[amsat-bb] ITAR Fun

Bryce Salmi bstguitarist at gmail.com
Mon Jan 27 00:47:10 PST 2014

In light of the bi-monthly HEO discussions that pop up here I figured I'd
share some info that many non-US aerospace industry people may not realize.
The International Traffic in Arms Regulations (ITAR) is a set of laws that
those of us in the United States must adhere to, even as volunteers for
AMSAT. I just finished up yet another refresher course from my employer so
this is fresh on the mind.

This email is my own and I don't claim to be 100% to the book accurate,
this is my understanding of it.

Some notes on what it means:

   - *Negligence is NOT a waiver for a violation*
      - just because you didn't realize you violated it, doesn't mean you
      won't/can't be prosecuted
   - *Simply inquiring about ITAR related subjects can be a violation*
      - If I called a company in Germany about their product I'd like to
      use on Fox-1 but need a small modification to the design and suggest the
      modification to their product so it works with my design... I could have
      violated ITAR.

*Individual Criminal Violation*

   - Up to $1,000,000 fine *per violation*, 10 years in prison, or both.

*Individual Civil Violation*

   - Up to $500,000 fine *per violation*

Those are the big hitters so-to-speak. They are also some of the main
reasons we cannot team up with other AMSAT groups to work on projects
together. Plain and simple. Heck, if I was conversing with some of the
Funcube volunteers and helped them with one of their designs via email,
even simple schematic review to help them I could be violating ITAR. So
those of us here volunteering for Fox-1 do our best to operate with these
rules in place and watch the other groups do their own thing.

*Non- ITAR....Launches*

I work in the launch industry and have quickly realized that the commercial
rocket industry is filled with companies who's satellites cost upwards of
$0.5 to $1 billion each.* To them, a $100 million launch is pocket money as
long as its reliability is high*. Until we see reusable rockets this will
be the playing field in which every AMSAT group in the world has to abide
by. Therefore, cubesats are the ticket into orbit*. On the notion of demo
launches for new rockets such as ones obtained my AMSAT for AO-40... Launch
integrators no longer have trouble finding payloads for them*. There are
more than enough university small sats and cubesats willing to dish out
$100,000+ if not a few million for a ride. Why would an integrator pass up
the opportunity to reclaim a few million $ on the test launch with people
throwing money at them?!

Again all thoughts are my own and would like to state that just because
some people express opinions on this list doesn't mean they are the
opinions/direction of AMSAT. Several posts on here lately have generalized
one or two peoples responses as the direction of AMSAT-NA which is very
much not the case.

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