1. COMSTAC: EXPORT CONTROLS WORKING GROUP COMSTAC: EXPORT CONTROLS WORKING GROUP May 11, 2012

2. Where we left off…

3. Not Just Virgin Territory

4. 1248 Report  Risk Assessment of United States Space Export Control Policy (specifically removing satellites and related components from the USML)  Determined that COMSATS that do not contain classified components or exceed certain performance parameters can be administered under the CCL without harming national security  Recommended returning to the President authority to determine the export control jurisdictional status of satellites and related items

5. Reasons for Pessimism  Lack of time  Priority (election year, etc.) (election year, etc.)  Committee Rivalry  Irrational Resistance

6. Reasons for Optimism  NDAA has to pass  Retirements  Positive Impact of the 1248 Report 1248 Report  It’s the right thing to do

7. Finding #1 COMSTAC members strongly support the recommendations of the Section 1248 report, including that Congress must return to the President authority to determine the export control jurisdictional status of satellites and related items.

8. Finding #2 The COMSTAC supports the Directorate of Defense Trade Controls decision to deem ‘passenger [spaceflight participant] participation in space travel’ as a non- licensable activity under the ITAR via responses to Commodity Jurisdiction requests and the Section 1248 report. The COMSTAC supports the Directorate of Defense Trade Controls decision to deem ‘passenger [spaceflight participant] participation in space travel’ as a non- licensable activity under the ITAR via responses to Commodity Jurisdiction requests and the Section 1248 report.

9. Finding #3 COMSTAC members strongly support the transfer of suborbital human spacecraft to the Commerce Control List.

10. Contact Info E-mail: mgold@bigelowaerospace.com mgold@bigelowaerospace.com Phone: (240) 235-6016