Export Control Reform Spacecraft/Satellites

7/28/2014
Export Control Reform
Spacecraft/Satellites
Space Export Controls Update
• After Delivery of the 1248 Report to Congress (Apr 2012), Congress
added language into the FY13 National Defense Authorization Act that:
– Gave the President the authority to transfer certain satellites and
related items to the Commerce Control List (CCL)
– Prohibits export of CCL satellites and related items to China, North
Korea, or any state sponsor of terrorism
• May 24, 2013: Published proposed rules for satellite sections in
USML (Cat XV) and CCL (ECCN 9x515) – Public comment period
closed July 8, 2013.
• May 13, 2014: Final rules published.
– Effective date for radiation-hardened integrated circuits (and related
software and technology): June 27, 2014
– Effective date for all other items: November 10, 2014
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7/28/2014
Summary of Spacecraft Controls
Revised USML
Cat XV
Military
Satellites
Military
Ground
equip
Revised CCL
Other
Parts
critical for
military
functions
Services
for USML
and CCL
satellites
(IV and
XV)
GPS
Rcvrs
(XV now;
future
XII)
New ECCN 9x515
Existing ECCNs
Worldwide license, except
Canada.
Review microelectronic
circuit ECCNs, 7A004,
7A104, and ECCNs using
“space qualified” prior to
using the catch-all control
in 9A515.x.
25% de minimis, except 0% for
China and other D:5 countries.
STA eligible for A:5, except for
certain software and technology
Sats and
Ground
equip not
in USML
Rad Hard
ICs
Parts not
on USML
or other
CCL
New sat
related
item or
tech
Spec
electronics
Spec
optical
sensors
Spec
radar
systems
3
Items Remaining on USML
• Satellites and spacecraft
− Unique military and intelligence functions, including nuclear
detection, intelligence collection, missile tracking, anti-satellite or
space-based weapons, classified operation or equipment, and
navigation
− Certain remote sensing with military applications
− Man-rated habitats with integrated propulsion
• Ground control equipment
− Performs a uniquely military function for one of satellites above
• Parts & components
− Sixteen specific technologies critical to military functions
− Any payload that performs one of military functions listed above
− DoD funded payloads
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16 Critical Technologies
Remaining on USML
1) Certain specified antennas having particular capabilities
2) Certain space-qualified optics with particular properties
3) Space-qualified FPAs having particular peak response wavelength
4) Space-qualified mechanical cryocooler
5) Space-qualified active vibration suppression
6) Certain optical bench assemblies
7) Certain non-communication space-qualified directed energy systems
8) Space-based kinetic or charged particle energy systems
9) Certain space-qualified atomics clocks
10) High performance attitude determination and control systems
11) Certain space-based thermoionic converters or generators
12) Certain thrusters for orbit adjustment
13) Control moment gyroscopes
14) Certain space-qualified MIMICs
15) Certain space-qualified oscillators
16) Certain high performing star trackers
5
Services Remaining on USML
• Satellite integration and launch services
− Provided by a U.S. person
− To a foreign launch integrator or launch vehicle
provider
• Launch support considered a defense service,
includes furnishing assistance or information
for:
− Integration of any satellite to a launch vehicle
− Launch failure analysis
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7/28/2014
Items Transferred to CCL
• Satellites
-
Commercial Communication Satellites
Lower-Performance Remote Sensing Satellites
Planetary Rovers
Planetary and Interplanetary Probes
• Related systems for the above:
Ground control systems
Training simulators
Test, inspection, and production equipment
Non-critical software for production, operation or maintenance
Non-critical technology for development, production, installation, operation or
maintenance
- Radiation hardened microelectronics
-
• Parts and components of satellite bus and payloads not listed on
USML
- Thousands of types of parts and subsystems
- Hundreds of thousands of specific parts
7
Notes on Jurisdiction
• Spacecraft in 9A004 or 9A515.a remain subject to the
EAR even when incorporating a hosted payload
performing a function described in USML Category
XV(a). All spacecraft incorporating primary or
secondary payloads that perform a function described
in XV(a) are controlled in XV(a).
