Defense Trade Advisory Group (DTAG) Category VIII Review Plenary Session October 20, 2010
Dec 16, 2015
• Bryon Angvall, The Boeing Company• Dave Bowman, Arvin Meritor• David Isenberg, Independent Analyst• Peter Jordan, United Technologies Corporation • Lawrence Keane, National Shooting Sports Foundation• Dale Rill, Honeywell International Inc. • Janet Rishel, Bell Helicopter• Jay Rodriguez, MAC Aerospace Corporation• Bruce Weinrod, Woodrow Wilson International Center
for Scholars
CAT VIII Working Group Members
2
General Comments
• Certain aircraft platform jurisdiction separate from military systems on the aircraft• Aircraft not subject to independent controls on the systems• Aircraft can be separately exported/valued from systems exported
• Item specific controls for all cargo/transport/utility designated aircraft (e.g., C-40)
• Allows support of EAR (dual use) platform to be EAR services while support to USML systems on the aircraft would be defense services
General Comments (continued)
• If military requirement similar to FAA mandated requirement for commercial aircraft, then related systems should be considered EAR • Inert fuel tanks (requirement to inert center fuel tanks)• Basic ballistic protection (cockpit doors, pilot seats, rotor blades)
• Advanced military armor still controlled under USML• Night Vision used in medevac, search and rescue, offshore oil
• Night Vision Goggle compatible for aircraft is EAR• FAA Technical Standard Order (TSO) C164 for Night Vision Goggles used on Emergency Medical Service Helicopters.
• Night Vision compliant is USML • NVIS compliant documented in MIL SPEC MIL-L-85762A
• More stringent requirements – Chromaticity (color) requirement NVIS A or B, Spectral Radiance, Sunlight readability (contrast ratio)
General Comments (continued)
• Certain types of military aircraft based on age should be removed from USML • Specific age (50 years since production) • Specific year cutoff (1960)• Applied to aircraft models (F-111A vs. F-111D)
• Obsolete aircraft platforms out of production and not in US Government inventory should not be controlled as a defense article (F-86 Saber)
• Depot level maintenance – ability to do maintenance would follow control level of item (e.g., aircraft platform but not on high tier military system on the platform)
• 17(c) clarification would remain in effect
Cargo/Transport/Utility Aircraft
• Aircraft functionality that is not military unique does not need to be controlled under USML• Short field takeoff• Heavy load/large capacity• Ballistic protection• Crash tolerance
• Aircraft with military unique functionality / systems controlled under USML (Tier 3)• Air-to-air refueling • Advance airdrop systems• Defensive systems
Fighter/Bomber/Attack Aircraft
• Aircraft for deploying WMD or containing Tier 1 military systems (Tier 1)
• General fighter/bomber/attack/specialized (e.g., anti-submarine warfare) aircraft (Tier 2)
• Trainer aircraft that do not have other controlled systems (e.g., afterburners) not capable of combat should not be controlled or if controlled, be done so Tier 3
Developmental Aircraft
• Developmental aircraft/engine would not be a separate item but technology on the aircraft /engine would be compared to control list to determine level of control• Fighter technology demonstrator controlled as fighter (Tier 1 or 2)
Inertial Navigation Systems
• Consider combining Cat VIII(e) with Cat XII to cover all military inertial in one category
• Export control rationale:– Standard INS less military attributes (e.g., SAASM/GPS, space qualified) subject to dual use controls
– Defense article / dual use item based upon unique functional attributes
– Tiered controls for product and technology based on performance capability level
Unmanned Air Vehicles (UAVs)
• Prevalent in both military and in non military use• Control UAVs at level of similar manned aircraft• Attack UAV on USML (Tier 1 or 2)• Utility UAVs (Tier 3 or not controlled)
Engines General
• Aero gas turbine engine propulsion systems with military unique attributes controlled on USML (Tier 2)• Thrust augmentation/afterburner• Thrust/exhaust nozzle vectoring• Low observable structures/coatings
• Aero gas turbine engines without military unique attributes controlled under EAR• Turboprop, turbo shaft and reciprocating engines• Non-propulsion engines (Auxiliary Power Units)
• Engine controls system hardware and software that enable military unique attributes controlled on USML (Tier 2)
Commercial Common & Military Unique Items
CommonFan Disk, Hub and
Blades
CommonInlet Case and Vanes;
Sound Suppression and Containment of
Blades Failures
MilitaryLow Observable Inlet
Coatings, Paints & Structures
MilitaryLow Observable Exhaust
Coatings, Paints & Structures
CommonLow Pressure Compressor
Technology & Materials
CommonHigh Pressure Compressor Technology & Materials;
Integrated Blades & Rotors; Variable Vane & Bleed Systems
CommonFuel Delivery & Combustor
Systems Technology & Materials; Coatings
CommonTurbine Blades & Vanes;
Materials; Cooling; Coatings; Temperatures & Turbine
Exhaust Systems
MilitaryThrust Augmentation
(Afterburner only); Thrust Vectoring; Exhaust Nozzle Vectoring &
Afterburner Systems
CommonEngine Controls (FADEC,
DEEC); Fuel Pumps; Accessory Gearbox
Assemblies)
MilitaryEngine Control Enclosures Hardened for
EMP/RCBN Exposure; Software to Control Military Unique Attributes
Parts and Components
• Aircraft/engine parts and components with same functionality as similar items on commercial aircraft under EAR or USML Tier 3 • Parts – Nuts, bolts, screws, stringers, brackets, clamps, fasteners, seals, O rings, gaskets, wire bundles (EAR99)
• Components/Assemblies – landing gear, aileron, flaps, slats, rotor blades, propellers, hydraulic systems, electric power systems, air management systems, fire protection/detection (EAR99 or EAR Tier 3)
• Major Assemblies – wings, fuselage (USML Tier 3)• Unique military attribute/technology components controlled
under USML (e.g., nozzle vectoring/afterburner systems, LO components) (USML Tier 2)