On May 24, 2013 the Department of State’s Directorate of Defense Trade Controls (DDTC) released proposed changes to the US Munitions List (USML) Category XV (“Spacecraft Systems and Related Articles”), redefining what constitutes satellites that would remain under the USML. Satellites removed from USML will be transferred to the Department of Commerce’s Commerce Control List (CCL). Consequently, the Department of Commerce’s Bureau of Industry and Security (BIS) also released proposed changes on May 24, 2013 regarding modifications to the Commerce Control List, creating a separate category for satellites that were formerly controlled under ITAR (International Traffic in Arms Regulations).
AMSAT President Barry Baines, WD4ASW and AMSAT Congressional Liaison Peter Portanova, WB2OQQ took on the task of drafting comments in response to the combined 105 pages of “bureaucratize” drafted by the DDTC and the BIS. Former AMSAT President Bill Tynan, W3XO crafted initial comments that provided a starting point. Peter, using various points of contact in Washington to help gauge how AMSAT might submit remarks, made recommendations on the crafting of AMSAT’s response. Barry then wrote two different drafts, one addressed to the DDTC in response to the USML changes, requesting confirmation that Amateur Satellite Service spacecraft and associated equipment will be removed from the USML. The other document is addressed to the BIS in response to the proposed changes to the CCL, suggesting that Amateur Satellite Service spacecraft and associated equipment be separately categorized and controlled given the significant differences between Commercial and Amateur Satellite Service spacecraft. Both drafts were initially reviewed by the AMSAT Board of Directors with the final versions submitted on 6 JUL 13. Here are AMSAT’s submissions:
In addition, AMSAT’s submission to BIS (along with the comments of others) may be viewed at:
AMSAT’s submission to the DDTC along with other interested parties may be found here:
Note that this PDF contains “all” comments received; AMSAT’s comments start on page 138.
Both DDTC and BIS will now review the comments received and presumably make modifications to the original proposals. It will likely take several months before both agencies respond to the
comments that they’ve received.
[ANS thanks Barry WD4ASW for the above information]