Re: [time-nuts] Atomic clocks and Wassenaar agreement

[Bernd Neubig]

Hi Attila,

the paragraph applies also to low phase noise crystal oscillators.
The limiting equation for phase noise stated in that section 3. A. 1. b. 10 
reads as follows:
L(F) > -(126+20log10F-20log10f) for 10 Hz ≤ F ≤ 10 kHz
With f being the carrier frequency in MHz and F the offset in Hz

In the attachment I have added a chart showing the limits for 10 MHz and 100 
MHz.
This equation is rather arbitrary and not conclusive, because it assumes a 
slope of the PN curve close to carrier of -20 dB/decade, while in reality it is 
-30 dB/decade. This means that even if you do not touch the limits very close 
to carrier, the real phase noise may intersect at larger offsets. If you look 
at the numbers, you can easily find that not only a few best in class OCXO will 
touch or crosss the limits, but many normal "industrial state of the art" OCXO 
nowadays will...
I have no idea, where I could place my arguments to advocate a change of this 
unrealistic regulation.

Indeed it may be good that not all customs officers are able (or have the time) 
to solve that equation.

Best regards
Bernd
DK1Ag



-Ursprüngliche Nachricht-
Von: time-nuts [mailto:time-nuts-boun...@febo.com] Im Auftrag von Attila Kinali
Gesendet: Sonntag, 20. August 2017 12:08
An: Discussion of precise time and frequency measurement <time-nuts@febo.com>
Betreff: [time-nuts] Atomic clocks and Wassenaar agreement

On Sun, 20 Aug 2017 08:50:59 +
"Poul-Henning Kamp" <p...@phk.freebsd.dk> wrote:


> >Bob your right its interesting that the sales locations are in China 
> >and India. Perhaps a larger opportunity for a RB reference today.
> 
> Could be because hydrogen masers are dual-use under the Waasenaar Arrangement 
> ?

As far as I can tell, there is no explicit mention of atomic clocks. But the 
list of dual use electronics is long and broad.
E.g. Section 3. A. 1. b. 10. covers basically all low noise frequency sources. 
Including just a simple low-noise XO.

Does anyone have more specific knowledge?

Attila Kinali

--
You know, the very powerful and the very stupid have one thing in common.
They don't alters their views to fit the facts, they alter the facts to fit the 
views, which can be uncomfortable if you happen to be one of the facts that 
needs altering.  -- The Doctor ___
time-nuts mailing list -- time-nuts@febo.com To unsubscribe, go to 
https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.
___
time-nuts mailing list -- time-nuts@febo.com
To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.

Re: [time-nuts] Atomic clocks and Wassenaar agreement

[jimlux]

On 8/20/17 9:15 AM, Attila Kinali wrote:

On Sun, 20 Aug 2017 11:28:17 +
"Poul-Henning Kamp"  wrote:



As far as I can tell, there is no explicit mention of atomic
clocks.


There very much is:


Oops... missed that one. Sorry about that.
(I wonder how. I am sure I searched for "atomic")


But the list of dual use electronics is long and broad.
E.g. Section 3. A. 1. b. 10. covers basically all low noise
frequency sources. Including just a simple low-noise XO.
Does anyone have more specific knowledge?


Knowledge ?  No.  Some Experience ?  Yes.


My condolences. I only had to deal with ITAR as a buyer once.
That was enough for a lifetime.


The people who wrote the list very much know why they put things
onto it, and in the process of narrowly tailoring the restrictions
often give more away than they probably should.



Yes. I skimmed through some of the electronic restrictions.
Given that a lot of SDR can be used in one of those ways listed,
it's damn easy to "accidentally" build something that has export
restrictions on it.


[1] I've always wondered about that rule and I suspect it is a
mistake.  Knowing who is on this list, I imagine that the next
revision will read the far more sensible: "Non-rubidium *or*
having ..."


Yes, singling out Rubidium is kind of weird.

Any guesses as for why?





I have some experience in this area - in the US it's the USML (United 
States Muntions List) that determines what is subject to controls under 
ITAR - that's run by the Department of State.  Then there's the 
Controlled Commodities List which features in the EAR run by the 
Department of Commerce.  The two groups have different objectives.


ITAR tends to focus a lot on "knowledge" as well as "things" - EAR is 
more about "things"  - A component might be export controlled, but the 
data sheet isn't.