• ITAR “see-through” rule does not apply to parts,
components, accessories, attachments, equipment, or
systems in XV(e) that are integrated into and included
as an integral part of an EAR item prior to export,
reexport, or transfer
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Non-Controlled Space-Related
Technology
• Technology required for spaceflight passenger or
participant experience, as described in Note 2 to
9E515, is not subject to the ITAR or EAR.
• Technical data is not subject to the ITAR or EAR when
transmitted to or from a satellite or spacecraft, when
limited to information about the health, operational
status, or measurements or function of, or raw sensor
output from, the spacecraft, spacecraft payload, or its
associated subsystems or components (see Note 3 to
9E515).
9
Order of Review - Spacecraft
(Supp. No. 4 to part 774)
• Review USML Category XV
– Specifically enumerated items
– “Catch-all” controls and ITAR definition of “specially
designed”
• If not on the USML, review the CCL
– Review applicable 9x515 ECCN
• Specifically enumerated items
• “Catch-all” controls and EAR definition of “specially
designed”
• Note: the following ECCNs supersede 9A515.x:
– ECCNs for microelectronic circuits
– 7A004, 7A104
– ECCNs containing “space-qualified” as a criterion
– Review other applicable non-9x515 ECCNs
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9x515 Framework
•
9A515
CCL
Category
0-9
Product
Group
A-E
.a - .w: specifically enumerated
end items, materials, parts,
components, accessories, and
attachments
– Some items may be “specially
designed”
Last two
characters
reference
USML Cat XV
“5” is used to distinguish from
600 series and dual-use items
not previously in USML Cat XV
•
•
.x: “specially designed” parts,
components, accessories, and
attachments that are not
specifically enumerated
.y: items that would otherwise be
within scope of 9A515.x but that
have been identified in
interagency-cleared CCATS
(§748.3(e))
– No items currently listed here
11
9x515 ECCN Framework
• Subject to same scope of controls as 600
series items
– NS1, RS1, and AT1 generally
– MT for some items
• License applications for Country Group D:5
reviewed consistent with ITAR § 126.1
– Policy of denial for Country Group E:1 and China
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7/28/2014
License Exceptions
• 9x515 generally eligible for many license
exceptions (e.g., LVS, TMP, RPL, GOV, TSU, STA)
– Restrictions apply in § 740.2, including 9x515
items subject to MT control
• Current restriction in § 740.2(a)(7) restricting
use of license exceptions for certain spacequalified items will be removed Nov 10.
13
License Exception STA
• 9x515 generally eligible for STA for Country Group
A:5
– Unlike 600 series, ultimate government end use is not
required
– Prior Consignee Statement requirements generally the
same as for non-600 series items, but statement must
allow for USG end-use check
– Certain spacecraft in 9A515.a require eligibility
request
– Software in 9D515.b, .d, or .e and technology in
9E515.b, .d, or .e are not eligible for STA
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License Exception STA
600 Series Items
9x515 Items
Other EAR Items
Ultimate government end
use required?
Yes
No
No
Always limited to Country
Group A:5?
Yes
Yes
No
Eligibility request
required?
Yes, for end items
in 0A606.a,
8A609.a, 8A620.a
or .b, or 9A610.a
Yes, for certain
spacecraft in
9A515.a
No
Must the foreign parties
have been on a previously
approved license?
Yes
No
No
Does Prior Consignee
Statement require
agreement to permit USG
end-use check?
Yes, if the
consignee is not
the government
of an A:5 country
Yes, if the
consignee is not
the government
of an A:5 country
No
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Reexport Considerations –
De Minimis
• 9x515 subject to same de minimis rule as 600 series
Items identified in .a through .x paragraphs of 9x515
ECCN
Item with U.S. content
25% de minimis rule
reexported to all countries,
except D:5 (see also ITAR
§126.1)
D:5 (U.S. arms embargoed) 0% de minimis rule
Note 1: See Supplement No. 2 to Part 734 – Guidelines for De minimis Rules
Note 2: If exceeds de minimis, the foreign made item is subject to the EAR.
