[amsat-bb] Re: Understanding ITAR

Bill Ress bill at hsmicrowave.com
Sat Oct 3 15:03:35 PDT 2009

Hi Wayne,

The State Department defines what is considered a "munition" in the ITAR 
regulations. See: http://pmddtc.state.gov/

The criteria is obviously determined by the State Department with 
direction from the Congress. The article just tries to describe some 
examples without trying to justify or explain why something is or isn't 
a munition.

The main point of the article is that any communications satellite, 
whether it is an Amateur, a university or a commercial satellite is 
considered by ITAR to be a munition controlled by ITAR export 
regulations. That's a fact and to understand the criteria is to 
understand the thinking of the authors of the regulation (State 
Department and the Congress), which I can't do.

To be sure, export regulations can be complicated and at times appear to 
us as being irrational. But the fact remains, ITAR is an export law that 
we at AMSAT have to comply with.

Regards...Bil - N6GHz

Wayne Estes wrote:
> I just read the article about ITAR in the Jan/Feb 2009 AMSAT Journal.  I 
> have to say that the article didn't help me understand ITAR at all.  It 
> seems to have skipped the first several steps in the explanation.
> For example, what criteria are used to judge that a device has dual use 
> as a munition?  It is not at all obvious to my feeble mind how a 23 GHz 
> amplifier or IHU-3 (computer) can be judged to have dual use as a munition.
> What criteria does ITAR law use to EXCLUDE devices that have obvious 
> dual uses as munitions?  For example, GSM cell phones have been used to 
> remotely control explosive devices that killed thousands of U.S. 
> servicemen.  Are they not regulated because they are too ubiquitous to 
> control?
> Wayne Estes W9AE
> Oakland, Oregon, USA, CN83ik
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