Tag: ITAR

A Closer Look at the UK’s Commercial Space Review

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Earth_from_space_graphic
Following the release of the document, “UK Government Review of Commercial Spaceplane Certification and Operations: Summary and Conclusions,” almost all media attention focused on one element of the report: the 8 candidate sites for the nation’s first spaceport.

This laser focus is easy to understand. The fierce, tooth-and-nail competition to land some big government project will be fun to watch. And spaceports are super cool. Well, they are when space planes are actually flying to space. When like a decade goes by with people promising imminent spaceflights without a single one taking place, spaceports become a lot less cool.  (I’m looking at you…everybody in Mojave!)

But, I digress. I went through the 80-page document and the 321-page technical report its based on so you don’t have to. Why would I do this? Because you guys are the best! You’re very welcome.

Key excerpts follow with commentary as appropriate. Read away!

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Commercial Spaceflight Federation Opposes Putting Commercial Space Vehicles on USML

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csf_logo_newestWASHINGTON (NASA PR) — The Commercial Spaceflight Federation submitted the following comments to the State Department regarding the interim Category XV rule of the International Traffic in Arms Regulations (ITAR).

June 27, 2014

Via E-Mail (DDTCResponseTeam@state.gov)

Directorate of Defense Trade Controls
Office of Defense Trade Controls Policy
U.S. Department of State
PM/DDTC, SA-1, 12th Floor
Washington, DC 20522-0112

ATTN: Regulatory Change, USML Category XV
RIN: 1400–AD33

The Commercial Spaceflight Federation (CSF) is an industry association comprised of leading businesses and organizations working to make commercial spaceflight a reality. Our mission is to promote the development of commercial spaceflight, pursue ever higher levels of safety, and share best practices and expertise throughout the industry. The CSF commends the Administration for its efforts on export control reform, especially in relation to Category XV, which will reinforce the competiveness of the U.S. satellite industry in the global market. The modernization of Category XV will help bolster the growth of the domestic commercial space sector while enhancing national security by allowing the government to focus its scarce resources on sensitive military technologies.

While we applaud the progress that has been made, there is still more work to be done. As commercial space companies continue to test and develop their vehicles, it is vital to have an export control regime that will not illegitimately inhibit the potential of this growing industry. Steps should be taken to further investigate how to modernize the USML to appropriately move these vehicles to the Commerce Control List (CCL). Again, the CSF commends the State Department on its export control reform efforts to date as well as its outreach to industry, and we hope to continue to work together to determine the appropriate controls for commercial spacecraft.

Although the State Department did not request comment on this matter in its May 13, 2014 rule, the CSF will submit further detailed comments to the State Department along with our submission to the Department of Commerce in response to their request for comments on the continued application of USML controls to commercial space launch vehicles and human spaceflight.

Sincerely,

Michael Lopez-Alegria
President

AIA Supports Lifting of Export Restrictions on U.S. Space Systems

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aialogosmTogether with Ex-Im Reauthorization later this year, the Interim Final Rule will open the door to increased international space-related sales.

Statement by Aerospace Industries Association President and CEO Marion C. Blakey 

Arlington, Va. — The Aerospace Industries Association applauds the Administration’s issuance of revisions to Category XV of the U.S. Munitions List (USML) that will end excessive restrictions on space systems like commercial satellites and related articles.  After a six month delayed implementation, the interim final rule will remove many of these less sensitive technologies from the USML and place them under the more appropriate controls of the Commerce Control List.

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New Export Rules Will Be Looser, More Complicated

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Capitol Building
The good news is that the U.S. government is about to loosen the restrictive export rules governing satellites and components that have been blamed for destroying America’s dominance in the satellite market over the past 15 years.

The bad news is that the rules are about to get a lot more complicated to interpret. And, for those who fail to interpret them properly, a jail cell could be in their future.

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Virgin Galactic’s Ban on Selling Tickets to Chinese Citizens

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SpaceShipTwo ignites its engines on the third powered flight. (Credit: Virgin Galactic)

SpaceShipTwo ignites its engine above Koehn Lake on its third powered flight. (Credit: Virgin Galactic)

It was a great story while it lasted, one full of spies, technological espionage, Cold War-style fears, and super power rivalry. And then the story turned into something far stranger.

The news broke two weeks ago that Virgin Galactic is turning away would-be space tourists from China. The reason: strict U.S. export restrictions known as ITAR that are designed to prevent the transfer of sensitive technologies to hostile foreign nations. Visions of Chinese spies signing up for flights and stealing the secrets to this new technology filled numerous news stories in the week that followed.