Also, there's a huge difference between "speculating" that something is 
so and "knowing" that something is so, in terms of design information or 
performance.  If you're interested in building, say, a guidance system 
for a ICBM - performance in a UAV might be a good indication that it 
would work, but there's no substitute for test in a real missile.



A few years ago, there was a big rewriting of the USML - to make it more 
specific in terms of capabilities, etc. rather than fuzzy - folks 
seeking export licenses were frustrated by the previous more generic 
language (often including the phrase "designed for military purposes" or 
similar).   For spacecraft, it got a lot more liberal - before "if it 
goes into space, it's ITAR" was the basic rule - afterwards, it's more 
about "does it tell someone how to make it, design it, etc." and a lot 
more things fell into more of a dual use (EAR is more about dual use) 
bucket - just because you're using 6-32 machine screws or 100MHz OCXOs 
on your spacecraft doesn't make ALL 6-32 screws or the same OCXO in 
other uses export controlled.


This was a godsend for us cobbling together breadboards for things that 
might someday go into space in a different form - before, if the work 
was funded by a "space technology development" sort of bucket, the 
evaluators would tend to say: yeah, that's export controlled, because 
the "design intent" is for an eventual space application. That made it 
hard to publish papers and reports openly as well as other tedious 
administrative aspects - you can't put export controlled information 
just anywhere or transmit it any old way, etc.



 That process, of course, gets input from both industry and government, 
and is not perfect.  But if you are a maker of a specific widget, you 
could weigh in on the rule making process and explain why YOUR 
particular widget's technology should or should not be controlled. 
"should not" if you want to sell it overseas; "should" if you want to 
avoid competition.


And then, there's a sort of continuing revision process - as each new 
license application (or commodity jurisdiction (CJ) request) makes its 
way through the system, that folds back to the actual rules or, more 
importantly, their interpretation.


ALso as "work-arounds" for technology become well known, the rules 
gradually change.  A good example is things like selective availability 
and code-less 2 frequency GPS.


There's also well known hacks - a mfr might claims that their parts are 
rad tolerant up to a particular level, even though they're made on a 
process which is well known to be much harder.  To claim that they're 
hard to a higher level would make them subject to ITAR instead of EAR, 
for instance.


Like all regulatory matters, the wheels grind slow and exceedingly fine. 
 MUCH slower than the advance of technology (nothing has really changed 
since you couldn't export pinball machines which had 68000 
microprocessors) and that's something you live with.


And then, there's also just plain old typographical screwups - I'm sure 
there are rules where it should be AND instead of OR, or 

Re: [time-nuts] Atomic clocks and Wassenaar agreement

[Poul-Henning Kamp]

In message <20170820181537.a7a834e32b848ea3f63d3...@kinali.ch>, Attila Kinali 
writes:
>On Sun, 20 Aug 2017 11:28:17 +

>> [1] I've always wondered about that rule and I suspect it is a
>> mistake.  Knowing who is on this list, I imagine that the next
>> revision will read the far more sensible: "Non-rubidium *or*
>> having ..."
>
>Yes, singling out Rubidium is kind of weird.

I see that rule as a way to carve out telco-class rubidiums, and
that's why I think "or" would make much more sense than "and".

-- 
Poul-Henning Kamp   | UNIX since Zilog Zeus 3.20
p...@freebsd.org | TCP/IP since RFC 956
FreeBSD committer   | BSD since 4.3-tahoe
Never attribute to malice what can adequately be explained by incompetence.
___
time-nuts mailing list -- time-nuts@febo.com
To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.

Re: [time-nuts] Atomic clocks and Wassenaar agreement

[Attila Kinali]

On Sun, 20 Aug 2017 11:28:17 +
"Poul-Henning Kamp"  wrote:

> >
> >As far as I can tell, there is no explicit mention of atomic
> >clocks.
> 
> There very much is:

Oops... missed that one. Sorry about that.
(I wonder how. I am sure I searched for "atomic")
 
> >But the list of dual use electronics is long and broad.
> >E.g. Section 3. A. 1. b. 10. covers basically all low noise
> >frequency sources. Including just a simple low-noise XO.
> >Does anyone have more specific knowledge?
> 
> Knowledge ?  No.  Some Experience ?  Yes.

My condolences. I only had to deal with ITAR as a buyer once.
That was enough for a lifetime.

