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AIA UPDATE SPECIAL INSERT: April 2007
AIA and Association Partners Launch Coalition for Security and Competitiveness
AIA and seven other leading associations representing business, manufacturing, aerospace, and technology have formed the Coalition for Security and Competitiveness to enhance America's national security, economic strength, and technological leadership by supporting a more modern U.S. export control system that is more efficient, predictable, and transparent.

The Aerospace Industries Association, the Association for Manufacturing Technology, the Coalition for Employment through Exports, the Electronic Industries Alliance, the Information Technology Industry Council, the National Association of Manufacturers, the National Foreign Trade Council, and the U.S. Chamber of Commerce jointly signed a letter sent to President Bush calling for administrative changes that can be implemented within current law to improve significantly the performance of the U.S. government's export control system.

"We must continue to protect our sensitive military technologies from our adversaries and rivals, while also maximizing the benefits of trade and technology cooperation with our allies and friends," the letter said. "It is essential that our system of controlling U.S. technology exports is modernized in a way that enhances our ability to counter rapidly and decisively evolving threats, and to maintain our global technological leadership and industrial competitiveness."

Even though the focus of the Coalition's efforts is on process improvements under the purview of the administration, the Coalition has organized briefings with congressional staff in the committees of jurisdiction and with the new Congressional Export Control Working Group. Such meetings and discussions will continue to ensure Congress is aware of the need for modernization and understand how the Coalition's proposals will provide a better export control process while still protecting U.S. national security and economic interests.

AIA President and CEO John Douglass said modernizing the export control system will boost U.S. national security and enhance diplomacy.

"Making these improvements will increase our ability to fight shoulder-to-shoulder with our allies and friends around the world," Douglass said. "Past experience has made it clear that multilateral operations enhance success, and military interoperability is vital to this endeavor. Improved defense trade and technology cooperation also help ensure that our brave men and women in uniform have the best weapons and equipment available to do their job. It is hard to overstate how important this is to our nation."

The Coalition seeks an improved export control system that:
  • Accurately identifies and safeguards sensitive and militarily critical technologies.
  • Enhances U.S. technological leadership and global industrial competitiveness through more responsive and efficient regulatory management.
  • Facilitates defense trade and technological exchange with allies and trusted partners.
  • Supports a strong U.S. technology industrial base and highly-skilled workforce.
  • Promotes greater multilateral cooperation with our friends and allies on export controls.
Coalition Logo



Digest of the opening statement of AIA Executive Vice President Mark Esper at a Washington, D.C., news conference announcing the creation of the Coalition for Security and Competitiveness:
Today, we are announcing the formation of a new coalition — the Coalition for Security and Competitiveness.

This coalition will work to urge the executive branch to make the nation's export control system more efficient, predictable, and transparent.

Photo: AIA's Mark Esper answers a question at a Coalition news conference.
AIA's Mark Esper answers a question at a Coalition news conference.
The first action was to send a letter to President Bush — which was delivered to the White House this morning. It includes our proposals for improving the current system, urges action on these recommendations, and requests a meeting to discuss these matters.

The letter states that "we must continue to protect our sensitive military technologies from our adversaries and rivals while also maximizing the benefits of trade and technology cooperation with our allies and friends."

It also states that "it is essential that our system of controlling U.S. technology exports is modernized in a way that enhances our ability to counter, rapidly and decisively, evolving security threats and to maintain our global technological leadership and industrial competitiveness."

The letter to the president includes a package of proposals that can be implemented by the executive branch without legislative action.

However, we have recommended that executive branch action on these issues be done so in consultation with Congress. We have endeavored to keep the Hill informed ourselves.

The letter is signed by the leaders of eight associations whose membership represent a broad cross-section of businesses — large and small — and their employees all across America.

The mission of the Coalition is to achieve a more efficient, predictable, and transparent export control system that is an enabling component of America's broader national security strategy.

What does that mean?

By efficient, the government must do a much, much better job at making decisions on export authorizations in a timely manner. The goal is a system that can deliver decisions on 95 percent of all license applications in 30 days, not the 55-plus days it now takes for defense items.

By predictable we mean that the license process must be consistent with applicable laws, regulations, and policies and be consistent in that comparable export applications under the same conditions receive the same or similar approvals in the same or similar time frames.

Transparent means, in part, that the rules governing the license process must be interpreted and used consistently, and that industry and foreign partners have quick, easy access to information on the status of their applications.

