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CSF continues to press for human spaceflight export rule changes

The mid-May publication of the “draft final” export control rule for satellites and related components largely brought the saga of export control reform to an end, with the exception of a few loose ends, such as aperture limits for remote sensing systems. The administration’s decision was a major, but not complete, victory for the space industry. One area where they sought but did not win change was in human spaceflight: crewed vehicles, both suborbital and orbital, will remain on the US Munitions List (USML) and thus under the jurisdiction of the International Traffic in Arms Regulations (ITAR).

“Spacecraft specially designed for human space flight that have integrated propulsion present another security concern, for such capabilities may be used for the purposes of weapons targeting from space,” the State Department noted in its final ruling. “So, although these technologies and capabilities are used in commercial endeavors, they continue to merit control on the USML.”

While the State Department appears to have no immediate plans to revisit this decision, the organization representing many developers of such spacecraft is keeping the agency aware of the issue. “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,” wrote the Commercial Spaceflight Federation (CSF) in a June 27 letter, signed by CSF president Michael Lopez-Alegria, to the Directorate of Defense Trade Controls in the State Department. “Steps should be taken to further investigate how to modernize the USML to appropriately move these vehicles to the Commerce Control List (CCL).”

The CSF notes in the letter that the State Department had not formally requested comment on its decision to retain human spaceflight vehicles on the USML, it says it plans to “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.”

The letter comes during a time of transition for the CSF. As Space News reported last week, executive director Alex Saltman stepped down last week, a move planned long ago as he is heading to California with his family; he will stay on with the CSF in the role of senior advisor. Lopez-Alegria is also planning to leave the CSF by the end of the year.

9 comments to CSF continues to press for human spaceflight export rule changes

  • Hiram

    Some curious language buried in this rule. In the section defining “Spacecraft and Related Articles” that need to be on the munitions list, we find

    “Spacecraft, including satellites and space vehicles, whether designated developmental, experimental, research, or scientific, or having a commercial, civil, or military end-use, that: … 4) Are specially designed to be used in a constellation or formation that when operated together, in essence or effect, form a virtual satellite (e.g., functioning as if one satellite)”

    I guess that means that just formation flying, and operating together as such, makes a system ITAR-controlled. So if you just connect nearby spacecraft with girders or ropes, I have to assume that then they are no longer ITAR controlled! That’s a curious provision that would have ramifications for many space based solar power designs and other potentially commercial space efforts. Not sure if this provision is new. Presumably it is intended to restrict large aperture synthesized-array optical systems which certainly have relevance to national defense.

  • John Malkin

    I would think this is aimed at autonomous or semi-autonomous drone constellations.

    http://www.hngn.com/articles/25667/20140303/flock-birds-drone-robots-will-now-fly-formation-navigate-without.htm

    • Hiram

      “I would think this is aimed at autonomous or semi-autonomous drone constellations.”

      Well, “drone constellations” are not “Spacecraft and Related Articles”.

      As to space assets, I would think that such a capability is hardly unique to national security threats. Again, a space based solar power constellation would be pretty dumb if it weren’t autonomously maintaining a constellation.

      No, what they’re after is synthesizing large optical apertures for space surveillance that would assure enormously high resolution on the ground. But an SSP array would need vastly lower stationkeeping precision to do it.

      • Egad

        >No, what they’re after is synthesizing large optical apertures for space surveillance that would assure enormously high resolution on the ground.

        The current EO sats with 2.4 meter aperture and 250 km-ish perigees are getting close to the 5-10 cm limit that, according to Fried, is about the best the atmosphere will allow with passive optics. Better resolution would, I’d guess, need some sort of active scheme to probe and compensate for the atmosphere on a centimeter-decimeter scale within a few milliseconds. That seems pretty sporty.

        Bigger apertures would allow the limiting passive resolution to be obtained from greater distances. Multiple, independent apertures that could be coordinated into various larger or smaller composite apertures would have a bunch of interesting possibilities. The technology to do that would be challenging, but perhaps doable.

        • Hiram

          Yes, I was partly thinking GEO sats. Precision constellation management in LEO is hard to do for many reasons, and a lot easier in GEO. DARPA is already working on large deployable apertures for GEO that would provide 24/7 high resolution imaging of selected sites.

          But the atmospheric perturbations on spatial resolution don’t work the same way both directions. Looking down, most of the angular distortion happens closer to the target. 10cm resolution at 250km is precisely the diffraction limit of a 2.4m telescope at visible wavelengths, so the atmosphere isn’t limiting the resolution in that case.

          • Egad

            10cm resolution at 250km is precisely the diffraction limit of a 2.4m telescope at visible wavelengths, so the atmosphere isn’t limiting the resolution in that case.

            Right, and that’s the point. Current EO spysats are getting to the cross-over point where diffraction-limited resolution gives way to atmosphere-limited, the aforementioned 5-10 cm. If you put a 10-meter telescope into the same orbit as a KH-11, its best optical resolution wouldn’t be much if any better. It might have other advantages, like low-light and IR capability, and it could get the same optical resolution at higher, slower, less draggy altitudes — but it’s not going to read newspapers any better than KH-11, i.e., not at all.

            • Hiram

              Very interesting. I’m still not sure I understand the physics because, like I said, looking down isn’t quite the same as looking up. Do you have a reference that explains this atmosphere-limited down-looking resolution? In principle, if you have a verifiable point source on the ground at your target, you ought to be able to do a lot better, adaptively.

  • Egad

    “Spacecraft specially designed for human space flight that have integrated propulsion present another security concern, for such capabilities may be used for the purposes of weapons targeting from space,”

    What??? “Weapons targeting from space”? “Integrated propulsion”? Yeah, KH-11 and Lacrosse spawn are used for weapons targeting from space and do have integrated propulsion, but their CMG orientation systems are way more relevant for targeting. The propulsion is mostly used for occasional orbital maintenance, as may be seen by examination of their orbital element histories.

    Beyond that, many other humdrum satellites have integrated propulsion systems. This strikes me as someone who doesn’t really understand the matter trying to come up with words to justify a preordained ruling.

  • vulture4

    Manned spacecraft are “munitions”? A manned missile?

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