[amsat-bb] Fwd: AMSAT, ITAR, More AMSAT-NA Volunteers & Such . . .

Samudra Haque N3RDX & S21X n3rdx at amsat.org
Mon Nov 16 19:07:00 PST 2009

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 at elkmtn.org>
Cc: amsat-bb at 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 :
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 *
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

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 at 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
> Best Case: 250 Schools x 50 students per graduating class x 75% =  9375
> 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
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