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Reexport Considerations –
De Minimis
• 9x515 subject to same de minimis rule as 600 series
For any future items identified in 9A515.y
Item with U.S. .y content only Not subject to the EAR
reexported to all countries,
except E:1 plus China
E:1 plus China
0% de minimis rule
Note 1: See Supplement No. 2 to Part 734 – Guidelines for De minimis Rules
Note 2: If exceeds de minimis, the foreign made item is subject to the EAR.
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Reexport or Transfer of Direct Products
of U.S. Technology or Software
• Under § 124.8(5) of the ITAR, any defense article produced or
manufactured from ITAR technical data or defense service requires
DDTC approval prior to transfer to any non-U.S. person.
• Under the EAR, certain foreign-made items that are located outside
the U.S. that are the direct product of certain U.S.-origin technology
or software are subject to the EAR when exported from abroad or
reexported to certain countries.
• 9x515 items are subject to a broader direct product rule (additional
country and product scope) than other items subject to the EAR.
• Foreign-made items subject to the EAR because of this rule are
subject to the same license requirements to the new country of
destination as if they were of U.S. origin.
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7/28/2014
Reexport or Transfer of Direct Products
of U.S. Technology or Software
The 9x515 direct product rule (same as 600 series)
Is the foreign-produced direct product of:
Yes
(i) U.S.-origin 9x515 technology or software or
(ii) a plant or major component of a plant that is a direct
product of U.S.-origin 9x515 technology or software?
Is the foreign-produced direct product a 9x515 item?
Yes
Is the foreign-produced direct product being reexported or
exported from abroad to countries listed in Country Groups
D:1, D:3, D:4, D:5 E:1?
Yes
Note: If “yes” to all three questions, then the foreign made item is subject to the EAR.
19
Items on the CCL - 9A515 .a and .b
•
9A515.a “Spacecraft,” including satellites, and space vehicles, whether
designated developmental, experimental, research or scientific, not enumerated in
USML Category XV or described in 9A004 (the ISS).
– This includes commercial communications satellites, remote sensing satellites
not identified in USML Category XV(a), planetary rovers, planetary and
interplanetary probes, and in-space habitats.
•
9A515.b Ground control systems and training simulators “specially designed” for
telemetry, tracking, and control of the “spacecraft” controlled in paragraph
9A515.a.
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Items on the CCL - 9A515.d
•
•
•
•
•
•
Microelectronic circuits (e.g., integrated circuits and micro-circuits) rated, certified,
or otherwise specified or described as meeting or exceeding all the following
characteristics and that are “specially designed” for defense articles, “600 series”
items, or items controlled by 9A515:
d.1. A total dose of 5 x 105 Rads (Si) (5 x 103 Gy (Si));
d.2. A dose rate upset threshold of 5 x 108 Rads (Si)/sec (5 x 106 Gy (Si)/sec);
d.3. A neutron dose of 1 x 1014 n/cm2 (1 MeV equivalent);
d.4. An uncorrected single event upset sensitivity of 1 x 10-10 errors/bit/day or
less, for the CRÈME-MC geosynchronous orbit, Solar Minimum Environment for
heavy ion flux; and
d.5. An uncorrected single event upset sensitivity of 1 x 10-3 errors/part or less
for a fluence of 1 X 107 protons/cm2 for proton energy greater than 50 MeV.
21
Items on the CCL - 9A515.e
•
•
•
•
Microelectronic circuits (e.g., integrated circuits and micro-circuits) that are rated,
certified, or otherwise specified or described as meeting or exceeding all the
following characteristics and that are “specially designed” for defense articles
controlled by USML Category XV or items controlled by 9A515:
e.1. A total dose ≥1 X 105 Rads (Si) (1 x 103 Gy(Si)) and <5 X 105 Rads (Si) (5 x 103
Gy(Si)); and
e.2. A single event effect (SEE) (i.e., single event latchup (SEL), single event
burnout (SEB), or single event gate rupture (SEGR)) immunity to a linear energy
transfer (LET) ≥80 MeV-cm2/mg.
Note 2 to 9A515.d and .e: See 3A001.a for controls on radiation-hardened
microelectronic circuits “subject to the EAR” that are not controlled by 9A515.d or
9A515.e.
