Greetings all!
This is my report to members for the third week of my term on AMSAT-NA Board of Directors.
Here are the major developments and goals.
Non Disclosure Agreements
At day 12, the new members of the board got copies of the Non-Disclosure Agreements (NDAs) that we, according to Joe Spier, President of AMSAT, must sign in order to have access to business communications for AMSAT-NA.
As of today, 21 days into the board term, no provision to sign an acknowledgement of the NDAs with either Spaceflight or Ragnarok Industries has been provided. An acknowledgement letter for existing agreements is an ordinary thing to do with new board members. Usually the agreements are given out ahead of the first day of work for review.
Waiting until the Board Meeting at Symposium to sort this out wastes about a month of time.
Independent legal review of the NDAs has been received.
The Spaceflight NDA appears to still be in effect. The end date is 5 years after any confidential information has been exchanged. For launches in the past, that information rapidly becomes irrelevant, but the agreement is still in force. More importantly for AMSAT-NA, if confidential information has been exchanged about payload failure analysis, then that information goes down a black hole for 5 years. This means publishing anything about lessons learned becomes very hard, unless Spaceflight allows the information or report to be published. Without an exemption, any analysis can only be shared internally among a very small group of people. Members may have to wait 5 more years from today, for example, to find out anything at all. That’s the downside of a secrecy mindset. The upside is obviously when things work out well, the organization gets a successful launch.
Approval for Ragnarak Industries NDA?
There is nothing in any published minutes from AMSAT-NA about the Ragnorak Industries NDA being voted on or approved by the Board of Directors. There is no record of any officer being directed to sign it on behalf of the organization. This needs to be cleared up. Keeping records of agreements is basic business practice.
Are NDAs “wrong”?
No, they are not. Is it fundamentally wrong to keep launch details secret? No. Does it mean that preventable failures and important lessons learned can be kept secret? Yes, it does.
However, for amateur radio and for AMSAT in particular, there are clearly superior alternatives to secret agreements with commercial entities for engineering research and development. Leave the NDAs for launches. In the US, the justification for being licensed amateur radio operators includes things like education and advancement of the radio arts.
Open Source Hardware and Software are a Better Way Forward
Open source hardware and software are a generally better approach than using proprietary solutions for education, advancement of the radio arts, and improvement in the quality of the satellites we build. If something is done in secret, it’s rarely done well. Being able to have the widest possible review for hardware and software designs increases the quality of the work substantially, for the type of work we do.
What is the type of work we do? Relatively small codebases and relatively simple hardware.
“The Coverity Scan Open Source Report, which measures the quality of OSS code, finds that the density of code defects (the number of bugs per 1,000 lines of code) is smaller for OSS than for proprietary software. Interestingly, while small OSS projects have significantly fewer issues than proprietary software projects of comparable size, the quality of large proprietary software projects is higher relative to large OSS projects. Proprietary software companies have well-defined processes and teams of experts to identify and fix bugs, including security vulnerabilities. Meanwhile, large open source projects sometimes lack standardized processes for quality control, sufficient qualified code reviewers, and good inter-team release coordination.”
Quality of Open Source Software: how many eyes are enough?
By Michael M Lokshin, Sardar A. Zari, and David Newsom
24 January 2019
This is just one study that shows measurable advantages for organizations like AMSAT-NA if they take an open source approach.
We have a very powerful part of regulatory law on our side to help us work on open source and public domain communications satellite technology. Proprietary-focused ITAR/EAR regulations are intended to protect commercial entities. They are difficult to comply with and incur real costs for volunteer or amateur organizations like AMSAT-NA.
What Have I Done in the Past to Effect Change?
There were a set of ITAR implementation guidelines, published in January 2018. After studying them, it did not appear that AMSAT-NA was in compliance with the proprietary-focused regulations.
A proposal to AMSAT Board of Directors was made in December 2017 by a group of members, including myself, that provided a path forward to compliance with the proprietary-focused regulations. This was done because the Board refused to discuss taking advantage of the much better path - the public domain carve-outs in ITAR.
Our thinking was “If you can’t make progress on the best solution, at least make sure the organization complies with the secrecy-centric rules.”
Being told to not talk to anyone about anything ever or else scary things will happen does not produce good work in volunteer settings, but if you’re going to go Full Secret, then you better do it right.
A copy of that proposal can be found here:
This was a very distant second choice to complying with the public domain carve-outs in ITAR/EAR, but was proposed because there was no, and is no published ITAR/EAR policy, no compliance officer, no training, and inconsistent guidance for engineering volunteers of AMSAT-NA.
Many months went by without any acknowledgement of this proposal. After asking about the status, Joe Spier told me on the phone that the board had voted it down. This vote does not appear in the published meeting minutes of AMSAT-NA. Why not?