The export control system we operate under today lacks these three basic qualities. We can and we must do better.

Why is this so important? Because the current system is hurting our national security, our economic strength, and our technological competitiveness, and the problems are getting worse.

There are clear, short-term effects, but there are also longer-term effects that could be even more harmful. This is why the Coalition has formed and developed its modernization proposals

Let me say up front — export controls are necessary. They are critical to our national security. We must keep sensitive items out of the wrong hands.

However, equally important to our national security is sharing technology with our friends and trusted partners. Our failure to do so is hurting interoperability, capacity building, and our relationships with allies.

It is impeding cooperation and tech exchange with these same partners, thereby hampering the ability of U.S. industry to leverage foreign innovation to deliver the best equipment to our warfighters at the best value to the U.S. taxpayer.

This inefficient system is also hurting our economic and technological competitiveness.

When you look at the positive impact greater trade and technology cooperation has on U.S. companies of all sizes, you cannot help but be concerned about the future competitiveness of our industrial base and workforce in the absence of a more modern export control system.

To start chipping away at these problems, the Coalition developed specific proposals — 11 for defense trade and 8 for dual-use trade — that the administration could implement now without legislative action.

These proposals are mutually supporting, and progress on any one of these recommendations will enhance our security and competitiveness.

When you talk about modernizing the defense trade system, you must address the dual-use process and vice versa.

There are proposals in our defense trade package that cut across all agencies of the federal government.
  • Request that the White House state strategic policy principles on export controls.
  • Appoint a senior director at the National Security Council to handle export control issues.
  • Establish a presidential advisory body to create a dialogue between the executive branch, Congress, and industry on this issue.
  • Clarify rules on the commodity jurisdiction process.
  • Establish an interagency appeals process for precedent-setting decisions on authorizations.
But the defense paper also makes proposals that will require the leadership of the State Department to:
  • Hire additional licensing and agreements officers to handle the increasing workload.
  • Create new types of export authorizations for munitions items to reduce the total number of routine transactions in a manner consistent with U.S. security interests.
  • Develop a more robust electronic system for processing licenses that enhances transparency.
  • And, finally, ensure accurate, consistent interpretation of the ITAR regulations governing exports of munitions items.
Many of you are wondering "Why do you think you will be successful this time around? What is different now?" Let me make four points:

First, this time we have specific recommendations that are measurable, attainable, and meaningful.

Second, we are focused on process improvements that can help all of industry — and the U.S. government — not just demands for change on specific technologies, countries, or other slices of the broader issue that tend to divide folks.

Third, we want to work with the executive branch and Congress to improve the system. This administration understands the issues and, in keeping with the president's promises, made serious attempts at reform in the first term. We are now looking for another push in the second term. Industry wants to work collaboratively with the government on this.

Last, we are working as a coalition, speaking with the voices of the thousands of companies we represent and the millions of Americans who go to work every day to make this country great — and we intend to grow this coalition.



Digest of the opening statement of William Primosch, senior director of international business policy for the National Association of Manufacturers, at a Washington, D.C., news conference announcing the creation of the Coalition for Security and Competitiveness:
I will address the Coalition's recommendations for modernizing export controls on so-called "dual-use" items — products and technologies that have both commercial and military applications.

This part of the export control system is managed by the Commerce Department's Bureau for Industry and Security in cooperation with the State and Defense departments.

One of the reasons we have such a broad, multi-industry coalition is because all of us appreciate the linkage between defense and national security on the one hand and competitiveness and technological leadership on the other.

The United States depends on its industrial strength and technological leadership to ensure the best military in the world and provide our forces with the technological advantage over any adversary.

At the same time, we also appreciate the importance of trade and international collaboration for sustaining economic growth, innovation, and skilled employment in U.S. industry.

Nearly four million workers are employed in U.S. high-tech industries — those affected either directly or indirectly by export controls.

These industries account for about one-third of manufactured goods exports, or nearly $350 billion in 2006. They are our most dynamic and innovative sectors. So there is a big economic stake here.

Over the past 10-15 years the global economy has undergone major shifts with the rapid dissemination of technology and the emergence of new competitors, particularly among transitioning economies. High-tech products are now widely available in the global marketplace.

The way global manufacturing is conducted has also changed. More than ever companies depend on global supply chains and international collaboration to innovate and produce cutting-edge products with ever shorter life-cycles.

