AMSAT files CJ requests with US State Department
The Radio Amateur Satellite Corporation filed four
Commodity Jurisdiction (CJ) requests with the Directorate
of Defense Trade Controls, US State Department last week.
These requests ask that the four commodity groups that
AMSAT provided support for AMSAT-DL's Phase 3-E project
(SDX, IHU-3, Can-Do! Bus, and thermal design) be transferred to the Department of Commerce and be regulated
under the Export Administration Regulations (EAR),
removing them from ITAR (International Traffic in Arms
Regulations) managed by the State Department's DDTC.
"Our CJ requests are based upon AMSAT's status as a not-
for-profit corporation that adheres to 'open source' and
'public domain' principles where all of our technical activities
are freely available through the Internet and publications, such
as the "AMSAT Journal", observed AMSAT President Barry Baines,
WD4ASW.
"Given the open nature of our activities, the focus
on scientific and educational purposes of our satellites,
and lack of military applications, we believe that our activities
in these areas are better suited for EAR rather than ITAR",
said Barry.
The CJ requests will be reviewed by the Directorate of Defense
Trade Controls as well as other federal agencies such as the
Commerce Department and Department of Defense. AMSAT expects
this review to take several months before a decision is made by
DDTC whether to grant the request.
AMSAT's involvement with P3-E halted in 2006 due to concerns over
possible ITAR violations. In January 2009, AMSAT filed a 'Voluntary
Disclosure' with DDTC outlining AMSAT's activities with AMSAT-DL
and AMSAT-UK on P3-E.
In March 2009, DDTC advised AMSAT that ITAR
violations did occur but that the case was being closed. AMSAT
was admonished not to violate ITAR in the future. Subsequent to
receiving DDTC's letter closing the case, AMSAT is now seeking a
means to re-establish technical exchanges in support of P3-E
while abiding under rules administered by the Commerce Department.
Further details on AMSAT's efforts to comply with ITAR while
developing ways which will allow AMSAT satellite builders to
work cooperatively with foreign nationals on amateur radio satellite
projects will be available in the next issue of the "AMSAT Journal."
Barry, WD4ASW
Amsat website
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