I’m discussing this and showing previous work to prove that serious attempts to improve regulatory compliance at AMSAT-NA have been made by many active participants.
Based on the results of the election, the membership wants the Board of Directors to adopt open source policies for AMSAT.
We should adopt established policies that comply with open source carve-outs and have been looked at by lawyers.
What am I Doing Now to Effect Change?
Here’s the policies from Open Research Institute, Incorporated. ORI was specifically founded for open source amateur radio research and development. The first goal was to become Member Society of AMSAT-NA, providing a way to do a safe and legal open source ground and payload work that would minimally impact AMSAT-NA Incorporated, while strengthening international ties and collaboration. This organization was founded by myself, Ben Hilburn, and Bruce Perens. 501(c)(3) status was granted 6 March 2019.
Open Research Institute has renewed a request to be recognized in the published minutes of AMSAT-NA as a Member Society. Previous requests were either overlooked or ignored. Given the amount of work published by Open Research Institute, the strong regulatory stance, enforced code of conduct, and the amount of published technical work of merit and distinction, the inclusion of Open Research Institute as a Member Society greatly benefits AMSAT-NA. Open Research Institute does not financially benefit from being a Member Society. Being a Member Society increases the level of work required from Open Research Institute.
It is my belief that AMSAT-NA itself should convert to an open source (by default) policy as soon as possible. This would allow substantial and sustained increases in funding, participation, and engineering quality. Failing that, having Open Research Institute as a Member Society is a win for AMSAT-NA
There is no risk-free forward path through regulatory law. Risk reduction is much more achievable through clearly defined public domain carve-out policies than it is with no published policy at all regarding the much more difficult-to-comply-with proprietary-focused ITAR/EAR.
Are you Saying Never Use Companies? Are You Some Kind of Zealot?
No, not at all. I believe that for AMSAT-NA, the default should be open source. It’s a much better regulatory, financial, social, and cultural match for the organization. Open source work done by AMSAT-NA or others can then be licensed to companies to improve upon or productize, achieving even more quality and improvement. A rising tide lifts all boats. There’s proof all around us of the economic benefits and quality improvements of open source. Open source hardware and software has a way of supercharging commercial activity.
As to being a zealot, I am a paid employee of a telecommunications company. We use and support open source whenever possible, but I have zero problem using proprietary solutions when they give the best business results. I have worked for large engineering firms like Qualcomm that made all sorts of money building massive portfolios of intellectual property, and then ruthlessly exploiting it. My conscience is completely clear when it comes to working for proprietary companies.
On the other hand, I have volunteered for, lead, and produced a wide variety of open source projects and events. When I say AMSAT-NA is best served by adopting open source policies, then I speak from experience.
What’s a Specific Example?
The open source attitude determination and control system from Libre Space, used successfully on UPSat, is a clear and compelling example of what AMSAT-NA should be building upon. Libre Space has documented and published this system. It is free to use.
Libre Space engineers have ideas on how to improve it and what they’d like to do next.
This system was suggested to AMSAT-NA engineering. Outreach from Libre Space was attempted. My goal with elevating and highlighting this work is to make it very clear there are real alternatives.
This isn’t the only open source project that AMSAT-NA has been informed about. In January 2018, I represented AMSAT at IEEE Radio and Wireless Week in Anaheim, CA. I did a technology demonstration and spoke during the Small Satellite track.
Full text of that report can be found here: https://github.com/phase4ground/documents/blob/master/Management/Weekly_Engineering_Reports/20180119_Phase4_weekly_report.txt
A relevant excerpt: “So all of this was really exciting to me, because it means that the tasks of attitude control, power distribution, and communications are all successfully being done and we can do it too. If we become familiar with this University project, and others like it, and build on it, then we can be way further ahead on amateur spacecraft design than we thought we were at the GOLF meeting at Symposium.”
Some of the work referenced here was built and successfully launched on the UWE Sat program. They’re up to UWE-4. Here’s the status page. https://space.skyrocket.de/doc_sdat/uwe-4.htm
I spoke with the professor presenting about UWE program for quite a while. There was great potential for collaboration and he gave me several papers to start with. I submitted the report and offered to help get some collaboration going so that GOLF could take full advantage of things that were way ahead of where we were, and would allow us to focus a lot more energy on the communications payload.
The response from AMSAT-NA engineering was silence. No interest in the new contacts. No interest in setting up a collaboration. I was disappointed, but did not stop working. I wanted to understand the options and who was doing what in current technology. I wanted AMSAT-NA to take advantage of it.
I’ve followed UWE through ResearchGate ever since.
The Phase 4 Space project proposal directly benefits from knowing about and being willing to use the work done by others in the open source community. GOLF should too.
More soon!
-Michelle W5NYV
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