Where Industry and Security Intersect
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Washington, DC 20230
31 January 2006
- The SITAC meeting was held at the Department of Commerce in Room 3884 from 9:30am to 12:30 pm. The meeting began with a brief introduction of the attendees. Mr. Goodrich (Fluke Corporation formerly Infrared Solutions Inc.), chair of the SITAC, provided several handouts including an agenda, proposed Wassenaar changes, and the membership roster for the meeting.
- The open session was structured to cover the following topics which will be discussed later:
1. Introductions and Opening Remarks
2. Government Presentations
3. Industry Presentations
4. Update on the Special Comprehensive Export License Process
5. Closed Session
6. Meeting Adjournment
- Mathew Borman, Deputy Assistant Secretary for Export Administration, commented on the departure of Peter Lichtenbaum to the private sector. Mr. Borman would act as Assistant Secretary until Mr. Lichtenbaum’s replacement was confirmed. Mr. Borman welcomed Mr. Burkle, manager of Export Administration at ITT Industries Night Vision as the newest member of the SITAC. Mr. Borman also mentioned that the processing time for applications for thermal imaging cameras still is approximately 30 days despite the personnel shortages and the increase in export applications from 2004. He indicated that most export licenses are destined for European Union locations but also that the exports to the PRC has declined as Chinese firms manufacture and export more of their own infrared cameras worldwide on a license-free basis. He also wanted to help level the playing field between domestic and foreign camera manufacturers and asked the SITAC members for their help.
- A presentation from Texas Instruments (TI) was made by Rod Ellicott on low light level imaging devices. He was introduced by Hector Rivera a former BIS employee who explained the impact the proposed USG control would have on TI’s business.
a. TI employs design and manufacturing teams in Japan to produce EMCCDs. EMCCD is a generic term that describes a family of CCDs that uses on-chip charge multiplication and are silicon based image intensifiers.
i. Patent holders for EMCCDs are E2V and TI.
ii. The technology is targeted to microscopy applications, such as ophthalmology, because it is effective in low light levels. The technology is not appropriate for military applications.
b. The proposed language to change Wassenaar 6.A.2.a.2.b.4 “catches” the TI technology, but not the E2V technology. The proposed language says that smaller pixels (more per page) should be controlled. TI argues that bigger pixels (fewer per page) should be controlled. Smaller pixels result in less sensitivity but better resolution.
i. Michael Grenn from the Department of Defense noted that the proposed language has changed. He added that DOD is attempting to write a control that will be appropriate in the present as well as in the future.
c. Under the proposed ECCN of 6.A.2.a.3.g, both TI and E2V sensors would be controlled.
i. Committee member Stanley Kummer asked how the Japanese and European governments have been controlling the technology. Mr. Rivera explained that Japan already has some controls in place but not for these devices. The United Kingdom looks at individual cases to determine whether the device has military applications. Military technology is controlled while commercially used technology is not.
d. Mr. Goodrich asked whether the EMCCD technology could be used in military applications. Mr. Rivera answered that, theoretically, any microscopy technology could be used in the military but that this technology is not suitable for man-portable applications.
e. Mr. Grenn commented that DOD agrees that cameras should be decontrolled but added that EMCCDs inherently have multiple applications. As a result, they should be controlled as focal plane arrays are controlled. Mr. Rivera responded that TI’s EMCCDs are too bulky to be practical in the military. Mr. Grenn explained that the technology could be made to use less power and this would render it man portable. He added that there is concern at DOD regarding controls that catch medical applications of the technology.
f. Committee member Frank Vallese asked whether United States controls for EMCCDs are tighter than in other countries. Mr. Rivera answered that the Japanese government does control EMCCDs. Applicants must explain who the end-users are and what the end-use will be. Although the application process in Japan does require significant paperwork, it is not necessarily more restrictive.
g. Mr. Goodrich wrapped up the discussion and said that proposals to Category 6 will be discussed later.
