[Board] CJ Open Source Satellite-CJ-0003120-Submittal Letter to DDTC

[Michelle Thompson]

Greetings! It's such good news to hear about your operations center. We
concur with your approach and we are here to help make learning and
participation in space easier.

Here is the GitHub folder with all our regulatory results.

https://github.com/phase4ground/documents/tree/master/Regulatory

We will be adding more soon. We completed the CJ request, we published the
application (not generally done), and included the final determination
letter in the folder. We did an EAR classification request, which was
successful, and the results are in the folder as well. Currently, we are
waiting for our advisory opinion letter to come back from Commerce.

At that point, all the documents will be in this folder.

The way that these sorts of requests work is to ask for regulatory relief
for a specific product or program. ORI results can be cited as part of your
open source space policy, and furthermore can be used as a reference in
filing your own CJ and EAR classification. Please let me know if you use
them, need example policies, or want to collaborate in filing more
requests. Building a body of work is a powerful approach to any regulatory
problem. We have spearheaded formal use of the open-source carve outs that
already exist in ITAR/EAR, but just as in the commercial sector, building a
"portfolio" of successful open source results reduces volunteer and
participant risk with every new filing.

My phone number is 858 229 3399, text ok.

-Michelle W5NYV
CEO ORI




On Mon, May 3, 2021 at 8:27 AM Betts, Byron E. <bbetts at caltech.edu> wrote:

> Dear Ms. Thompson,
>
>
>
> Caltech is in the planning stages of creating a spacecraft Mission/Science
> operations center on campus.  Would it be possible to obtain a copy of the
> CJ-0003120-Submittal Letter drafted by Thomsen and Burke LLP?  The current
> ITAR/EAR regulations will possibly result in restrictions on our MOC/SOC
> limiting access to US persons only, or impose licensing requirements that
> would essentially have the same result.  If an “Open-Source” approach to
> these activities would allow us to limit these restrictions it would result
> in a much more open and inclusive learning environment.
>
>
>
> Best regards and 73
>
> Byron
>
> *Byron Betts PE (KM6RHX)*
>
> Export Compliance Technical Specialist
>
> MC 272-6
>
>  *Caltech* | *caltech.edu* <http://www.caltech.edu/>
> E: bbetts at caltech.edu *| * *| *C: (661) 547-6982
> Visit us at http://export@caltech.edu <http://www.caltech.edu/>
>
>
>
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