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Items on the CCL - 9A515.x
•
•
•
•
•
Parts,” “components,” “accessories” and “attachments” that are “specially
designed” for defense articles controlled by USML Category XV or items controlled
by 9A515, and that are NOT:
1.
Enumerated or controlled in the USML or elsewhere within ECCN 9A515;
2.
Microelectronic circuits;
3.
Described in 7A004 or 7A104; or
4.
Described in an ECCN containing “space-qualified” as a control criterion (i.e.,
3A001.b.1, 3A001.e.4, 3A002.a.3, 3A002.g.1, 3A991.o, 3A992.b.3, 6A002.a.1,
6A002.b.2, 6A002.d.1, 6A004.c and .d, 6A008.j.1, or 6A998.b).
23
Items on the CCL - 9A515.y
•
Items that would otherwise be within the scope of ECCN 9A515.x but that have
been identified in an interagency-cleared commodity classification (CCATS)
pursuant to § 748.3(e) as warranting control in 9A515.y.
•
No items are currently identified for .y
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7/28/2014
Items on the CCL - 9B515
•
Test, inspection, and production “equipment” “specially designed” for “spacecraft”
and related commodities, as follows (see List of Items Controlled).
•
a.
Test, inspection, and production “equipment” “specially designed” for the
“production” or “development” of commodities enumerated in ECCN 9A515.a, or
USML Category XV(a) or XV(e).
Note: ECCN 9B515.a includes equipment, cells, and stands “specially designed” for
the analysis or isolation of faults in commodities enumerated in ECCN 9A515.a or
USML Category XV(a) or XV(e).
•
•
b.
Environmental test chambers capable of pressures below (10-4) Torr, and
“specially designed” for commodities enumerated in 9A515.a or USML Category
XV(a).
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Items on the CCL – 9D515 and 9E515
•
9D515 “Software” “specially designed” for the “development,” “production,”
operation, installation, maintenance, repair, overhaul, or refurbishing of “spacecraft”
and related commodities.
•
9E515 “Technology” “required” for the “development,” “production,” operation,
installation, repair, overhaul, or refurbishing of “spacecraft” and related
commodities.
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7/28/2014
USML Spacecraft
•
•
•
•
•
•
•
Spacecraft, including satellites and space vehicles, whether designated
developmental, experimental, research, or scientific, or having a commercial, civil,
or military end-use, that:
Are specially designed to mitigate effects (e.g., scintillation) of or for detection of a
nuclear detonation;
Autonomously track ground, airborne, missile, or space objects in real-time using
imaging, infrared, radar, or laser systems;
Conduct signals intelligence (SIGINT) or measurement and signatures intelligence
(MASINT);
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) with the characteristics or functions of other items in paragraph
(a);
Are anti-satellite or anti-spacecraft (e.g., kinetic, RF, laser, charged particle);
Have space-to-ground weapons systems (e.g., kinetic or directed energy);
27
USML Remote Sensing Satellites
•
•
•
•
(i) Electro-optical visible and near infrared (VNIR) (i.e., 400nm to 1,000nm) or
infrared (i.e., greater than 1,000nm to 30,000nm) with less than 40 spectral bands
and having a clear aperture greater than 0.35 meters;
(ii) Electro-optical hyperspectral with 40 spectral bands or more in the VNIR, shortwavelength infrared (SWIR) (i.e., greater than 1,000nm to 2,500nm) or any
combination of the aforementioned and having a Ground Sample Distance (GSD)
less than 30 meters;
(iii) Electro-optical hyperspectral with 40 spectral bands or more in the midwavelength infrared (MWIR) (i.e., greater than 2,500nm to 5,500nm) having a
narrow spectral bandwidth of Δλ less than or equal to 20nm full width at half
maximum (FWHM) or having a wide spectral bandwidth with Δλ greater than
20nm FWHM and a GSD less than 200 meters; or
(iv) Electro-optical hyperspectral with 40 spectral bands or more in the longwavelength infrared (LWIR) (i.e., greater than 5,500nm to 30,000nm) having a
narrow spectral bandwidth of Δλ less than or equal to 50nm FWHM or having a
wide spectral bandwidth with Δλ greater than 50nm FWHM and a GSD less than
500 meters;
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USML Spacecraft
•
•
•
•
•
Have radar remote sensing capabilities or characteristics (e.g., active electronically
scanned array (AESA), synthetic aperture radar (SAR), inverse synthetic aperture
radar (ISAR), ultra-wideband SAR), except those having a center frequency equal to
or greater than 1 GHz but less than or equal to 10 GHz and having a bandwidth
less than 300 MHz;
Provide Positioning, Navigation, and Timing (PNT) signals;
Provide space-based logistics, assembly, or servicing of any spacecraft (e.g.,
refueling) and have integrated propulsion other than that required for attitude
control;
Provide for sub-orbital, Earth orbital, cis-lunar, lunar, deep space (i.e., space
beyond lunar orbit), and planetary spaceflight, or in-space human habitation,
which have integrated propulsion other than that required for attitude control; or
Are classified, contain classified software or hardware, are manufactured using
classified production data, or are being developed using classified information .
