Commercial Space Competitiveness Strategy for the 21st Century Aerospace Industries Association
The United States was the leader in space for much of the early Space Age after initial Soviet successes. From the development of the Saturn V rocket and the Apollo Lunar landing program, to development of the first communications satellites and the Global Positioning System, the U.S. has been the primary driver of both the exploration and commercial utilization of space.
Russian President Vladimir Putin has signed a law to consolidate the nation’s space industry under the control of a revamped Roscosmos as officials eye export sales to China as a way to offset budget cuts in the nation’s space program.
The law will combine the United Rocket and Space Corporation with Roscosmos, which will become a state corporation. The new company will be led by former auto industry executive Igor Komarov.
Space Access Update #142 6/24/15 copyright 2015 by Space Access Society __________________________________________
Contents This Issue:
Commercial Crew Funding – Deeper Background? – Opposition Overreach
Major Problem With Proposed New ITAR Rules
Commercial Crew Funding
– Deeper Background RSN
Since this latest Commercial Crew funding fight started a few weeks back, we’ve been skimping on context. Those of you less than totally immersed in all this might not have ended up with a completely clear picture of what we think is really going on, or why we think it matters so much. We’ve been rushed. Our apologies.
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!
WASHINGTON (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.
Together 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.
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.
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.
Prepared 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.
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.”
ARLINGTON, 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.
Rockledge, Fla., June 14, 2013 (FSDC PR) — The Florida Space Development Council (FSDC), a chapter of the National Space Society, has written to the U.S. Department of State to voice opposition to proposed export-control rulemaking that would add commercial human spaceflight vehicles to a Department of Defense “munitions list” and thereby place onerous restrictions on their export from the U.S.
By Andrew Nelson Chief Operating Officer, XCOR Aerospace
Just a quick note while I have a moment to stop and reflect in the thick of NSRC 2013. Specifically, I want to address some new rules being proposed by the US State Department on export controls for manned suborbital space vehicles designed for commercial spaceflight.
At the end of May, the Department of State published a Notice of Proposed Rulemaking (or NPRM) Rule 78 FR 31 444 (pdf)– that did a great thing. The DoS proposed a move of commercial satellites from the US Department of Defense (DoD) Munitions List to the Department of Commerce’s commerce control list (CCL). This is a great step for the industry. Since the time commercial satellites were placed on the munitions list in 1999, the commercial satellite industry was almost wiped out.