Hi Tom,
Thanks for weighing in on this sticky issue.
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.
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.
I jest somewhat, but perhaps there are some other legitimate directions we can follow and that is why I think all this dialog is useful.
I have just sent off an email to one of my CalPoly contacts involved with the CubeSat program asking him about ITAR. I'll report on what I get back.
Regards...Bill - N6GHz
Tom Clark, K3IO wrote:
Bill Ress wrote:
Hi Lou,
Perhaps you can talk Frank into making AMSAT an official educational/research division of NASA. Would affiliate status work?
Whoa - could something along those lines happen?? Hey, I'm for trying anything that might work. Come to think of it, I'm really not clear how the university CubeSats are treated by ITAR. I don't recall any of the participants complaining about ITAR. Someone got the answer??
If you look at the ITAR regs, commercial satellites can be exported, under the rules Chuck stated. Since AO-51 was
* built at SpaceQuest with (mostly) components supplied by SpaceQuest, * under contract between AMSAT and SpaceQuest, and * since Chuck stayed behind in Kazakhstan after the rest of the AMSAT/SpaceQuest folks came home just to meet the ITAR rules and * since SpaceQuest (specifically Dino Lorinzini) had already met all the ITAR commercial rules (just as they had done for the Saudi microsats) ,we elected to have SpaceQuest handle the all details export to Moscow and thence Kazakhstan.
Most of the CubeSats have been flown by bona fide educational organizations and/or under support of NASA, NSF, DoE and other gov't agencies. Educational organizations have negotiated away most of the onerous rules. Personally, I have advocated getting a disposition that AMSAT, as a 501c(3) scientific/education organization, is an educational entity.
It is interesting to note, as an aside, AFAIK a decade ago, the Republican congress wrote the tough ITAR export rules after Loral (previously known as Philco/Ford) told the Chinese why they were having control system problems on their LongMarch rocket. At the time Loral was a major Silicon Valley contributor to the Clintons. Guess what US firm is the probable source for a Geostationary ride is?
73, Tom
Via the Eagle mailing list courtesy of AMSAT-NA Eagle@amsat.org http://amsat.org/mailman/listinfo/eagle
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