There was only one problem: the story appears to be only half true.

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Stu Witt’s Prepared Remarks to Congress on Commercial Space

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Stu_wittPrepared Statement of Stuart O. Witt
CEO and General Manager
Mojave Air and Space Port
Hearing on “Commercial Space”
Wednesday, November 20, 2013
Subcommittee on Space Committee on Science, Space, and Technology
U.S. House of Representatives

Chairman Palazzo, Ranking Member Edwards, Chairman Smith, and members of the subcommittee, thank you for giving me the opportunity to address the subcommittee this morning. My name is Stuart Witt, and I am the CEO and General Manager of the Mojave Air and Space Port, which is located in southeast Kern County, California.

Many of my tenants call Mojave the Silicon Valley of Commercial Spaceflight. I’m just proud to lead the nation’s only private experimental flight test center, a place where Innovation Takes Flight.

Our topic today is America’s commercial space industry, and my message to you from the high desert is that American engineers and entrepreneurs in Mojave and other places across the country are successfully revolutionizing America’s future in space. This is a 100% good news story. What my Mojave tenants require from elected representatives in Washington is continued permission, and modest encouragement, rather than obstacles.

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Witt to Congress: Extend Learning Period, Revise ITAR and Make Indemnification Permanent

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Mojave Air and Space Port CEO Stu Witt (Credit: Bill Deaver)

Mojave Air and Space Port CEO Stu Witt (Credit: Bill Deaver)

In testimony before the House Subcommittee on Space on Wednesday, Mojave Air and Space Port CEO Stu Witt urged legislators to extend the “learning period” for new space systems to eight years, remove suborbital tourism vehicles from the ITAR list, and to make permanent the risk-sharing launch indemnification in which the government covers damages from private space missions above a certain level.

“This industry needs regulatory certainty,” Witt said in his prepared remarks. “But the learning period restriction on unsubstantiated safety regulations expires in less than two years and the risk-sharing (indemnification) regime expires at the end of next month. That regulatory uncertainty is difficult for many companies. I ask Congress to make Indemnification permanent, and also extend the Learning Period to a full eight years of R&D and operational flights to provide regulatory certainty to firms developing passenger carrying vehicles.”

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ISPCS Panel Discussion on IP, Export Controls and Insurance

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ispcs_logoHot Topics:
Intellectual Property, Export Controls & Insurance

Chair: Franceska Schroeder, Principal, Fish & Richardson, P.C., Washington, DC Office

Speakers:

  • Grant Anderson, Senior Vice President and Chief Engineer, Paragon Space Development Corporation
  • James W. Babineau, Principal, Fish & Richardson P.C., Austin Office – Intellectual Property
  • Christopher T.W. Kunstadter, Senior Vice President Aerospace Insurance, XL Group

Tweets

Now on the stage: panel discussion on export control and intellectual property protection related to the commercial space industry. (ISPCS ‏@ISPCS)

Now up at #ISPCS, additional duscussion on risks and insurance. Moderator @FOSchroeder (Alan Ladwig ‏@SpaceArtAl)

Chris Kunstadter, XL Insurance on “Hot Topics” panel: lot of capital in space insurance market right now, pushing down rates. (Jeff Foust ‏@jeff_foust)

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AIA Praises Export Reform Measure, Calls for End to Shutdown

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aialogosmARLINGTON, Virg. (AIA PR) – Aerospace Industries Association President and CEO Marion C. Blakey calls on Congress and the administration to end the shutdown and allow exporters to take advantage of export control reforms in support of U.S. national security and economic prosperity as soon as possible.

The Aerospace Industries Association (AIA) welcomes today’s enactment of the first set of revisions to the U.S. Munitions List (USML) that are removing onerous controls on exports of essentially commercial technology used in military aircraft (Category VIII) and military aircraft engines (Category XIX).  Subjecting these technologies to the export control requirements of the Commerce Control List (CCL) will allow for more appropriate reviews and restrictions while making trade with America’s closest military allies and partners more predictable, efficient and transparent.

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Video: XCOR’s Andrew Nelson on Restrictive Export Rules

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Wall Street Journal Opinion: Will Bureaucrats Ground Private Space Before It Launches?

XCOR Aerospace COO Andrew Nelson on the threat potential suborbital space regulations pose to America’s burgeoning space industry.

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