Altius Comments to the EAR NPRM

Altius Bulldog Satellite Servicer

Here are some comments that I prepared on behalf of Altius for the Export Administration Regulations (EAR) Notice of Proposed Rule Making (NPRM) I’ve been discussing on Selenian Boondocks (here, here, and here). This NPRM proposes how the Department of Commerce would handle spacecraft, spacecraft components, and spacecraft technologies that the State Department proposes to move off of the US Munitions List (ITAR) onto the Commerce Control List (EAR). I’m not an expert in Export Control law, but these comments were based on my understanding, personal research, and conversations with other export control lawyers–consider yourself caveat emptor’d. I wanted to provide these to everyone because even though the due date for comments closes on Monday (July 8th), there’s still time to submit comments, and I also hoped to solicit feedback from others who have more experience with Export Control on these suggested tweaks to their proposed rule.

Here’s the link to our formal comments: Signed_Altius_RIN-0694-AF87_Comments

I hope to have a similar set of comments for the USML Category XV Revision NPRM before I go to bed tomorrow.