Intended to stop American technology falling into enemy hands, restrictions on military-grade chips can be a headache for non-US space organisations.
Satellite manufacturers are at the beginning of a decade-long boom, according to Paris-based Euroconsult's 12th World Market Survey. It expects the period to 2018 to see 50 per cent more craft hurled into Earth orbit than in the preceding 10 years, some 1,185 objects in total. More hardware will go into the larger geostationary satellites as communications companies try to pack in more channels and bandwidth.
As component suppliers to the space industry, companies such as Actel and Xilinx aim to benefit from this upsurge in two ways: through the increase in manufacturing and from a technological shift.
'It's big in Europe, America and India. The satellite business is a booming business - all sorts of satellites, whether for Earth monitoring, telecom or other applications. This has been our biggest year to date,' says Sharon Blades, Actel's senior regional sales manager for northern Europe.
The technological shift is taking the market away from custom logic or application-specific integrated circuits (ASICs) towards programmable and reprogrammable devices, most notably the FPGAs (field programmable gate arrays) made by both chip companies.
ASICs offer higher logic densities and lower costs at higher volumes, but demand serious upfront investment - known as non-recurrent engineering (NRE) - to make the masks that define the devices' functions during manufacturing. 'And customers don't want to commit to NREs if they don't have to,' says Blades.
Xilinx recently launched FPGAs for the aerospace sector. Amit Dhir, senior director of its aerospace, defence and high-performance computing business, says the attractions of programmable devices are not just about cost: 'They allow customers to make changes right up to launch. They can get to market much quicker.'
However, this migration from ASIC to FPGA is not entirely straightforward for non-US satellite designers. Most military and space ASIC suppliers have been based in the US, although there are some headquartered elsewhere. By contrast, all the major FPGA suppliers are US companies, which means their spaceborne parts must be checked and sometimes explicitly approved for export under the US International Traffic in Arms Regulations (ITAR). If a part is protected by ITAR, much information about the technologies it contains is restricted to US citizens unless the Department of State grants an exemption.
The European Space Agency (ESA) has complained that the regulations further complicate project management. Wolfgang Veith, ESA's head of product assurance and safety, says: 'It increases the risk, both programmatic and technological. It's programmatic risk in the sense that it inevitably leads to extended procurement times. And the lifecycle of each component must be tracked to a large level of detail, from design to integration to testing to launch.'
ESA projects, by their nature, involve multiple subcontractors from multiple nations. A unit may be designed in Sweden, shipped to a contractor in the UK, tested in France, and launched in Kazakhstan. 'And for every single event, the [ITAR] application needs to include all the details and geographical locations,' Veith says.
'Often, we don't know where testing or launch will be performed. Launch could be at one out of three or four possible sites. Still, all the different options must be included because if anything changes, you have to go back and reapply.'
Restricted access to US technology makes failure analysis more difficult. 'With European components, we have complete traceability and visibility. We have a deep insight,' Veith says. 'But that is not the case with US components. We are very often denied the detailed knowledge that we require. Generally, this is not a problem but if something goes wrong then it can be.'
ESA has therefore decided to reduce its dependence on some US-created components even if development costs increase. Private contractors are looking at the export benefits in ITAR-free satellites, particularly if their potential customers are in countries such as China, where the US still has major technology transfer worries.
The Obama administration is aware of the economic loss this represents. Robert Gates, its Defence Secretary, said in April: 'Some European satellite manufacturers even market their products as not being subject to US export controls, thus drawing overseas not only potential customers but some of the best scientists and engineers as well.
'At the same time, onerous and complicated restrictions too often fail to prevent weapons and technologies from going places they shouldn't. They only incentivise more creative circumvention strategies, on the part of foreign companies as well as countries that do not have our best interests at heart.'
Those concerns have not stopped the extension of ITAR to more and more components in the post-September 11 era, and a still greater frustration is the degree to which it has become a moving target. 'The regulations are becoming stricter over time. You could start with a component that is not ITAR-listed, then it is put on the list,' says Veith. 'So you have to reapply for ITAR compliance, and you can't predict the results of that.'
Actel even found itself in a situation where some FPGAs were taken off the ITAR register only to be later put back on it. 'We have had grey areas where some parts were shipped before they went back onto ITAR. To ship them again, we had to get approval,' says Blades.
ESA has launched initiatives to reduce its dependence on ITAR-covered components. Some are relatively specific. The agency's Deep Sub-Micron project was launched in 2008 to develop an ASIC technology based on STMicroelectronics' 65nm chip manufacturing process (the company is headquartered in Geneva, Switzerland) and it is also fostering development of ITAR-free microprocessors and propulsion systems.
However, ESA's most wide-ranging ITAR-free scheme aims to increase the use of European components in electronics generally. 'This has been pretty successful,' Veith claims. 'When we release a request to tender, there is typically a statement that calls for the supplier to reduce the number of ITAR-listed parts. We have a European preferred-parts list. We are now reaching 50 per cent for parts coming from Europe as a very rough ballpark figure.'
The growing role played by nations other than the US in the commercial space sector is also helping to increase the availability of non-ITAR components. Veith says ESA now has an agreement with its Japanese equivalent, JAXA, through which the agencies sell each other parts 'without a lot of bureaucratic overhead'.
The vendors are, in public, relatively phlegmatic. 'Most customers don't like ITAR. But they put up with it,' says Actel's Blades. 'If it's a technology they need, they will use it. They would prefer not to. They look at other vendors where the technology is non-ITAR. But, typically, the best technology is covered by ITAR.'
For its space-ready FPGAs, Dhir says Xilinx was able to run an early-access programme that included international customers, but says: 'There are countries out there who don't want to be burdened by ITAR. They don't want to report to the US Department of State.'
One country where ITAR is especially unwelcome is Israel. 'The main reason is commercial information. They don't want to disclose what they have to the US government. They feel that they are disclosing their technology to the marketplace,' says Blades.
The ESA will not entirely rule out ITAR-listed parts, and acknowledges some efficiencies can be gained by using them. 'But the reality is that for many components we have a European source and for those that don't ITAR so far has not been a total showstopper. It's a headache and a bother and it increases our risks, but it does not mean the components are not available to us,' Veith says.
'But if we can avoid ITAR, we will.'