I retitled the thread because this topic is NOT BS! It is real.
Bill -- you asked for more documentation:
You
mentioned SpaceQuest exporting AO-51 as a commercial satellite. Now
that confuses me since an Amateur satellite by FCC rules cannot be
"commercial". So somewhere there's a definition disconnect. I'd be
happy to define our satellites as "commercial" and then follow whatever
Space Quest did. But can we do that? I have a copy of the paper they
wrote here somewhere describing all they went through as a sorta
guideline.
The fact that we "bought" AO-51 (from AMSAT members @ SpaceQuest)
impacted the ITAR situation. The Amateur Satellite Service status is
defined by ITU & FCC and has nothing to do with the manner of
acquisition/fabrication. If I follow your logic, then all the
YaeComWood radios are not amateur. We might want to talk with Dino
(KC4YMG) about how SpaceQuest (BTW, they has been involved in a LOT of
amateur satellites, see http://spacequest.com/success_stories.php?PHPSESSID=e57bf8985c5689d7e2340f450c7b19fa).
Educational organizations - I'd have to go back
through ITAR again but I didn't recall seeing a ITAR exemption for
"educational" entities. IF there is, I would think, like you, that
AMSAT should be considered a bona fide educational institution. If
degrees can be obtained on the internet, surely we can offer courses in
satellite design, building and operation. I bet you could whip up a
curriculum.
The Federal Register describing the March, 2002 "ITAR Exemptions for US
Institutions of Higher Learning" can be found at http://www.fas.org/sgp/news/2002/03/fr032902.html.
See also http://www.fas.org/sgp/crs/RL31695.pdf
& http://fas.org/sgp/crs/RL31845.pdf
The problem is, as I understand it, the 2002 rule got universities out
of their black hole. Commercial entities has well defines procedures.
But ad hoc volunteers working on activities for a non-profit
organization seem to fall thru the cracks. This idea has been discussed
with some high ups (lawyers, DoS retirees, etc) but so far,. when
all is said and done, much more has been said than done!
For some other info on ITAR, I recommend everyone look at: http://en.wikipedia.org/wiki/International_Traffic_in_Arms_Regulations
where you will see a lot of references and the words that IMHO
summarize our problem: "Currently, officials at the
Department of State dismiss the burden on industry and educational
institutions as minor compared to the contributions to national
security provided by ITAR. They also view the announcements of
"ITAR-free" items as anecdotal and not systemic"
For
more info on the Loral/LongMarch story, this makes interesting reading:
http://www.thespacereview.com/article/528/1
For an interesting mp3 interview about the ITAR mess, where David
Livingstone first said "ITAR
is Three Types of Stupid": http://archived.thespaceshow.com/shows/457-BWB-2006-02-12.mp3
Are the commercial visitors to the ISS exports? http://rescommunis.wordpress.com/2007/11/01/deemed-exports-and-space-tourists/
Its 3AM & Bed time -- 73, Tom