After reading this answer by someone knowledgeable in the field, I realized that I still don't understand even a little bit what International Traffic in Arms Regulations (ITAR) (and its cousins) does and doesn't say what various people can or can't do, and so far I haven't found the ITAR-tl;dr.

edit: I'm getting rid of the hypothetical scenario and adjusting the question to make sure it doesn't read like a request for legal advice.

I've given myself an exercise - launch to orbit in 20 lines of python. It's along the lines of A Neural Network in 11 lines of Python; Part 1 and Part 2. (Part 2 is 13 lines, a clear case of mission creep.)

This is purely a deterministic model. ISP is constant or a simple function, thrust is on or off, Earth's atmosphere rotates as a rigid body, drag coefficient is brontosaurus shaped when plotted vs Mach number, atmosphere is isothermal with scale height behavior, etc. You launch thousands of times and use gradient descent to eventually find an orbit. Only SciPy and NumPy are allowed. I think fifty lines is realistic and probably straightforward, but it could be shorter if made ugly and/or opaque.

Now, if I allow for realistic wind, or engine fluctuations, or mechanical noise in my thrust vectoring, or turbulence, or other things, then I need to add some simulated measurements (e.g. simulated inertial sensors or GPS) and then feedback, and also raise my limit to a few hundred lines of python and/or import other python packages within the Anaconda distribution.

I am wondering if is there any way to tell when a US citizen sitting with their laptop in the US might be starting to cross into potential ITAR territory? Is it when feedback is introduced? Or when Kalman filtering is added? Or is it only when it gets out of the laptop and on to the internet?

I am not asking for nor do I want a legal opinion. But are there any guidelines, rules of thumb, articles in space related magazines, blogs... anything where one could get some kind of gist of where the gray zone begins to darken noticeably?

I see a lot of cautions and warnings peppered in SXSE, but they mostly seemed nuanced for those who should already know but a reminder now an then can't hurt. In this case I'm asking from a responsible noob's point of view.

  • $\begingroup$ Should ask a lawyer. $\endgroup$
    – gerrit
    Apr 11 '17 at 10:49
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    $\begingroup$ @gerrit If I have/had it shouldn't prevent me from asking for a tl;dr here in SXSE as well. $\endgroup$
    – uhoh
    Apr 11 '17 at 10:57
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    $\begingroup$ One problem with ITAR is that because it's difficult to determine if something is covered, agencies play it safe and say everything is. Former flight director and head of the shuttle program Wayne Hale just mentioned in his blog that as a retiree he is denied access to all NASA archives for this very reason. $\endgroup$ Apr 11 '17 at 11:06
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    $\begingroup$ Just to add to what the others have said, it's not so much that the question can't be answered so you should ask a lawyer, as it is that the answer is actually "Ask a lawyer". You can view the ITAR regulations online yourself, but obviously that doesn't quite give you the condensed perspective you were hoping for. Only a lawyer can accurately tell you how it will impact you. $\endgroup$
    – called2voyage
    Apr 11 '17 at 15:39
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    $\begingroup$ @uhoh gov-relations.com/itar "Some examples include; an export license (DSP-5), exchanging technical emails or teaching how to repair an ITAR-covered item which requires a Technical Assistance Agreement (TAA), and allowing a foreign company to manufacture an item requires a Manufacturing License Agreement (MLA)." What exactly allows a foreign company to manufacture an item? As David said, you could even try to wrap F=ma into this. The only advice with no legal repercussions is stay out of rockets. $\endgroup$
    – called2voyage
    Apr 11 '17 at 20:11

With the exception of model rockets made of paper, wood, or breakable plastic, that are passively stabilized, that have low thrust and low delta V, and that do not have guidance software, launch vehicles fall under ITAR regulations. The regulations are now much more relaxed once the launch vehicle has achieved its goal and placed its payload into orbit. Certain satellites with limited sensor/effector capabilities fall under the realm of the Export Administration Regulations levied by the Commerce Department rather than the realm of the International Traffic in Arms Regulations levied by the State Department. Satellites with even less capabilities (e.g., some cubesats) are pretty much regulation-free.

Whether simulating a launch vehicle of interest might trigger the interest of the State Department (ITAR), the Commerce Department (EAR), or the Transportation Department (FAA regulations) -- I am not a lawyer. It's important to keep in mind that F = ma would be classified TS/NOFORN (top secret / no foreign nationals) if the DoD had its druthers.

From what I've seen, the boundary is rather fuzzy. NASA has publicly released some parts of it's core Flight Executive, some parts of it's core Flight System, and all of it's Trick Simulation Environment as open source. These are highly capable tools. On the other hand, some NASA software that kinda-sorta provides the ability to simulate trajectories and perturbations to those trajectories remains subject to ITAR.

Full disclosure: I've written a good chunk of the software used at the NASA Johnson Space Center to model trajectories and perturbations thereof. Much of the software that I have written has been deemed to fall under ITAR. On the other hand, I've written what is to me significantly more complex software that apparently is not subject to ITAR. I am not a lawyer, so I'm rather clueless with regard to the distinction.

  • $\begingroup$ I've adjusted the question, but I believe that the effect on your answer is neutral or slightly positive. $\endgroup$
    – uhoh
    Apr 11 '17 at 13:45
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    $\begingroup$ As far as I can tell working here (GRC), whether something is ITAR or not depends on who's paying for it :P... $\endgroup$
    – Aaron
    Apr 11 '17 at 20:57
  • $\begingroup$ @Aaron It's why I included "and it's cousins". While ITAR proper may apply to the export of products, it may have distant cousins, aunts, uncles, in-laws, or even an evil twin (1, 2) that still applies to someone just doing stuff on their own sitting in a coffee shop. In fact these days there is probably a branch of government specifically in charge of keeping an eye on people doing stuff on their own in a coffee shop! $\endgroup$
    – uhoh
    Apr 11 '17 at 23:15
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    $\begingroup$ @uhoh I've never worked with anything strictly classified, rather SBU (sensitive but unclassified). The really boring truth of the matter is that all of it was so because of NDAs with the private companies that were paying NASA to do research and testing for them. Very little is regulated because of national security. Most restrictions stem from money changing hands... $\endgroup$
    – Aaron
    Apr 12 '17 at 4:05
  • $\begingroup$ ...keeping in mind that NASA is no longer officially connected to DoD, so we don't interact with the super sensitive stuff as frequently. (so my experience is almost definitely biased) $\endgroup$
    – Aaron
    Apr 12 '17 at 4:23

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