> The people who wrote the list very much know why they put things
> onto it, and in the process of narrowly tailoring the restrictions
> often give more away than they probably should.


Yes. I skimmed through some of the electronic restrictions.
Given that a lot of SDR can be used in one of those ways listed,
it's damn easy to "accidentally" build something that has export
restrictions on it. 

> [1] I've always wondered about that rule and I suspect it is a
> mistake.  Knowing who is on this list, I imagine that the next
> revision will read the far more sensible: "Non-rubidium *or*
> having ..."

Yes, singling out Rubidium is kind of weird.

Any guesses as for why?

Attila Kinali

-- 
You know, the very powerful and the very stupid have one thing in common.
They don't alters their views to fit the facts, they alter the facts to
fit the views, which can be uncomfortable if you happen to be one of the
facts that needs altering.  -- The Doctor
___
time-nuts mailing list -- time-nuts@febo.com
To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.

Re: [time-nuts] Atomic clocks and Wassenaar agreement

[Poul-Henning Kamp]

In message <20170820120742.c48c69758cc9fa4856ab0...@kinali.ch>, Attila Kinali 
writes:
>On Sun, 20 Aug 2017 08:50:59 +
>"Poul-Henning Kamp"  wrote:
>
>> >Bob your right its interesting that the sales locations are in China and
>> >India. Perhaps a larger opportunity for a RB reference today.
>> 
>> Could be because hydrogen masers are dual-use under the Waasenaar 
>> Arrangement ?
>
>As far as I can tell, there is no explicit mention of atomic
>clocks.

There very much is:

3. A. 2. g. Atomic frequency standards being any of the following:

1. "Space-qualified";

2. Non-rubidium and having a long-term stability less (better) than
   1 x 10 -11 /month; or

3. Non-"space-qualified" and having all of the following:

   a. Being a rubidium standard;

   b. Long-term stability less (better) than 1 x 10 -11 /month; and

   c. Total power consumption of less than 1 Watt;

The product in question drives directly through the loophole in point 2[1]

>But the list of dual use electronics is long and broad.
>E.g. Section 3. A. 1. b. 10. covers basically all low noise
>frequency sources. Including just a simple low-noise XO.
>Does anyone have more specific knowledge?

Knowledge ?  No.  Some Experience ?  Yes.

The people who wrote the list very much know why they put things
onto it, and in the process of narrowly tailoring the restrictions
often give more away than they probably should.

Depending on your hobbies, you can get some pretty interesting
project ideas by reading the list[2].  (3.A.3 anyone ? or
how about 9.B.6 ?)

The civil servants who administer the lists in the foreign ministries
are seldom rocket engineers and will usually administer the list
strictly to the letter, rather than talk to one.

Poul-Henning

[1] I've always wondered about that rule and I suspect it is a
mistake.  Knowing who is on this list, I imagine that the next
revision will read the far more sensible: "Non-rubidium *or*
having ..."

[2] 
http://www.wassenaar.org/wp-content/uploads/2016/12/List-of-Dual-Use-Goods-and-Technologies-and-Munitions-List-Corr.pdf

-- 
Poul-Henning Kamp   | UNIX since Zilog Zeus 3.20
p...@freebsd.org | TCP/IP since RFC 956
FreeBSD committer   | BSD since 4.3-tahoe
Never attribute to malice what can adequately be explained by incompetence.
___
time-nuts mailing list -- time-nuts@febo.com
To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.

[time-nuts] Atomic clocks and Wassenaar agreement

[Attila Kinali]

On Sun, 20 Aug 2017 08:50:59 +
"Poul-Henning Kamp"  wrote:


> >Bob your right its interesting that the sales locations are in China and
> >India. Perhaps a larger opportunity for a RB reference today.
> 
> Could be because hydrogen masers are dual-use under the Waasenaar Arrangement 
> ?

As far as I can tell, there is no explicit mention of atomic
clocks. But the list of dual use electronics is long and broad.
E.g. Section 3. A. 1. b. 10. covers basically all low noise
frequency sources. Including just a simple low-noise XO.

Does anyone have more specific knowledge?

Attila Kinali

-- 
You know, the very powerful and the very stupid have one thing in common.
They don't alters their views to fit the facts, they alter the facts to
fit the views, which can be uncomfortable if you happen to be one of the
facts that needs altering.  -- The Doctor
___
time-nuts mailing list -- time-nuts@febo.com
To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts
and follow the instructions there.