- Larry Konsin, representing Mine Safety Appliances (MSA) as well as the American Council for Thermal Imaging (ACTI) gave a presentation on the Fire Service Thermal Imaging Camera Standards Working Group, a committee that has been formed to create standards for thermal imaging cameras (TICs) used by fire fighters. The committee includes sensor manufacturers, camera manufacturers, and customers.
a. The Working Group recommends the development of a “common operating system” among TICs. Currently, it is difficult for fire fighting organizations to share TIC equipment because it operates differently and indicates heat intensity differently. This is especially problematic when fire fighters from several regions work together to fight very large fires.
b. The National Fire Protection Association (NFPA) does not have the resources to develop standards until 2007. In 2007, the NFPA Technical Committee on Electrical Safety Equipment will begin work to create an “umbrella standard”. By then, the Working Group should have a TIC proposal to present to NFPA. There may be a standard adopted as early as 2008 or 2009.
a. Mr. Goodrich noted that France and the EU fall under the auspices of Wassenaar and asked whether ULIS has to have their end users approved to get export licenses. The representative answered that ULIS designs infrared detectors but not for any specific applications.
b. An industry representative asked if ULIS were affiliated with the French military. The representative responded that ULIS is indirectly affiliated with the military but added that their market for detectors is for civilian goods. They get licenses for each company they sell to for a specific product and are required to describe how the technology will be used.
c. Carol Kalinoski asked whether the French licensing authorities require them to monitor the end use of their products and if the licensing authorities can influence who their customer might resell their products to. Committee member David Little answered that ULIS sells detectors to his company, ISG. ISG is required to integrate the product into a commercial product before it can be sold. He explained that ULIS sells their product to a “friendly” country and once the product is in that country, that country’s rules apply.
d. After the ULIS representatives left, Mr. Goodrich commented that SITAC needs to have a better understanding of how Wassenaar rules are applied in other countries. In his view, the United States laws are creating an unlevel playing field for domestic producers.
i. Mr. Little, president of ISG, noted that Wassenaar does not really have any jurisdiction. We have ITAR in the United States because it’s a national prerogative to control exports.
ii. Carol Kalinowski added that export controls are not harmonized. The laws are based on individual countries’ interpretations.
iii. Mr. Goodrich asked the group whether they thought DTSA goals were being met. SITAC may be able to have some influence over what items are on the Wassenaar list, but there is little more they can do to influence what other countries do with the list.
iv. Mr. Kummer commented that Wassenaar includes “nobly” generated objectives but that the United States national discretion should be applied in a way that protects national security without harming domestic industry. He also asked that the discussion be continued in the closed session. Furthermore, Stan Kummer explains that the French government is supportive of exports of this technology to the PRC.
- Ron DeMarines from the Department of Commerce gave more information about the survey DoC is conducting to determine the health and competitiveness of domestic industry.
a. The survey looks at exports, levels of import penetration and requested responses from final platform producers, service providers, and component manufacturers.
b. They have received responses from 70% of the companies surveyed, accounting for 90% of industry shipments. Mr. DeMarines’ staff is currently in the process of reviewing the responses, organizing the data, and making tables.
c. Mr. DeMarines hopes to have an internal review of the results by the end of March and could issue the report a few months later.
- James Thompson, director of the Sensors and Aviation Division, discussed two upcoming Wassenaar proposals relevant to SITAC.
a. One proposal would decontrol PbS and PbSe linear rays with a high aspect ratio. This proposal was not approved last year but may be reintroduced this year.
b. There may be some revisions to laser controls. Again, there has been no agreement on any previously proposed revisions but they may be amended and discussed further.
c. Wassenaar is considering several proposals to modify Category 6. They may decontrol low pixel count focal arrays, clarify confusing language, decontrol cameras used in astronomy and civil aircraft, and relax controls on high speed cameras.
- Mr. Grenn gave a presentation for DTSA regarding three classes of digital infrared night vision devices and relevant controls.
a. He first discussed charge multiplying CCDs. These use focal plane array technology and achieve single photon imaging performance by implementing impact ionization. The technology is used in both military and commercial cameras.
b. Next, Mr. Grenn discussed CCD/CMOS hybrids that he believes should be ITAR controlled.
c. Finally, he discussed hybrid tubes which use a video based chip in a vacuum space in a tube.
d. Mr. Grenn argued that digital infrared devices should be controlled the way other similarly performing technologies are controlled. A way to distinguish military from commercial uses may be to measure focal plane array performance at starlight as a function of signal to noise ratio.
e. Mr. Thompson noted that industry disagrees with the specs DOD uses to distinguish military from commercial use. For example, Motorola has complained that their cameras would be controlled under the DOD specs. Mr. Grenn responded that the current language refers to technology “using a frame rate less than or equal to 30 frames.” The language could be changed to “when referenced to 30 frame rate.” Mr. Rivera noted that if the language is difficult for people in charge of export controls to understand, Wassenaar won’t accept it.
John Goodrich then adjourned the general session and the closed session began.