SIA Submits Comments on ITAR Draft Rules
The Satellite Industry Association Files Comments Supporting Draft Rules to Reform Satellite Export Controls, Satellite Industry Association
“The Satellite Industry Association (SIA) filed comments on Monday on the Administration’s proposals to reform the U.S. export controls for satellites and related items. The Departments of State and Commerce published draft regulations in May to significantly update the satellite export control system, following the passage of enabling legislation in January. SIA’s comments conveyed support for the Administration’s proposals, citing the importance of efficient, clear, and sensible export control rules in supporting innovation, investment and competitiveness for the nation’s space sector. SIA also identified several areas where the rules could be adjusted to improve clarity or bring them into better alignment with commercial practices and technology.”
– SIA Comments (PDF)
“… After undertaking a thorough review of the proposed rules, SIA has identified several areas in which modifications would enhance the regulations’ focus on the technologies of greatest concern, provide additional clarity, and enhance the intended benefits of reform for the U.S. satellite sector and overall U.S. space industrial base.
SIA urges the Department to ensure that the revised export control system for satellites and related items does not establish a “double licensing” requirement for certain items, where both a Commerce Department and a State Department license would be required for export. (In SIA’s comments on the proposed previsions to USML Category XV5, we note one limited exception to this position in the unique case of hosted payloads.) In general, “double licensing” requirements run contrary to the goal of streamlining and simplifying the existing system. One step that would help avoid the establishment of a “double licensing” requirement would be to clarify the application of the see-through rule to items listed under the revised USML Category XV.“
