[amsat-bb] Re: ITAR is interesting to me
ko6th_greg at hotmail.com
Sun Oct 25 14:35:45 PDT 2009
I wonder if we could hook up with a university somewhere? Become part of their graduate program in Astro-something, even get some graduate students to help with the design and manufacture... What sort of restrictions do they have on the definition of a "student"?
Just a thought,
> Date: Sun, 25 Oct 2009 12:14:38 -0700
> From: bill at hsmicrowave.com
> To: tosca005 at tc.umn.edu
> CC: amsat-bb at amsat.org
> Subject: [amsat-bb] Re: ITAR is interesting to me
> Hi John,
> The completed satellite is usually exempt. This is how AO-51, as a
> completed satellite, went to Russia and was launched on a Dnepr. AMSAT
> has in the past and will in the future, apply for an export license for
> a satellite. It's when you try to export satellite components or
> technology, like the IHU, the SDX for the P3E, or engage in dialog
> regarding a satellites thermal performance the the AMSAT-DL folks to
> assist them, that you run afoul of ITAR.
> There's a big different between sharing technology and components than
> it is to export a complete satellite for launch. Often the State Dept.
> will require that a representative(s) of the satellite builders (and
> sometimes the State Dept. itself) accompany the satellite at all times,
> insuring that no one can get a closer look than just the outside, right
> through the launch.
> Yes, a bit confusing and frustrating, but workable.
> Regards...Bill - N6GHz
> John P. Toscano wrote:
> > Bob McGwier wrote:
> >> 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.
> > Bob:
> > I would not dream of second-guessing you for a moment, since you are
> > fully engaged in this stuff and I am simply an interested observer.
> > However, why doesn't the following quotation directly from the ITAR
> > regulations provide the exemption we need? The quotation comes from the
> > section that defines what are the items that are covered by ITAR:
> > ITAR Part 121 - The United States Munitions List
> > -----------------------< begin quote >-------------------------------
> > Category XV - Spacecraft Systems and Associated Equipment
> > *(a) Spacecraft, including communications satellites, remote sensing
> > satellites, scientific satellites, research satellites, navigation
> > satellites, experimental and multi-mission satellites.
> > *NOTE TO PARAGRAPH (a): Commercial communications satellites, scientific
> > satellites, research satellites, and experimental satellites are
> > designated as SME only when the equipment is intended for use by the
> > armed forces of any foreign country.
> > -----------------------< end quote >---------------------------------
> > Note that SME refers to "Significant Military Equipment"
> > Paragraph (a) seems to cover everything and anything having to do with
> > satellites, but the asterisk and "NOTE" attached to it seems to say that
> > an Amateur radio satellite for use by Amateurs instead of foreign armed
> > forces should be exempted, doesn't it?
> > Granted, I realize that we have already lost one argument with ITAR
> > about our past cooperation with AMSAT-DL, but is there some compelling
> > reason why the lawyers didn't point out this exception?
> > Just wondering...
> > If I had to guess the answer myself, after looking at the horribly
> > convoluted language of the small piece of the ITAR regulations that I
> > have looked at, there is probably another paragraph elsewhere that
> > effectively says, "we were just kidding when we said that it had to be
> > used by foreign armed forces, we really mean it to cover everything"
> > John
> > W0JT
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