29
USML Spacecraft Related Items
•
Ground control systems or training simulators, specially designed for telemetry,
tracking, and control (TT&C) of spacecraft in paragraph (a) of this category.
•
Global Positioning System (GPS) receiving equipment specially designed for
military application, or GPS receiving equipment with any of the following
characteristics, and specially designed parts and components therefor:
–
–
–
Specially designed for encryption or decryption (e.g., Y-Code) of GPS precise positioning service (PPS)
signals (MT if designed or modified for airborne applications);
Specially designed for use with a null steering antenna, an electronically steerable antenna, or
including a null steering antenna designed to reduce or avoid jamming signals (MT if designed or
modified for airborne applications);
Specially designed for use with rockets, missiles, SLVs, drones, or unmanned air vehicle systems
capable of delivering at least a 500 kg payload to a range of at least 300 km (MT if designed or
modified for rockets, missiles, SLVs, drones, or unmanned air vehicle systems controlled in this
subchapter).
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USML Technical Data and Defense Services
•
XV(f) Technical data and defense services directly related to the defense articles
enumerated in paragraphs (a) through (e) of this category and classified technical
data directly related to items controlled in ECCNs 9A515, 9B515, or 9D515 and
defense services using the classified technical data.
•
Defense services include the furnishing of assistance (including training) in the
integration of a satellite or spacecraft to a launch vehicle, including both planning
and onsite support, regardless of the jurisdiction, ownership, or origin of the
satellite or spacecraft, or whether technical data is used. It also includes the
furnishing of assistance (including training) in the launch failure analysis of a
satellite or spacecraft, regardless of the jurisdiction, ownership, or origin of the
satellite of spacecraft, or whether technical data is used.
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Commerce Contact Information
Technical and Licensing Questions on Satellites: Office of National Security and Technology
Transfer Controls
• Mark Jaso, [email protected]
• Reynaldo Garcia, [email protected]
• Dennis Krepp, [email protected]
Regulatory Interpretation and Transition Guidance
• Regulatory Policy Division: [email protected] , 202-482-2440
Web: www.bis.doc.gov
www.export.gov/ecr
NOTE: For ITAR items please refer to State/DDTC
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7/31/2014
Export Reform and
NASA’s Mars Missions
David T. Flynn
NASA Headquarters Export Administrator
National Aeronautics
and Space Administration
July 29, 2014
1
MID-20TH CENTURY FASCINATION WITH SPACE
Wernher von Braun and Chesley Bonestell prediction of the future in 1951
Illustration by Robert McCall
Drake – Footprints on Mars
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DR. WERNHER VON BRAUN’S MANNED MARS LANDING
PRESENTATION TO THE SPACE TASK GROUP - 1969
Nuclear Thermal
Propulsion
640 Total Days
60 Days on Mars
Venus Swing-by
Propulsive Earth Return
Collectors Guide Publishing
December 1, 2006
100 in LEO
48 on Moon
Mars: 48 on Surface
24 in Orbit
Drake – Footprints on Mars
3
WHY DO WE WANT TO EXPLORE MARS?
Long-standing
curiosity
Are we alone?
