[eagle] Re: ITAR BS

Bill Ress bill at hsmicrowave.com
Tue Sep 9 22:50:56 PDT 2008

Hi Tom,

Thanks for weighing in on this sticky issue.

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.

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.

I jest somewhat, but perhaps there are some other legitimate directions 
we can follow and that is why I think all this dialog is useful.

I have just sent off an email to one of my CalPoly contacts involved 
with the CubeSat program asking him about ITAR. I'll report on what I 
get back.

Regards...Bill - N6GHz

Tom Clark, K3IO wrote:
> Bill Ress wrote:
>> Hi Lou,
>> Perhaps you can talk Frank into making AMSAT an official 
>> educational/research division of NASA. Would affiliate status work?
>> Whoa - could something along those lines happen?? Hey, I'm for trying 
>> anything that might work. Come to think of it, I'm really not clear how 
>> the university CubeSats are treated by ITAR. I don't recall any of the 
>> participants complaining about ITAR. Someone got the answer??
> If you look at the ITAR regs, commercial satellites can be exported, 
> under the rules Chuck stated. Since AO-51 was
>     * built at SpaceQuest with (mostly) components supplied by
>       SpaceQuest,
>     * under contract between AMSAT and SpaceQuest, and
>     * since Chuck stayed behind in Kazakhstan after the rest of the
>       AMSAT/SpaceQuest folks came home just to meet the ITAR rules and
>     * since SpaceQuest (specifically Dino Lorinzini) had already met
>       all the ITAR commercial rules (just as they had done for the
>       Saudi microsats) , 
> we elected to have SpaceQuest handle  the all details export to Moscow 
> and thence Kazakhstan.
> Most of the CubeSats have been flown by bona fide educational 
> organizations and/or under support of NASA, NSF, DoE and other gov't 
> agencies. Educational organizations have  negotiated away most of the 
> onerous rules. Personally, I have advocated getting a disposition that 
> AMSAT, as a 501c(3) scientific/education organization, is an  
> educational entity.
> It is interesting to note, as an aside, AFAIK a decade ago, the 
> Republican congress wrote the tough ITAR export rules after Loral 
> (previously known as Philco/Ford) told the Chinese why they were 
> having control system problems on their LongMarch rocket. At the time 
> Loral was a major Silicon Valley contributor to the Clintons. Guess 
> what US firm is the probable source for a Geostationary ride is?
> 73, Tom
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