Transportation and Related Equipment Technical Advisory Committee
(TransTAC)

March 7, 2013
 U.S. Department of Commerce
Bureau of Industry and Security
Washington, DC

OPEN SESSION

TransTAC members in attendance: (Industry) Mr. Ari Novis (TransTAC Chair), Mr. Brent Baustain1, Mr. Joe Bergeron1, Ms. Kimberly DePew, Mr. Jim Downs1, Mr. Simon Gharibian, Mr. Dean Johnson , Mr. Kenneth Lyons1, Mr. Michael Osborne1, Mr. Howard Pfeifer1, Mr. Donald Stevenson1, Mr. Charles Volk1, 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 9:32 a.m. and introductions were made around the room.

Mr. Don Stevenson was thanked for his service as the Chairperson for the past two years.

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:

With the changes to 7A1 accepted, the focus will move to 7A3, specifically the language of Inertial Units. The goal will be to identify the functions of concern and avoid simply using nomenclature, which is not standardized. The Inertial sub-team has held seven working sessions since the last (November 2012) TransTAC meeting, and prepared a 7A3 proposal for the 2013 Wassenaar session.

Challenges to any inertial system controls include writing the controls so item classification can typically be done through published specifications, and respect of the advancing capability of consumer products.

As the consumer market for inertial systems increases, there is a drive to create miniaturized IMUs, with a global production base. To this end, 7A1 and 7A2 control levels need to consider consumer end uses and availability outside the Wassenaar countries. In terms of end-use (aircraft versus ocean versus land) the systems in question are specified differently based on use. For legacy/tradition reasons, different vendors use different measurement criteria. There is a wish to control systems based on outputs, not on the internal items, but some sort of ‘see-through’ requirement may still be necessary.

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

The proposal to update the AFCS control text in 7.D.3 and 7.E.4.b was approved at the December Plenary session, and we await publication in the Federal Register later this year (2013).

9.D.4 - Mr. Ari Novis provided a status on the 9.D.4 Software TWG:

A subteam has drafted a 9.D.4.g paper to review the current 9.D.4.g regulation for clarity, appropriateness, and need.

The TWG is considering clarifying the wording of 9.D.4.b to note that specific ‘low technology’ or similar simple functions, such as an overspeed shutdown, would not be controlled.

Category 9

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 control language for 9.E.3.a.5 from the September TWG was accepted at the December Plenary session. We await publication in the Federal Register later this year (2013).

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. There is no proposal language ready for the 2013 Wassenaar session, but the TWG is ready to respond to proposals from other countries.

Composite Working Group

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

The CWG continues to meet regularly, and is ready to support/provide comment on foreign proposals, including 1C210 materials (slit composites.) The team is working a 9.E.3.a.3 (composite aircraft parts) proposal to eliminate overlap with 1.E.1. A new, simplified draft white paper is being worked on how the controls apply to scrap and other composite materials for recycling. In many cases, these may materials scrapped or rejected because they don’t meet the required specifications. In terms of finished or semi-finished parts, how reasonable is it to be able to extract the controlled fibers or resin?

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

• 1.B.1 specially designed parts. This may be addressed with a series of CCATS, and could be greatly impacted by the new definition of “specially designed.”
• 1.A.2 ‘finished’ parts. Finished parts are de-controlled in the 1.A.2 note, but the boundary between a ‘finished’ and ‘semi-finished’ part is not clear.
• The use of ‘for’ in ECCNs. There is no extra discriminator, not even ‘specially designed,’ and this can be problematic. This is a global issue, not just composites.
• 1.B.1 and 1B101 (MTCR) mismatches. Consider adding performance thresholds.
• 1.C.1 and 1C101 (MTCR) inconsistencies (one references the ITAR, the other does not.)
• Coverage of 1.C.1.a relating to carbon fiber fillers.

Objectives/New Teams

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

Simon Gharibian (Sikorsky Aircraft) volunteered to head a review of 9.E.3.d (“technology” for helicopter or tilt rotor/wing power transfer systems). There is no performance threshold, so the gearbox for the Hughes 269 ‘MASH’ helicopter, with less complexity than a transmission for a VW ‘bug’ of the same era, is controlled. Because it can also be used for production, this restricts overhaul and assembly/reassembly information.

Eliminate overlap and clarify control threshold with 9.D.1, 9.D.2, and 9.D.4.

Proposals/Comments from the public

There were no comments from the public.

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

Open Session Attendees
November 15, 2012 TransTAC

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¹By phone