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Open Session
TransTAC members in attendance: (Industry) Mr. Michael Gries, Ms. Kimberly DePew (TransTAC Chair), Mr. Bill Kennedy, Mr. Michael Osborne, Mr. David Salome, and Mr. Donald Stevenson. (Government) Mr. Gene Christiansen, Mr. Anthony Lombardi, and Ms. Yvette Springer.
Others present: The complete list of attendees is attached at the end of these minutes.
Opening remarks
Ms. Kim DePew called the meeting to order at 9:38am and introductions were made on the phone and around the room.
CCL Review
TransTAC members described the status of the review for Categories 7-9. A summary presentation was used to facilitate the discussion. Those on the phone requested a copy of the presentation and Ms. Kim DePew agreed to provide it. The status of the milestones on the timeline was reviewed. Leaders for each of the categories have been identified. Mr. Don Stevenson leads the review of Category 7 - non-inertial items, and Mr. Mike Osborne and Mr. Michael Gries lead the review of Category 7 - inertial and guidance navigation systems. Ms. Kim DePew leads the Category 8 review. Because Category 9 is a large category, Ms. Kim DePew will help coordinate the review of Category 9 with several working groups focusing on specific ECCNs. The working groups are classifying each ECCN using the classifications listed below. A fifth classification was added to indicate which ECCNs can not be reviewed with current working group membership. In those cases additional members from industry and academia will be solicited. Ms. Kim DePew and Mr. Gene Christiansen will work getting additional members.
The working groups are also prioritizing the ECCNs, which have been identified for possible update. The goal is to complete non-papers and proposals complete for the top priority ECCNs by May, 2008 with remaining ECCNs by September, 2008. At a minimum, all top priority ECCNs should be completed by September, 2008.
Each working group provided a status of non-papers and proposals being worked.
Flight Controls and 3D/Head Up Displays
Mr. Don Stevenson provided a status on the efforts. The working group has completed a first brief review of the ECCNs. Mr. Don Stevenson would like larger industry participation. The working group is developing proposals and non-papers to cover displays and flight controls. In the first fly-by-wire proposal, not all changes desired are covered. Additional research is required to develop a proposal covering all aspects. The flight controls non-paper is in interagency review. The 3D display non-paper was submitted to Wassenaar in the fall session. The working group will meet via call-in after the TransTAC.
Inertial
Mr. Mike Osborne provided a status on the efforts to review the inertial entries in Category 7. The working group has had a couple of calls which included TransTAC members and makers of the equipment. The team has developed eight draft proposals. Two are Wassenaar draft proposals. One is a Missile Control Technology Regime draft proposal. Five draft proposals are for unilateral controls. As discussed and depicted in the presentation, the ECCNs include 7B001, 7D002, 7E102, 7D001, 7D101, 7E001, 7E002, and 7E101. Mr. Don Weadon suggested that proposals be presented to the Defense Trade Advisory Group as appropriate. Mr. Gene Christiansen and Ms. Lisa Wenger, DOS, agree that working together in some way may be beneficial.
Marine
Ms. Kim DePew stated that no additional work has been done on this category. Additional working group members will have to be identified to continue with the review.
Category 9
Ms. Kim DePew gave a summary of the activities underway. The current working group members are those individuals who have participated in reviewing 9E003.a.4 and 9E003.a.5. The working group developed an industry proposal for both of these ECCNs. Category 9 is composed of 71 ECCNS, 147 “items”. Ms. Kim DePew suggested that Category 9 be split up into several working groups and provided a list of the ECCNS with proposed i-v classifications listed. In addition to using classification iii for loosening controls, that classification was also used to indicate when desired wording correction or clarification was identified. Twenty-seven higher priority items were identified including those covering hot section, hole drilling, FADEC, unmanned aerial vehicles, and very light jets. Mr. Howard Pfeifer suggested that 9B001, equipment for manufacturing gas turbine blades, vanes, or tip shroud castings, also be added to the priority list. The TransTAC was asked to review the list of ECCNs and classifications. Mr. Howard Pfeifer agreed to lead the 9A101 (very light jet engines), 9B001, 9B991, 9D004.b, and 9D004.d effort. Mr. Joe Brostmeyer agreed to find someone to lead the hot section effort. The TransTAC is invited to participate on all the sub-teams. Mr. David Salome requested that 9E003.a.7 be added. Mr. Gene Christiansen also asked that 9E003.a.10 be reviewed including the noted exceptions to see if items are being caught that should not be. Mr. Gene Christiansen suggested we consider looking at technology related to deoxygenation of fuel. TransTAC should consider additional controls for emerging technologies. The working group reviewing 9E003.a.4 and 9E003.a.5 will meet via call-in after the TransTAC meeting.
