[amsat-bb] Re: ITAR is interesting to me

Bob McGwier rwmcgwier at gmail.com
Sun Oct 18 15:18:52 PDT 2009

k0vty at juno.com wrote:
> Greetings All:
> The Amsat BB is a great source of information we all know:
> I have a few questions about ITAR that I thought might interest more than
> I.
> I tried to be careful of the words I used.
> 1.) Do all launched satellites that have US components or interests fall
> under ITAR? 
> 2.) When does ITAR interest begin for a launchable Amateur satellite?
The minute you wish to discuss what is in it with someone who is not a 
US national or want to ship the thing overseas for launch.
> 3.) Is software and firmware that is a part of a Amateur satellite at
> launch fall under ITAR?
Most definitely
> 4.) Who normally handles University Cube Sat ITAR issues when Amateur
> frequencies are used?
Depends on who is going to do the launch but Cal Poly has been involved 
for sure.
> 5.) Who normally handles US Military school Cube-Sat ITAR issues when
> Amateur frequencies are use ?
U.S. government entities have a form of an exemption because they are a 
component of the U.S. government (and not a for profit company which 
might be tempted to sell intellectual property to the highest bidder) 
and those equities are handled differently.  Even then, ITAR only comes 
into play if non-U.S. citizens are involved in the program and/or an 
overseas launch is envisioned.
> 6.) When is there no ITAR interest in a Amateur satellite? 
There is interest.  That is what is causing us so much grief.  It has 
effectively ended the participation of AMSAT-NA in Phase 3E.
> 7.) Did Suitsat one or two (ARISSaT-1) have any ITAR problems since they
> are satellites
>       using Amateur frequency?
NASA is able to work through different channels than AMSAT has to in 
order to get things launched to the space station.  AMSAT-NA will be 
responsible for ALL transfer of components for ARISSat 1 to the launch 
site.  We might get assistance from some places in the government but it 
will be handled as an export request and we  will have to show how we 
will protect the equities that need protecting under ITAR.
> I have more ITAR related questions.
> Best Regards
> Joe  K0VTY
> ==================== 

ANY aspect dealing with a satellite, software, hardware, ground stations 
(hardware, software, protocols, etc.), ideas, random ejaculations from a 
diseased mind or whatever that deals with spacecraft or ground stations 
are DEEMED EXPORTS when they depart a U.S. citizen and are delivered to 
a non-U.S. citizen.  It is a nearly impossible task to abide by and one 
that really makes me want to throw my hands up in despair and walk away.

There are exceptions for classrooms and courses taught in U.S. 
university's.  A person, even a non-U.S. citizen, who can pay for taking 
a course, may go and involve themselves in course work, even if it is 
dealing with the design, construction, and control of spacecraft during 
the course work.  Some of this applies to your earlier questions but for 
US service academies,  there are very few non-U.S. citizens in them.


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