ESRA was alerted to a very critical change to US Federal ITAR rules that would directly affect future competitions. Specifically, prohibiting the ability of any international students to purchase, transport or even interact with amateur high power rocket systems weighing more than 5lbs in the US.

ESRA as well as many other corporations, groups and individuals have already commented on these proposed changes.  We are asking for our student participants, university officials and others to get involved and let your voices be heard!  You do not have to be a US Citizen to add your comment.

Instructions to comment:

  1. Go to https://www.regulations.gov/document/DOS-2024-0035-0002
  2. Click the "Comment" button in the upper left
  3. Place the comment text (below) in the comment box. Individuals are encourage to customize and expand for their specific circumstances
  4. Complete the remaining identity fields and reCAPTCHA
  5. Press Submit Comment button
    Done!

The absolute submission deadline is 11:59 PM Eastern Time (Washington DC time), tomorrow 23 December 2024. 

 

Please consider posting the following into the Comment section of the form:

As a student participant in the Intercollegiate Rocket Engineering Competition (IREC), I urge the Department of State to revise parts of the proposed rule to better support U.S. universities and international educational collaboration while maintaining appropriate controls. IREC is a global competition fostering the next generation of aerospace leaders through hands-on experience in designing and launching amateur rockets. The proposed rule, as written, would impose significant new burdens that could limit U.S. educational opportunities and international participation, without advancing U.S. critical military advantages. Specifically, I request the following changes: 

To the definition of Amateur Rocket: 

  1. Materials: Explicitly permit commonly used, non-sensitive materials like carbon fiber and composite materials to align with modern technology. 
  2. Active Controls: Replace with the term "Targeting Functions" to differentiate from academic controls terminology. Clarify that simple altitude control mechanisms, such as airbrakes, are not targeting functions and should remain uncontrolled. 
  3. Propellant Mass Limit: Delete the 5 pound propellant mass limit. This is duplicative, yet significantly more restrictive, than the 40,960 Ns total impulse limit already included. This clause significantly increases the USML's scope of control compared to today's regulations. 

To the definition of Amateur Rocket Motor: 

  1. Propellant Mass: Replace the proposed 5-pound propellant mass with a total impulse limit of 40,960 Ns, which is already a widely recognized performance standard. If a propellant mass limit must be retained, increase it to 50 pounds to align with existing commercial products of similar impulse. 
  2. NFPA Certification: Delete reference to NFPA Certification. This consumer safety standard has no bearing on export control, and invoking it controls all university research rocket motors, no matter how small. 

Without these revisions, the proposed rule risks stifling innovation, burdening educational institutions, and discouraging student participation in programs that inspire future aerospace leaders. By making these changes, the Department can ensure that the proposed rule supports safe, educational rocketry while maintaining U.S. critical military advantages. Thank you for considering this feedback.