Did Mars ever harbor life?
Understanding Earth’s
future from Mars’ past
Drake – Footprints on Mars
Pioneering new
frontiers
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5/10//2014
5
SPACE EXPLORATION AND EXPORT REFORM
 Previously, all spacecraft, specially designed parts and




components, and production equipment subject to ITAR
—International Space Station was lone EAR spacecraft
Regulatory change is causing NASA to evaluate jurisdiction
and classification on a mission by mission basis
Preliminary indications are that the changes will benefit
NASA’s international collaborations in space exploration
Changes are eagerly anticipated by many of NASA’s
international partners
Assessment is ongoing
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7/31/2014
ORDER OF REVIEW
(Supp. No. 4 to part 774)
 Review the USML

—Specifically enumerated items
—“Catch-all” controls and ITAR definition of “specially
designed”
If not on the USML, review the CCL
—Review characteristics of item to determine applicable CCL
category and product group
—Review applicable 500 & 600 series ECCNs
 Specifically enumerated items
 “Catch-all” controls and EAR definition of “specially
designed”
—Review applicable non-500 & non-600 series ECCNs
NASA’S MARS ROVERS
9A515.a “Spacecraft,”
including satellites, and space
vehicles, whether designated
developmental, experimental,
research or scientific, not
enumerated in USML Category
XV or described in 9A004 (the
ISS).
Sojourner, Opportunity, and Curiosity Rovers
• This includes commercial
communications
satellites, remote sensing
satellites not identified in
USML Category XV(a),
planetary rovers,
planetary and
interplanetary probes,
and in-space habitats.
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Mars Reconnaissance Orbiter
Applying Export Reform to MRO
 NASA's Mars Reconnaissance Orbiter (MRO) is orbiting
Mars searching for evidence that water persisted on the
surface of Mars for a long period of time.
 MRO’s science instruments zoom in for extreme close-up
photography of the Martian surface, analyze minerals,
look for subsurface water, trace how much dust and
water are distributed in the atmosphere, and monitor
daily global weather. The MRO is also a powerful
communications and navigation link.
 To demonstrate the impact that Export Reform will have
on the Mars Program, we’ve classified these instruments
using the new rules to see which, if any, will be
transferred from the ITAR to the EAR.
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MRO SCIENCE INSTRUMENTS
 Cameras
— High Resolution Imaging Science Experiment (HiRISE)
— Context Camera (CTX)
— Mars Color Imager (MARCI)
 Spectrometer
— Compact Reconnaissance Imaging Spectrometer for Mars
(CRISM)
 Radiometer
— Mars Climate Sounder (MCS)
 Radar
— Shallow Radar (SHARAD)
REVISED ITAR CATEGORY XV PARA (A)(7)
– SATELLITES THAT ...
Have any of the following electro-optical remote sensing capabilities or
characteristics:
i. Electro-optical in VNIR wavelength (400 to 1000nm) or IR (1001 to 30,000nm)
with < 40 spectral bands and a clear aperture > 0.35 m; or
ii. Electro-optical hyperspectral in VNIR or SWIR wavelength (1001 to 2500nm) or
any combination thereof, with spectral bands ≥ 40, and having a Ground Sample
Distance( GSD) < 30m; or
iii. Electro-optical hyperspectral with spectral bands ≥ 40 in the MWIR (2501 to
5500nm), having a narrow spectral bandwidth of delta lambda ≤ 20nm full
width at half maximum (FWHM) or having a wide spectral bandwidth with delta
lambda > 20nm FWHM and a GSD < 200 meters;
iii. Electro-optical hyperspectral with spectral bands ≥ 40 in the LWIR 5501 to
30,000nm), having a narrow spectral bandwidth of delta lambda ≤ 50nm FWHM
or having a wide spectral bandwidth with delta lambda > 50nm FWHM and a
GSD < 500 meters;
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7/31/2014
ELECTRO-OPTICAL REMOTE SENSING







Electro-optical devices operate by modification of the optical properties of a material by an
electric field.
Spectral bands - regions of the electromagnetic spectrum, such as ultraviolet radiation, visible
radiation, etc.
