AMSAT has asked the federal government to confirm that the Amateur Satellite Service will not be subject to International Traffic in Arms Regulations (ITAR), as a result of export control reforms now underway. In May the US Department of State Directorate of Defense Trade Controls (DDTC) proposed changes to the US Munitions List (USML) Category XV (Spacecraft Systems and Related Articles). The changes redefine satellites that would remain under the USML. Satellites removed from USML would be transferred to the Department of Commerce Commerce Control List (CCL).

“We ask that the Directorate of Defense Trade Controls explicitly confirm that satellites, ground equipment, and associated technical data for items pertaining to the Amateur Satellite Service are not subject to the ITAR when the new Category XV provisions are implemented,” AMSAT said in comments filed earlier this month “Over the past 43+ years AMSAT has been integral to the development of Amateur Radio communications spacecraft based upon the model of an all-volunteer organization that follows ‘open source’ practices and creates spacecraft that are very low cost, which also reflects relatively low levels of sophistication compared to commercial satellites,” AMSAT said.

A related set of AMSAT comments went to the Department of Commerce Bureau of Industry and Security (BIS), which has proposed creating a separate CCL category for satellites formerly under ITAR. AMSAT asked that Amateur Satellite Service spacecraft and associated equipment be separately categorized and controlled, given the significant differences between commercial and Amateur Satellite Service spacecraft.

“We ask that the Department of Commerce recognize the relative impacts of regulatory oversight on small, not-for-profit scientific and education organizations such as AMSAT and to find ways to mitigate these impacts on both AMSAT and our volunteers,” AMSAT said. AMSAT suggested creating a separate category for Amateur Satellite Service; allow a license exception for “deemed exports” for Amateur Radio satellite design and construction, to permit a “free exchange of ideas, software, etc pertaining to Amateur Radio satellite design and construction when interacting with foreign nationals who are citizens of nations listed in the License Exception Strategic Trade Authorization Country List, and focus export licensing requirements only on the export of hardware.

AMSAT President Barry Baines, WD4ASW, and AMSAT Congressional Liaison Peter Portanova, WB2OQQ, took on the task of drafting comments in response to a combined 105 pages of bureaucratese drafted by the DDTC and the BIS. Former AMSAT President Bill Tynan, W3XO crafted initial comments as a starting point.