Composites Technical Working Group
Ms. Kim DePew provided a status on the efforts underway by the Composites TWG. The working group has developed industry proposals for two ECCNs, eight items, and has identified an additional eight ECCNs with several items to be worked. This includes clean-up to make related ECCNs consistent with the current proposals. Mr. Gene Christiansen suggested that the Office of Technology Evaluation, which is headed by Mr. Kevin Kurland, may be a resource to collect data on foreign availability. Mr. Kevin Kurland will be invited to a future TransTAC to explain the process. The Composite TWG continues to meet every other week. Sub-teams also meet periodically.
Helicopter Power Transfer Systems
Mr. Gene Christiansen had provided a Bell Helicopter definition to the other manufacturers and requested they comment at the last TransTAC meeting. Mr. Gene Christiansen explained that Mr. Ed Auger, DOD, subsequently indicated that a different method of describing the technology may need to be developed. Mr. Ed Auger will continue working with the manufacturers to help define the control parameters.
Jurisdiction – 17c – Interpretation 9
Mr. Gene Christiansen began the discussion on jurisdiction. The Aerospace Industries Association has developed a paper, which has resulted in significant interest by congress, which has, in turn, pushed on the executive branch to address jurisdiction questions. The DoC is talking with the DoS on this. The DoS has a proposal that would change the language in Category 8 that talks about section 17(c) of the Export Administration Act and civil certified items. One issue is that it does not appear that FAA certification is a bright line. Some certified items go beyond commercial items. An interagency meeting is scheduled for November 20. Attendees should include DoS, DoD, DoC, and the FAA personnel. One goal is to better understand FAA certifications. The DoD is also reviewing the DoS proposal. Since the agencies are working directly with the FAA to understand certification, an earlier action given to the TransTAC to collect information related to certifications is no longer required.
Comments by the Public
Mr. Donald Weadon indicated that the call-in worked very well. He also asked how the Federal Register Notice, which was published to get comments from the public on the CCL, would impact the TAC’s effort. The TACs will use those public comments in their review. The comments may also provide additional contacts throughout industry.
The discussion then turned to determining foreign availability. The TransTAC recognized that improvements can be made in this area to become more effective.
Mr. Donald Weadon made the comment that the content of the Militarily Critical Technology List (MCTL) is not being fed back into the CCL. The TAC members responded that there are already plans to use recent MCTL changes in the Category 9 review.
Mr. Donald Weadon asked that additional connectivity tools such as taping the sessions, a electronic way to submit questions, etc. be introduced into the TransTAC meetings. These e-tools will be considered in future meetings.
Open Action Items
Action 1: (November 2003) Mr. Gene Christiansen to review the proposed change to license exception “TSU” for disclosure of technical data to non-U.S. civil aviation authorities and NTSB type foreign organizations in support of flight incident investigations.
Update 9/21/04: Mr. Osborne to provide additional refinements to proposal and identify which export license exception should be modified.
Update 12/8/04: Mr. Osborne provided a proposed change to the license exception TSU. Mr. Christiansen has the action to review within BIS.
The proposal has been provided to Commerce Regulations Division and to DOD for comment.
Update 3/17/05: Mr. Christiansen to continue review within BIS and other government agencies.
Update 5/18/05: Mr. Christiansen to continue review within BIS and other government agencies.
Update 9/7/2005: Mr. Osborne has provided information to Mr. Christiansen and has requested Gene review it internally in Commerce for consideration for inter-agency review. Mr. Osborne will also work with Ms. Julie Ann Felgar, Boeing to be sure that the proposal covers all applicable civil aircraft systems.
Update 11/09/2005: A revised white paper, with further clarification, was presented by Mr. Osborne.
Update 02/09/2006: Discussed the intent and clarification of the White Paper from last meeting. The discussion asked for lists of items typically requested in an investigation, and whether requests are for use technology or include development or production technology?
Update 05/03/2006: The request for industry to provide lists of items typically requested in an investigation was reiterated.
Update 09/13/2006: Mr. Osborne distributed a White Paper outlining a proposed change to the wording of License Exception TSU (ref: 15 CFR 740.13). Mike asked all TransTAC members to review the White paper for concurrence and a unified position to be forwarded to BIS. And reiteration of the request for industry to provide examples of items typically requiring an export license and requested during aircraft incident investigations.
Update 11/09/2006: BIS is reviewing the paper provided to BIS through Mr. Osborne outlining a proposed change to the wording of License Exception TSU (ref: 15 CFR 740.13).
Update 02/07/2007: BIS review and consideration continues.
Update 05/02/2007: BIS review and consideration is nearing final conclusions.
Update 09/12/2007: Action still in process.
Update 11/15/2007: Action still in process.
Action 4: (February 2004) TRANSTAC Team will validate whether the current multi-dome combustion controls are realistic or provide any changes that are required, for instance with respect to temperature vs. number of domes.
