The U.S. Department of Commerce (DoC) Bureau of Industry and Security (BIS) surprised industry with an interim final rule posted this past weekend. Effective more-or-less immediately, on January 6, 2020, the rule, tediously titled “Addition of Software Specially Designed To Automate the Analysis of Geospatial Imagery to the Export Control Classification Number 0Y521 Series,” appears familiar to anyone who has worked with ITAR in the space industry.

And like the laws surrounding ITAR, the rule here is knee-jerk. Also, it’s akin to closing the barn door and setting fire to the barn after the whole herd of horses ran out.

We understand that many senior officials with the DoC were uninformed of this pending rule. However, someone (or more likely, many someones), decided that software created to automatically conduct analyses of geospatial imagery (and something called point clouds) … Read the rest