Transportation and Related Equipment Technical Advisory Committee
(TransTAC)

 Open Session

TransTAC members in attendance: (Industry) Mr. Ari Novis (TransTAC Chair), Mr. Brent Baustain1, Mr. Joseph Bergeron, Ms. Kimberly DePew, Mr. Mr. Colin Donahue, Ms. Julie Kelly, Mr. Michael Osborne, Mr. Howard Pfeifer, Mr. Donald Stevenson1, Mr. Ernest Tong, Mr. Charles Volk, and Mr. Todd Zarfos.

(Government) Mr. Gene Christiansen (DFO).

Others present: The complete list of attendees is attached at the end of these minutes.

Opening remarks
Mr. Ari Novis called the meeting to order at 9:30 a.m. and introductions were made around the room.

Industry Working Group
Ms. Kim Depew announced that a meeting of a new, Industry Export Working Group will be held after the TransTAC at UTC's Washington office (1101 Pennsylvania Ave). U.S. Government members are welcome to attend. The purpose of the group is to identify and work on issues specific to the regulations with an emphasis on ECR, and to bring those issues to the USG.

ECR
The discussion concerned the implementation ECR, with emphasis on issues common to the industry. The classification of parts is typically straightforward, but technical data is more complex. It's not uncommon for a document (e.g., a maintenance manual) to cover a range of technology jurisdictions and categories.

There was a discussion of changes to how we write licenses – there have been more questions from the Licensing Officers regarding the jurisdiction and classification of items requested. License applications need to be clearer and more detailed than pre-ECR.

It was asked if the 'see-through' rule applied to the EAR. By applying Interpretation 2, an EAR item loses its identity when incorporated into a higher level assembly. A U.S. origin non-600 series EAR item that has a 600 series item incorporated would remain non-600 series. A non-U.S. origin item that incorporates a 600 series item would fall under the de minimis rules. As always, the 600 series part by itself (e.g., as a spare) is controlled under the appropriate 600 series ECCN.

CCL Review – Working Group Reports
Transportation TAC (TransTAC) members described the status of the review for Categories 7-9 of the Commerce Control List (CCL), as well as efforts underway by the Composite Working Group.

Category 7

Inertials - Mr. Mike Osborne provided a status on the Inertial portion of Category 7:

The TWG continues to focus on Wassenaar Arrangement proposal support. Looking forward to provide control language for clear regulations based on data typically provided by manufacturers, which also assists control officers both in the US and Participating States.

AFCS - Mr. Don Stevenson provided a status on the AFCS TWG:

The TWG is focused on Wassenaar Arrangement proposal support, with a proposal submitted on Fly-By-Wire controls. The proposal was updated to address inputs from other Participating States during the summer intersessional.

Category 9

9.D.4 – No work has been done on the update to 9.D.4 to reduce overlap with 9.D.1 and .2.

9.E.3.a.4/a.5 TWG Status - Ms. Kim DePew provided a status on the a.4/a.5 working group activities.

The TWG is moving on to align 9.E.3.a.4 with the recently updated 9.E.3.a.2 and 9.E.3.a.5 measurement methodology, with a proposal submitted to the Wassenaar Arrangement.

Composite Working Group

Ms. Kim DePew provided a status on the Composite working group (CWG) activities.

The CWG continues to meet monthly, and is ready to support/provide comment on foreign proposals. The Wassenaar proposal for 9.E.3.a.3 (composite engine parts) to eliminate overlap with 1.E.1 was discussed during the summer intersessional.

A white paper is near final, and may serve as a basis for an Advisory Opinion (AO), similar to the request for the General Technology Note.

The CWG has also developed a list of additional items to work:

• Discussions continue on the inter-relation of 1C010.e, 1A002, and 1C008.
• Drafting a white paper to address 1B001 and 1B101 mismatches
• CWG to identify non-MT materials in respect to 1C001 MT controls, with the possibility of a definition of "usable for missiles."
• Starting work on a 2015 proposal for 1.C.10.c

Gearbox Working Group

Regular working meetings have begun. The goal is to harmonize controls on rotorcraft gearboxes across the ITAR (Cat VIII(h)(2)) and EAR (9.E.3.d). ITAR revisions have taken priority, and there is an 'open' white paper draft in final revision with the intent to submit to DoD by 11/22/2014. Proprietary papers from interested industry entities will be submitted separately to DoD/DoC but in support of the open paper. 9.E.3.d control clarifications are included in the open paper, along with recommendations for revised language.

UAS Working Group

The working group title is Unmanned Aerial Systems, to reflect the broader category of items of interest. The membership has been established, and participation is excellent with the group at about 20 people.. There was a kickoff meeting held on 3/13/2014, with a total of five telecons to date. The objective is to enumerate the technical distinctions between military and civil UAS with a view towards updating the regulatory language.

The initial task is to develop a spreadsheet identifying UAS specific items, broken into 'special', 'not special', and 'may be special' items. Those supporting the activity were thanked.

Objectives/New Teams

Continue to review Categories 7, 8, and 9 for possible updates.

Would like to leverage the TAC as a clearinghouse for ECR, as we have Commerce, DoD, and State in the room with Industry.

Proposals/Comments from the public

There were no comments from the public.

The Open Session adjourned at 10:14 a.m.

Open Session Attendees
September 10, 2014 TransTAC