traffic in Arms Regulation (ITAR), which controls the export and import of defense-related material and services. Offerors must disclose any proposed use of foreign nationals, their country of origin, and what tasks each would accomplish in the statement of work in accordance with section 3.5.b.(7) of the solicitation
I would hope AMSAT-NA would consider teaming with universities to apply for research grants like these.
-samudra N3RDX
On Mon, Nov 16, 2009 at 12:35 PM, Alex, N3SQ amsat@elkmtn.org wrote:
Ladies & Gentlemen,
Here's the main thing to think about ITAR. ITAR regulates OUTFLOW of information, it doesn't care about INFLOW of information. If you build or design it by a non-US Person (Citizen or Legal Permanent Resident) and you bring it INTO the US, ITAR does not care. So AMSAT-NA can use designs from P3E, but cannot design parts of P3E.
So the logical thing to do is have all "major" future AMSAT spacecraft be AMSAT-NA managed spacecraft with design elements (camera systems, experiments, etc.) contributed by other AMSAT organizations. The only main technical interaction between the AMSATs would be via a standard, open-sourced, well-published-in-technical-journals interface specification. Money could be contributed from other AMSATs to fund launch & development costs.
As for the mantra of "no one being able to develop the equipment in the US" . . . The volunteer base is not capped, just expand the size of the volunteer base and organize it better. None of the experienced engineers should be directly building hardware, we should all be supervising teams of engineering students who actually build the equipment. There are over 250 University Engineering programs in the US. Each of those programs have at least 50 students in each graduating class. Let's say that we can get 15% of the students interested in working on a satellite project (my personal observations are more like 75% of the students are interested).
Let's do the Math: Worse Case: 250 Schools x 50 students per graduating class x 15% = 1875 POTENTIALLY INTERESTED STUDENTS IN THE US Best Case: 250 Schools x 50 students per graduating class x 75% = 9375 POTENTIALLY INTERESTED STUDENTS IN THE US And this is just talking about COLLEGE SENIORS - EE's, ME's, CE's, CS's, SE's . . . double the number if you include the Juniors.
Anywhere near this load of students would completely overload the current AMSAT-NA volunteer base. But talk about the potentially available volunteer base!
With Binghamton University, I had 7 Hardware Engineering slots available on the team. There are 200 Hardware Engineers in the BU graduating class
- about 168 of the students wanted to be on the Satellite Project Team,
a 24x over-subscription. That's pretty impressive. I could have had more teams, but we need to crawl, the walk, then run with this activity - EVOLUTIONARY not REVOLUTIONARY (but let's just make sure evolution works quickly . . .)
The current BU student team is "stoked", they are really excited to be working the project. Every week I get thanked by the students for bringing the project to their attention. They have done some really great work and they have a great faculty advisor, Dr. Roger Westgate. I expect that there will be more than 1 project team next year working on an AMSAT satellite, assuming AMSAT is interested in sponsoring more.
So stop crying into your beer over ITAR. The world is not coming to an end. Let's work to launch spacecraft within the ITAR limits. In the meantime, let the AMSAT-NA BoD navigate it's way through the byzantine structure of the US Govt to try to bring about change in ITAR.
Alex Harvilchuck, N3NP
Sent via AMSAT-BB@amsat.org. Opinions expressed are those of the author. Not an AMSAT-NA member? Join now to support the amateur satellite program! Subscription settings: http://amsat.org/mailman/listinfo/amsat-bb
participants (4)
-
Alan P. Biddle -
Alex, N3SQ -
Samudra Haque -
Samudra Haque N3RDX & S21X