Tom,
Thanks for the references. Very interesting material indeed.
Regards...Bill - N6GHz
Tom Clark, K3IO wrote:
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=e57bf8985c5689d7e2340f45...).
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-tourist...
Its 3AM & Bed time -- 73, Tom
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