[eagle] Re: Some more ITAR background

Bill Ress bill at hsmicrowave.com
Wed Sep 10 09:36:26 PDT 2008


Tom,

Thanks for the references. Very interesting material indeed.

Regards...Bill - N6GHz

Tom Clark, K3IO wrote:
> I retitled the thread because this topic is NOT BS! It is real.
> Bill -- you asked for more documentation:
>> 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.
> The fact that we "bought" AO-51 (from AMSAT members @ SpaceQuest) 
> impacted the ITAR situation. The Amateur Satellite Service status is 
> defined by ITU & FCC and has nothing to do with the manner of 
> acquisition/fabrication. If I follow your logic, then all the 
> YaeComWood radios are not amateur. We might want to talk with Dino 
> (KC4YMG) about how SpaceQuest (BTW, they has been involved in a LOT of 
> amateur satellites, see 
> http://spacequest.com/success_stories.php?PHPSESSID=e57bf8985c5689d7e2340f450c7b19fa).
>> 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.
> The Federal Register describing the March, 2002 "ITAR Exemptions for 
> US Institutions of Higher Learning" can be found at 
> http://www.fas.org/sgp/news/2002/03/fr032902.html. See also 
> http://www.fas.org/sgp/crs/RL31695.pdf & 
> http://fas.org/sgp/crs/RL31845.pdf
> The problem is, as I understand it, the 2002 rule got universities out 
> of their black hole. Commercial entities has well defines procedures. 
> But /ad hoc/ volunteers working on activities for a non-profit 
> organization seem to fall thru the cracks. This idea has been 
> discussed with some high ups (lawyers, DoS retirees, etc) but so far,. 
> /when all is said and done, much more has been said than done! /
>
> For some other info on ITAR, I recommend everyone look at: 
> http://en.wikipedia.org/wiki/International_Traffic_in_Arms_Regulations 
> where you will see a lot of references and the words that IMHO 
> summarize our problem: /*"Currently, officials at the Department of 
> State dismiss the burden on industry and educational institutions as 
> minor compared to the contributions to national security provided by 
> ITAR. They also view the announcements of "ITAR-free" items as 
> anecdotal and not systemic"
>
> */ For more info on the Loral/LongMarch story, this makes interesting 
> reading: http://www.thespacereview.com/article/528/1
>
> For an interesting mp3 interview about the ITAR mess, where David 
> Livingstone first said /*"ITAR is Three Types of Stupid"*/: 
> http://archived.thespaceshow.com/shows/457-BWB-2006-02-12.mp3
>
> Are the commercial visitors to the ISS exports? 
> http://rescommunis.wordpress.com/2007/11/01/deemed-exports-and-space-tourists/
>
> Its 3AM & Bed time -- 73, Tom
>
>
>
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