Update May 2004: This was provided in the handout. There is a follow up action to have other engine manufacturers not represented on the TRANSTAC review the proposal. (Mr. Christiansen).
Update September 2004: Mr. Pfeifer to coordinate putting the proposed changes into Wassenaar proposal format.
Update 3/17/05: Still open
Update 5/18/05: Pending TransTAC member input.
Update 9/7/2005: Still pending TransTAC member input. Also, want to request input from Mr. Brostmeyer and Ms. DePew.
Update 11/09/2005: Pending additional input and clarification from industry whether to revise current controls or impose new controls on multidomed combustors, multipoint fuel injection combustors and/or thermally decoupled combustors.
Update 02/09/2006: GE provided a proposal for changes to 9E003.a.2. Proposal to make a combustor exit temperature change from 2800 F to 3000 F due to typical civil uses today. All other industry members need to provide comment.
Update 05/03/2006: The request for industry to provide comment on the proposal for changing combustor exit temperature from 2800 F to 3000 F was reiterated.
Update 09/13/2006: Industry is working to provide a consolidated position.
Update 11/09/2006: Industry is working to provide a consolidated position.
Update 02/07/2007: Industry is working to provide a consolidated position.
Update 05/02/2007: Industry is still working to provide a consolidated position.
Update 09/12/2007: Industry will include this item in the overall CCL review.
Update 11/15/2007: Industry will include this item as a top priority in the overall CCL review.
Action 5: (February 2004) TRANSTAC Team: Review 9E003.a.4 and 9E003.a.5 on whether temperature range is correct and whether this needs to be clarified with respect to hot spot, average or some other defined gas path or hardware temperature.
Update: This was provided in the handout at the May 2004 TRANSTAC meeting. There is a follow up action to solicit inputs from GE and other engine manufacturers (Mr. Christiansen).
Update September 2004: Mr. Pfeifer to coordinate putting the proposed changes into Wassenaar proposal format.
Update 3/17/05: Still open.
Update 5/18/05: Pending TransTAC member input.
Update 9/7/2005: Still pending TransTAC member input. Also, requesting input from Mr. Brostmeyer and Ms. DePew.
Update 11/9/2005: DTSA persons in attendance requested the TransTAC work on a clarification of what constitutes “hot section” in a turbine engine. Ms. DePew provided a proposed definition of “hot section” for TransTAC propulsion member review. Require further discussion of the proposal and definition of design point parameters between all major engine manufacturers.
Update 02/09/2006: GE provided a revision of the proposal from the last meeting for changes to the definition of hot section parts in 9E003.a.4 and 9E003.a.5. Proposal would apply to aero, industrial, civil, defense and marine turbine engines. All other industry members need to provide comment.
Update 05/03/2006: The request for industry to provide comment on the proposal for clarifying the definition of hot section parts was reiterated.
Update 09/13/2006: Industry is working to provide a consolidated position based on General Electric’s proposed clarification of ‘Hot Section’.
Update 11/09/2006: Industry is working to provide a consolidated position.
Update 02/07/2007: Industry is working to provide a consolidated position.
Update 05/02/2007: Industry is working to provide a consolidated position in response to foreign proposal (see Wassenaar Arrangement meeting minutes above) by the end of May.
Update 09/12/2007: Proposals in process. Industry will include this item in the overall CCL review.
Update 11/15/2007: Working group has submitted proposals to the TransTAC and DoC. The working group continues to investigate the impact of threshold limits per the proposed language and to answer questions as they arise during interagency review.
Action 10: (rewritten 3/17/05): Mr. Martling, Cessna, and Mr. Pfeifer: Report to TRANSTAC on any helicopter power transfer system issues and on whether the CCL (9E003.d) needs to change. Would like to know if there are differentiating features or capabilities between military and commercial use helicopter power transfer systems.
Update 5/18/05: Pending TransTAC member input.
Update 9/7/2005: Pending TransTAC member input.
Update 11/09/2005: Pending TransTAC member input. Include DTSA in distribution.
Update 02/09/2006: Are there differences in civil and defense helicopter power transfer systems? What are they? Still require input from helicopter manufacturers. Include Mr. Ed Auger in any input.
Update 05/03/2006: Ms. Elaine Vaught, Bell Helicopter, agreed to review 9E003.d.
Update 09/13/2006: Pending industry input.
Update 11/09/2006: Mr. Bruce Hansen, Sikorsky, attended the TransTAC and agreed to assist reviewing technology controlled by 9E003.d.
Update 02/07/2007: Industry is working to provide a consolidated position.
Update 05/02/2007: Industry is working to provide a consolidated position.
Update 09/12/2007: Bell has provided some input on control parameters and wording clarifications. Boeing and Sikorsky are invited to participate in the review. Industry will include this item in the overall CCL review.
Update 11/15/2007: Ed Auger continues to work with industry to determine how these controls can be better defined.
