3. Level Playing Field

GOAL: Achieve a Level Playing Field for the Aerospace Industry

In today’s global economy, it is paramount for AIA’s members to work with the U.S. government to ensure that our firms can compete on a level playing field in the international marketplace, seek out new market opportunities for exports and ensure the dialogue among all global stakeholders advances American aerospace and defense interests.

Remove U.S. Impediments to Industry Competitiveness Internationally

In 2012, AIA made significant progress working with the Obama administration to advance a number of export control reform priorities, in particular initiating the process of removing non-sensitive, essentially commercial technology from ITAR control and making improvements to DOD’s Technology Security & Foreign Disclosure process, two areas of major concern to AIA’s members. In 2013, AIA will work with the administration as it completes the migration of non-sensitive technology to the Commerce Control List from the U.S. Munitions List.  AIA will also work closely with the administration as it addresses remaining export control reform priorities for industry, including development of a useable program licensing model, creation of a “single form” and a “single portal” for export license applications, implementing the UK and Australian Defense Trade Cooperation Treaties, and establishing an interagency policy on the approval of UAS exports. 

In 2012 Customs and Border Protection established an Automotive & Aerospace Center of Excellence and Expertise (CEE) to work with associations to gain a better understanding of how a specific industry operates in order to facilitate trade, reduce transaction costs, increase compliance with applicable import laws, and to achieve uniformity of treatment at the ports of entry for identified industries.  AIA will work with the CEE throughout 2013 and beyond to help achieve these goals.

Increase Open and Fair Business Opportunities for U.S. Companies in Foreign Markets

These objectives are part of a larger endeavor for AIA and its members, namely the establishment of a National Defense Export Strategy (NDES).  The goal is a level of engagement and cooperation that allows industry to make business decisions early enough to ensure our companies are fiscally and physically constructed in tune with the USG’s international priorities, especially at a time when budget constraints and foreign competition make U.S. industry defense export activity a more risky business proposition.  Besides building on ongoing export control and security cooperation reform efforts, an NDES will also entail developing a systematic USG Interagency-Industry dialogue on technology trends and improving intra-agency and interagency coordination and communication (including industry as appropriate) on defense trade matters.

AIA will also expand its international efforts to support U.S. space and civil aviation manufacturers’ priorities in specific existing and emerging markets and ensure our industry’s overall competitiveness worldwide.  In this regard, we will continue our work to enhance manufacturers’ presence and representation at ICAO. AIA will work to ensure that civil aviation authorities throughout the world apply more uniform standards and procedures in certificating and validating aeronautical products. Closely aligned to this work are our efforts to reduce inconsistent regulatory interpretation and application and shorten the time it takes to get our products from design to production.

In 2012, AIA met and worked with ASD (Aerospace and Defense Industries Association of Europe) and ADS (Aerospace, Defense and Security) at the groups’ second international conference to update each organization and members to the status of global chemical regulations and policies.  The groups expanded on the materials used to educate European officials responsible for implementing the European Union’s Registration, Evaluation and Authorization and Restriction of Chemicals regulation (REACh) of the unique conditions associated with the aerospace industry’s needs.  We must ensure that restricted chemical substance alternatives are compatible with other materials and certified to meet multiple customer requirements associated with product safety.  In 2013, AIA will continue to press the unique concerns of the aerospace industry in responding to international chemical regulations the need of the industry to ensure that substances exist to replicate the performance requirements necessary for aerospace products through its long life spans and urge our trading partners to maintain a fair regulatory framework for all market players.

Promote Fair and Equitable, Market-Based Contractor Compensation Practices

AIA and its members have serious concerns with recent legislative proposals that have suggested the government might save money by limiting allowability of contractor compensation in the defense industry.  We believe such proposals have singled out the aerospace and defense industry and are not based on an understanding of the nature of our business approach. They would negatively impact the cost of providing our goods and services and inhibit our ability to ensure technological superiority where it matters most – on the battlefield – and ultimately harm our national security and endanger our armed services by undermining a key and fundamental market based practice that underpins and supports the defense industrial base.

In 2013, we continue to argue that imposing a lower fixed cap will sever the compensation practices of the private sector-supported federal agencies’ missions from the dynamics of those of the rest of the private sector and, as a result, companies will be reluctant to assign top management or highly-skilled employees to federal contracts and such employees may be more willing to work on commercial rather than government contracts. They will result in a loss of access to specific expertise and innovation that the private sector delivers for the federal government.

AIA will resume our efforts to educate Members of Congress on the reasoning underlying the creation of an executive compensation formula - to ensure that federal contractors could continue to compete for high-level management and other technical talent. Those who are seeking to tie the cap to current federal employee compensation levels will be made aware that by taking this path they will be ignoring the original intended purpose by converting the comparison to a government-to-contractor evaluation.

 

 
Target 7: Remove U.S. impediments to industry competitiveness internationally  
Provide industry input on implementing regulations for Treaties
Secure DOD implementation of proposals for reform of the DOD Technology Disclosure process
Promote US Space industries at international air shows
Organize U.S. industry input on Global Arms Trade Treaty negotiations
Organize industry import/export training for newly established CBP Automotive and Aerospace Centers of Excellence and Expertise
Adopt industry positions for MTCR release policy
Provide industry input on Single Portal/Single Form for export licensing
Implement program license proposal at State
Advocate for AIA institutional role on behalf of industry in international space cooperation
Promote renewal of Commercial Space Launch Act indemnification
Ensure new brokering regulations do not adversely impact international defense sales activities
Obtain workable formulations for key ITAR exemptions
Secure implementation of AIA proposals to transition appropriate technology from the USML to CCL
 
Target 8: Increase open and fair business opportunities for U.S. companies in foreign markets  
Create and execute a workshop to support space exports in order to strengthen U.S. space industrial base
Create and execute a workshop to support space exports in order to strengthen U.S. space industrial base
Continue Offsets Dialogue with Indian MoD and Greek MoD
Prepare for 2014 Ex-Im Bank reauthorization and expansion of lending capacity
Support the adoption of NextGen globally by promoting nationally and internationally policies providing U.S. companies access to foreign markets
Educate Congress on negative impacts of legislation that could affect competitiveness of US exporters
Develop and implement a strategy to affect fair EASA fees and charges
Actively participate in Part 21/SMS ARC and designated working groups to advocate industry positions and recommendations
Produce AIA policy paper on ODA citing economic and safety benefits
Target 9: Promote fair and equitable, market-based contractor compensation practices among comparable high technology manufacturing and electronics sectors  
Educate Congress on the negative impacts of legislation that would reduce contractor compensation
Promote policies to ensure industry’s ability to attract and maintain the skilled workforce necessary to support the government’s defense posture