export control reform spacecraft/satellites
TRANSCRIPT
7/28/2014
1
Export Control Reform Spacecraft/Satellites
Space Export Controls Update
2
• 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
7/28/2014
2
Summary of Spacecraft Controls
Revised USML
Cat XV
Military Satellites
Military Ground equip
Parts critical for military
functions
Other
Services for USML and CCL satellites
(IV and XV)
GPS Rcvrs
(XV now; future XII)
Revised CCL
New ECCN 9x515
Worldwide license, except Canada.
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
Existing ECCNs
Review microelectronic circuit ECCNs, 7A004, 7A104, and ECCNs using “space qualified” prior to using the catch-all control in 9A515.x.
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
4
7/28/2014
3
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
6
7/28/2014
4
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
8
7/28/2014
5
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 10
7/28/2014
6
9x515 Framework • .a - .w: specifically enumerated
end items, materials, parts, components, accessories, and attachments – Some items may be “specially
designed”
• .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
9A515
CCL Category 0-9
Product Group A-E
“5” is used to distinguish from 600 series and dual-use items not previously in USML Cat XV
Last two characters reference USML Cat XV
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
12
7/28/2014
7
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 space-qualified 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
14
7/28/2014
8
License Exception STA
15
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
Reexport Considerations – De Minimis
• 9x515 subject to same de minimis rule as 600 series
16
Items identified in .a through .x paragraphs of 9x515 ECCN
Item with U.S. content reexported to all countries, except D:5 (see also ITAR §126.1)
25% de minimis rule
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.
7/28/2014
9
Reexport Considerations – De Minimis
• 9x515 subject to same de minimis rule as 600 series
17
For any future items identified in 9A515.y
Item with U.S. .y content only reexported to all countries, except E:1 plus China
Not subject to the EAR
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.
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.
18
7/28/2014
10
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: (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?
Yes
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.
20
7/28/2014
11
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.
22
7/28/2014
12
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
24
7/28/2014
13
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).
25
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.
26
7/28/2014
14
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, short-wavelength 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 mid-wavelength 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 long-wavelength 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;
28
7/28/2014
15
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).
30
7/28/2014
16
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.
31
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
32
7/31/2014
1
1
July 29, 2014 David T. Flynn
NASA Headquarters Export Administrator
Export Reform and
NASA’s Mars Missions
National Aeronautics and Space Administration
MID-20TH CENTURY FASCINATION WITH SPACE
Wernher von Braun and Chesley Bonestell prediction of the future in 1951 Illustration by Robert McCall
2 Drake – Footprints on Mars
7/31/2014
2
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
100 in LEO
48 on Moon
Mars: 48 on Surface 24 in Orbit
Collectors Guide Publishing December 1, 2006
3 Drake – Footprints on Mars
WHY DO WE WANT TO EXPLORE MARS?
4 Drake – Footprints on Mars
Long-standing curiosity
Are we alone? Did Mars ever harbor life?
Pioneering new frontiers
Understanding Earth’s future from Mars’ past
7/31/2014
3
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
7/31/2014
4
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). • 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.
Sojourner, Opportunity, and Curiosity Rovers
7/31/2014
5
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.
10
7/31/2014
6
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;
7/31/2014
7
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
14
Parameter
Spectral range Spectral Bands Clear aperture Resolution Classification
Performance
400 to 600 nm 550 to 850nm 800 to 1000 nm 3 0.5 m 0.3 m CAT XV(e)(17)
Comments
Visible - Blue-Green (BG) Visible - Red Near infra-red (NIR) At 300 km altitude Payload performing the functions described in paragraph (a)(7)(i) (i.e., having spectral range VNIR, spectral bands < 40, clear aperture > 0.35 m).
A HIGH RESOLUTION REFLECTING TELESCOPE
7/31/2014
8
MRO SCIENCE INSTRUMENTS – CRISM SPECTROMETER
15
Parameter
Spectral range
Spectral Bands
Ground Sampling Distance (GSD)
Classification
Performance
370 to 3920 nm
544
18 m
CAT XV(e)(17)
Comments
VNIR, SWIR, MWIR At 300 km altitude Payload performing the functions described in paragraph (a)(7)(ii) (i.e., having spectral range VNIR & SWIR; spectral bands ≥ 40; GSD < 30 m).
PRODUCES DETAILED MAPS OF THE SURFACE MINERALOGY OF MARS
MRO SCIENCE INSTRUMENTS – SHARAD RADAR
16
Parameter
Remote Sensing Capability Bandwidth Center Frequency Classification
Performance
Synthetic Aperture (SAR) 10 MHz 20 MHz 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).
Probes underground layers of ice, rock and water to a depth of 1 km
7/31/2014
9
MRO SCIENCE INSTRUMENTS – MARS CLIMATE SOUNDER (MCS)
17
Parameter Spectral Range Spectral Bands Clear Aperture Classification
Performance 300 to 3000 nm 12000 to 50000 nm 9 4 cm ECCN 9A515(x)
Comments VNIR Thermal Infra-red (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.
A SPECTROMETER MEASURING TEMP., PRESSURE, WATER VAPOR AND DUST LEVELS
MRO Science Instruments – Context Camera (CTX)
18
Parameter Spectral Range Spectral Bands Clear Aperture Resolution Classification
Performance 500 to 700 nm 3 < 0.35 m 6 m/pixel ECCN 9A515(x)
Comments 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).
A MAKSUTOV CASSEGRAIN TELESCOPE PROVIDING CONTEXT MAPS FOR HIRISE & CRISM
7/31/2014
10
MRO SCIENCE INSTRUMENTS – MARS COLOR IMAGER (MARCI)
19
Parameter Spectral Range Spectral Bands Clear Aperture Resolution Classification
Performance 260 to 725 nm 7 < 0.35 m 1 to 10 km/pixel ECCN 9A515(x)
Comments 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).
A WIDE ANGLE CAMERA THAT PROVIDES A DAILY GLOBAL WEATHER REPORT
MRO ENGINEERING INSTRUMENTS –OPTICAL NAVIGATION CAMERA
20
Parameter Spectral Range Spectral Bands Clear Aperture Resolution Classification
Performance 450 – 600 nm 2 6 cm 24 mrad/pixel ECCN 9A515(x)
Comments 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).
500 MM FOCAL LENGTH, F/8.3 RITCHEY-CHRETIEN
7/31/2014
11
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).
Gyro Ring laser gyro CAT XV(e) 9A515x Not a control moment gyro of XV(e)(13).
Reaction Wheels CAT XV(e) 9A515x Reaction wheels are not enumerated in XV(e).
Thrusters 170.0 N Vacuum Trust 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).
Antennae HGA is 3 m. CAT XV(e) 9A515x Doesn’t meet any parameters of XV(e)(1).
FPAs
No Focal Plane Arrays are used on MRO.
MIMICs No MIMICs are used on MRO.
Ultra Stable Oscillator 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.
22 Drake – Footprints on Mars
7/31/2014
12
Multi-Purpose Crew Vehicle
Orion Spacecraft
Orion is the first spacecraft in history capable of taking humans to multiple destinations in deep space.
– Long Duration – – Adaptable –
– Life Sustaining –
23 Drake – Footprints on Mars
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.
7/31/2014
13
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
Acknowledgements: Bret G. Drake, NASA Lyndon B. Johnson Space Center
John Duncan, Jet Propulsion Laboratory