Action 12: Mr. Stevenson of Honeywell to investigate foreign design capability for Fly By Wire (FBW) flight control.
Update 3/17/05: White paper was presented to Committee. Closed.
Update 5/18/05: Mr. Stevenson still working.
Update 9/7/2005: Mr. Stevenson has submitted information to Commerce. The next step is to write a new proposal requesting decontrol based on foreign availability, Mr. Stevenson has offered to start the proposal.
Update 11/09/2005: A white paper for the proposal was distribute. DOC to distribute white paper for interagency review.
Update 02/09/2006: The white paper is currently queued for review in BIS and interagency. Any additional industry input is welcome.
Update 05/03/2006: The BIS interagency review is continuing.
Update 09/13/2006: The BIS interagency review is continuing.
Update 11/09/2006: The BIS interagency review is continuing. BIS may develop the White paper into a non-paper for Wassenaar review.
Update 02/07/2007: The BIS interagency review is continuing. BIS may develop the White paper into a non-paper for Wassenaar review.
Update 05/02/2007: The White Paper has been developed into a Non-Paper for presentation to the Wassenaar Arrangement Multilateral Control Regime. Feedback is requested by Industry from BIS: was the format of this White Paper good, was it lacking in any way that could be improved? For example, foreign availability was presented in the White Paper but can the foreign availability be quantified by critical comparison to U.S. origin items and technology.
Update 09/12/2007: The non-paper for presentation to the Wassenaar Arrangement Multilateral Control Regime is in interagency review. Industry has also prepared a draft Wassenaar proposal.
Update 11/15/2007: The non-paper is still in interagency review. Additional changes to these controls may be identified as the full Category 7 review proceeds.
Action 14: Mr. Stevenson of Honeywell to investigate availability of Heads Up Displays and 3D Displays.
Update 11/09/2005: Pending TransTAC member and industry input.
Update 02/09/2006: Pending TransTAC member and industry input.
Update 05/03/2006: Pending TransTAC member and industry input.
Update 09/13/2006: Pending TransTAC member and industry input. Note the proposal for the TransTAC to review CCL items may accomplish the same end result.
Update 11/09/2006: Pending TransTAC member and industry input, Mr. Stevenson to work with Rockwell Collins.
Update 02/07/2007: Mr. Stevenson provided a paper for 3D displays for TransTAC and BIS review and consideration. Feedback or comment is requested. Heads Up Displays will be the subject of future paper.
Update 05/02/2007: The portion of the White Paper on 3D Displays has been developed into a Non-Paper for presentation to the Wassenaar Arrangement Multilateral Control Regime.
Update 09/12/2007: The 3D display non-paper was approved for Wassenaar consideration. Two draft proposals, one updating the controls and one eliminating the controls, have also been prepared.
Update 11/15/2007: The team continues to work display-related proposals.
Next Meetings
The next TransTAC meeting, for the first calendar quarter of 2008, is set for 9:30 am Wednesday, February 6, 2008 at the U.S. Department of Commerce.
The second calendar quarterly meeting for 2008 is tentatively scheduled for Thursday, May 8, 2008.
The third calendar quarterly meeting for 2008 is tentatively scheduled for Thursday, September 11, 2008.
The fourth calendar quarterly meeting for 2008 is tentatively scheduled for Thursday, November 13, 2008.
TransTAC Members are reminded that meetings typically work through lunch and are trending toward five to six hours in length and should plan accordingly. Each meeting will be partially closed, beginning with the open session.
The open session adjourned at 10:50 am.
Attendees
November 15, 2007 TransTAC
NAME ORGANIZATION
Michael Gries
TransTAC Industry Member Rockwell Collins, Inc.
Kim DePew
TransTAC Industry Member, Chair General Electric Aviation
Bill Kennedy
TransTAC Industry Member Rolls-Royce North America
Michael Osborne
TransTAC Industry Member Honeywell
David Salome
TransTAC Industry Member Honeywell
Donald Stevenson
TransTAC Industry Member Honeywell
Gene Christiansen
TransTAC Designated Federal Official DOC / BIS
Anthony Lombardi
TransTAC DOD Member DOD / OSD / DTSA
Yvette Springer
TransTAC Government Liaison DOC / BIS
John Albert DOS / ISN / CATR
Joe Brostmeyer Florida Turbine
Melanie Bunke IBC
Carrie Fletcher Crowell & Moring
Samuel Gilston The Export Practitioner
Larry Junod Rolls Royce North America
Bob Kaercher IDA
Ken Lyons Airbus Americas
Brian Martling Cessna
Howard M. Pfeifer Pratt & Whitney
Frank Record MK Technology
Dan Squire DOC / BIS
Ken Tucker Boeing
Donald Weadon, Jr. Weadon & Associates
Lisa Wenger DOS / PM / DTCP