The export control system has not kept pace with these changes.

Our recommendations are geared to improving and modernizing the export control system for dual-use items. They are focused on administrative and procedural changes that can be made within existing legislation. No new laws would be required.

We have included eight recommendations in our initial proposals. We believe that all of these recommendations are doable. We are eager to have a dialogue with U.S. officials to discuss how they can be implemented in a way that protects national security and also helps modernize the system and make it more efficient, predictable, and transparent.



Recommendations for Modernizing Export Controls on Munitions List Items
The United States currently faces unprecedented threats to its security both at home and abroad. In confronting these threats, we must be able to exploit the full advantage we derive from our economic strength and technological prowess.

To that end, the U.S. export control system must be modernized so that it is better able to respond quickly and effectively to evolving security threats and promote our nation's continued economic and technological leadership.

The Coalition for Security and Competitiveness, representing multiple industry and trade associations, is committed to working with the executive branch and Congress in a cooperative spirit to accomplish these important goals.

To modernize the system and make it more efficient, predictable and transparent, the Coalition has developed the following eleven recommendations on export controls for munitions list items:
  • State strategic policy principles for defense and technology trade and cooperation.

  • Appoint a senior director at the National Security Council responsible for defense trade, export policy, and technology cooperation.

  • Create a presidential advisory body on defense trade and security cooperation.

  • Re-program funds for the Directorate of Defense Trade Controls to add a sufficient number of officers for agreements, licenses, and commodity jurisdiction evaluations.

  • Ensure accurate interpretation and consistent use of International Traffic in Arms Regulations that govern the commodity jurisdiction process.

  • Keep items, particularly FAA-certified equipment, on the Commerce Control List until after a final commodity jurisdiction determination is made.

  • Implement more efficient, effective, and transparent licensing procedures and technology disclosure review processes.

  • Establish a quarterly interagency appeals process (at the political appointee level) for decisions on critical jurisdiction and licensing applications.

  • Provide industry "intent to deny" and "intent to return without action" feedback before decisions are finalized.

  • Accelerate implementation of a more robust electronic system for processing and tracking license applications, including licenses that require congressional notification.

  • Require license and agreement processing to follow reasonable and predictable metrics.

Photo: The room was full for the March 6 Coalition news conference held in Washington, D.C.
The room was full for the March 6 Coalition news conference held in Washington, D.C.




This letter to President Bush was signed by the president of each of the eight Coalition members.
The White House
Washington, DC 20500

Dear Mr. President:

Today we are announcing the formation of the Coalition for Security and Competitiveness. We strongly believe that export control modernization is needed and that the opportunity is now. We must continue to protect our sensitive military technologies from our adversaries and rivals, while also maximizing the benefits of trade and technology cooperation with our allies and friends.

It is essential that our system of controlling U.S. technology exports is modernized in a way that enhances our ability to counter rapidly and decisively evolving security threats, and to maintain our global technological leadership and industrial competitiveness.

The Coalition is committed to working closely and cooperatively with the Administration and the Congress to provide a more efficient, predictable and transparent export control system that supports national security and competitiveness. In that spirit, we are forwarding a number of proposals to advance both of these important goals. These proposals can be implemented by the Executive Branch under existing statutory authorities. We strongly support decisive executive action to advance the recommended improvements. We would appreciate the opportunity to meet with you at your earliest availability to discuss our proposals.

Mr. President, we share your commitment to the safeguarding of America's security in the current environment. Industry stands ready to work with you to further our national interests of military and economic security. We believe a modernized export control system is an essential element of our strategy.



Recommendations on Export Controls for Dual-Use Items
To modernize the system and make it more efficient, predictable and transparent, the Coalition has developed the following eight recommendations on export controls for dual-use items:
  • Create a license exception for the transfer of controlled items within companies.

  • Certify foreign end-users with strong compliance programs for favorable treatment.

  • Enhance procedural transparency in the licensing process to help companies comply.

  • Enhance the Commerce Department's role in the "commodity jurisdiction" process for determining whether or not dual-use products should be treated as defense products and subject to State Department licensing.

  • Streamline the current complex controls on products with encryption features.

  • Ensure timely updates of the Commerce Control List to reflect market availability.

  • Expand factors used to determine "foreign availability" of controlled items.

  • Revise the "re-export" controls to level the playing field for U.S. companies vis-à-vis foreign competitors.



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