Clear aperture – the diameter or size of an optical component that must meet specifications.
Multi-spectral imaging captures image data at specific frequencies across the electromagnetic
spectrum – the opposite of panchromatic, which records only the total intensity of radiation falling
on each pixel.
Hyperspectral imaging is spectral imaging with more numerous bands, finer spectral resolution or
wider spectral coverage.
Full width at half maximum - FWHM is used to describe a measurement of the width of an object
in a picture, when that object does not have sharp edges.
Ground sample distance (GSD) – Distance between pixel centers measured on the ground. The
smaller the value of the image GSD, the higher the spatial resolution of the image and the more
details that are visible.
MRO SCIENCE INSTRUMENTS – HIRISE CAMERA
A HIGH RESOLUTION REFLECTING TELESCOPE
Parameter
Performance
Comments
Spectral range
400 to 600 nm
550 to 850nm
800 to 1000 nm
Visible - Blue-Green (BG)
Visible - Red
Near infra-red (NIR)
Spectral Bands
Clear aperture
Resolution
3
0.5 m
0.3 m
At 300 km altitude
Classification
CAT XV(e)(17)
Payload performing the
functions described in
paragraph (a)(7)(i) (i.e.,
having spectral range
VNIR, spectral bands < 40,
clear aperture > 0.35 m). 14
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MRO SCIENCE INSTRUMENTS – CRISM SPECTROMETER
PRODUCES DETAILED MAPS OF THE SURFACE MINERALOGY OF MARS
Parameter
Performance
Comments
Spectral range
Spectral Bands
Ground Sampling
Distance (GSD)
370 to 3920 nm
544
VNIR, SWIR, MWIR
18 m
At 300 km altitude
Classification
CAT XV(e)(17)
Payload performing the
functions described in
paragraph (a)(7)(ii) (i.e.,
having spectral range
VNIR & SWIR; spectral
bands ≥ 40; GSD < 30 m).
15
MRO SCIENCE INSTRUMENTS – SHARAD RADAR
Probes underground layers of ice, rock and water to a depth of 1 km
Parameter
Performance
Remote Sensing
Capability
Synthetic Aperture
(SAR)
Bandwidth
10 MHz
Center Frequency
20 MHz
Classification
CAT XV(e)(17)
Comments
Payload performing the
functions described in
paragraph (a)(8) (i.e., being
SAR with center frequency < 1
GHz and bandwidth < 300
MHz).
16
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MRO SCIENCE INSTRUMENTS – MARS CLIMATE SOUNDER (MCS)
A SPECTROMETER MEASURING TEMP., PRESSURE, WATER VAPOR AND DUST LEVELS
Parameter
Performance
Comments
Spectral Range
300 to 3000 nm
12000 to 50000 nm
9
4 cm
ECCN 9A515(x)
VNIR
Thermal Infra-red
Spectral Bands
Clear Aperture
Classification
(not XV(e)(17) as payload
performing functions of (a)(7)(i)
because clear aperture not > 0.35
m; not (a)(7)(ii), (iii) or (iv)
because spectral bands not ≥ 40.
17
MRO Science Instruments – Context Camera (CTX)
A MAKSUTOV CASSEGRAIN TELESCOPE PROVIDING CONTEXT MAPS FOR HIRISE & CRISM
Parameter
Performance
Comments
Spectral Range
Spectral Bands
Clear Aperture
Resolution
Classification
500 to 700 nm
3
< 0.35 m
6 m/pixel
ECCN 9A515(x)
Visible
At 300 km altitude
(not XV(e)(17) as payload
performing functions of (a)(7)(i)
because not VNIR or IR with clear
aperture > 0.35 m; not (a)(7)(ii),
(iii) or (iv) because spectral bands
not ≥ 40).
18
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MRO SCIENCE INSTRUMENTS – MARS COLOR IMAGER (MARCI)
A WIDE ANGLE CAMERA THAT PROVIDES A DAILY GLOBAL WEATHER REPORT
Parameter
Performance
Comments
Spectral Range
Spectral Bands
Clear Aperture
Resolution
Classification
260 to 725 nm
7
< 0.35 m
1 to 10 km/pixel
ECCN 9A515(x)
Ultraviolet and visible
2 Ultraviolet, 5 Visible
(not XV(e)(17) as payload
performing functions of (a)(7)(i)
because not VNIR or IR with clear
aperture > 0.35 m; not (a)(7)(ii),
(iii), (iv) because spectral bands
not ≥ 40).
