Defense Trade Advisory Group (DTAG)
Category VIII Review
Plenary SessionOctober 20, 2010
• 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)
Defense Trade Advisory Group (DTAG)
Category VIII Review
Questions?