19
MRO ENGINEERING INSTRUMENTS –OPTICAL NAVIGATION CAMERA
500 MM FOCAL LENGTH, F/8.3 RITCHEY-CHRETIEN
Parameter
Performance
Comments
Spectral Range
Spectral Bands
Clear Aperture
Resolution
Classification
450 – 600 nm
2
6 cm
24 mrad/pixel
ECCN 9A515(x)
Blue-Green (BG)
At 200 km
(not XV(e)(17) as payload
performing functions of (a)(7)(i)
because not VNIR or IR with clear
aperture > 0.35 m; not
(a)(7)(ii),(iii), or (iv) because
spectral bands not ≥ 40).
20
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MISCELLANEOUS MRO SYSTEMS
System
Specifications
Current
Classification
Proposed
Classification
Remarks*
Star Tracker
20 arcsec (3-sigma) for 1
deg/sec
CAT XV(e)
9A515x
Lacks accuracy/tracking rate of XV(e)(16).
Attitude Determination &
Control
CAT XV(e)
9A515x
Lacks autonomous ACS capability of
XV(e)(10).
Accelerometer
CAT XV(e)
9A515x
Accelerometers are not enumerated in
XV(e).
CAT XV(e)
9A515x
Not a control moment gyro of XV(e)(13).
CAT XV(e)
9A515x
Reaction wheels are not enumerated in
XV(e).
CAT XV(e)
9A515x
XV(e)(12) requires > 667.23 N vacuum
thrust.
Ka Band Radio
CAT XV(e)
9A515x
Radios are not enumerated in XV(e).
UHF Radio
CAT XV(e)
9A515x
Radios are not enumerated in XV(e).
CAT XV(e)
9A515x
Doesn’t meet any parameters of XV(e)(1).
Gyro
Ring laser gyro
Reaction Wheels
Thrusters
Antennae
170.0 N Vacuum Trust
HGA is 3 m.
FPAs
No Focal Plane Arrays are used on MRO.
MIMICs
Ultra Stable Oscillator
No MIMICs are used on MRO.
Phase noise 1 kHz/-120 dBc
CAT XV(e)
9A515x
Not used for radar as required in XV(e)(15).
21
Use the lunar vicinity as a proving ground to demonstrate capabilities and
learn to manage the risks of the deep space environment.
Drake – Footprints on Mars
22
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7/31/2014
Orion Spacecraft
Multi-Purpose Crew Vehicle
Orion is the first spacecraft in
history capable of taking
humans to multiple
destinations in deep space.
– Long Duration –
– Adaptable –
– Life Sustaining –
Drake – Footprints on Mars
23
SPACECRAFT DEFINITIONS
ITAR Spacecraft
Provide for sub-orbital, Earth
orbital, cis-lunar, lunar, deep
space (i.e., space beyond lunar
orbit), and planetary spaceflight,
or in-space human habitation,
which have integrated propulsion
other than that required for
attitude control;
articles.
EAR Spacecraft
9A515.a “Spacecraft,” including
satellites, and space vehicles,
whether designated developmental,
experimental, research or scientific,
not enumerated in USML Category
XV or described in 9A004 (the ISS).
– This includes commercial
communications satellites,
remote sensing satellites not
identified in USML Category
XV(a), planetary rovers,
planetary and interplanetary
probes, and in-space habitats.
12
7/31/2014
COMMERCE CONTROLLED SPACECRAFT
PRELIMINARY ASSESSMENT INDICATES THE ORION CREW MODULE WILL JOIN THE ISS ON THE CCL
For questions contact
David T. Flynn
NASA Headquarters Export Administrator
[email protected]
Acknowledgements:
Bret G. Drake, NASA Lyndon B. Johnson Space Center
John Duncan, Jet Propulsion Laboratory
13