Published in the Daily Bugle, December 1, 2023
Go Fast and Don’t Break Things
This was to be the first installment of a three part deep dive into the CoCOM IL 1312(c ) (circa 1980) entry on control equipment for isostatic presses[1], but I’ve been engaged in a long answer to a short question and might as well put all that thinking to good re-use.
Dedicated Federal Register readers[2] know the 2022 Wassenaar updates to the EAR were published October 18, which not only deleted a comma from 9E003.c[3], also changed the licensing landscape for commercial supersonic engines and associated technology.
Before this, gas turbine engines (GTEs) for non-military supersonic aircraft unlike their subsonic brethren, had no release from 9A001 and NS control upon civil certification. This hasn’t been much of a problem lately, but advances in aircraft design promise to mute sonic booms, and design improvements allow engines to go supersonic without afterburners – which means acceptable fuel consumption and emissions, and no ITAR control. Many companies are working on civil supersonic aircraft, and just for once, we wanted the EAR ahead of the curve.
Engines are released from the NS control of 9A001 for supportability. When an engine is part of the aircraft, the aircraft’s control status – 9A991.b rules. Planes could fly all over the world with NS-controlled engines and not need re-export licenses. But engines break. Aircraft on Ground situations are very costly for airlines, and adding in a license application process to ship a part or spare engine would be untenable. The other bad news is the technology for 9A001.b engines was controlled in 9E001 and 9E002, also controlled for NS. The “production” “technology” control of 9E002 is particularly thorny, because “production” data remains controlled even when used for repair or overhaul. Because 9E002 is so broad, certain repair data, even simple stuff, would be caught[4].
By removing the supersonic reference, 9A001 applies (or not) to aero GTEs writ large and are released from 9A001 when the aircraft is certified, at the same time moving 9A003 parts to 9A991.c. With 9A001.b empty, the critical technology now lives in a stand-alone supersonic engine technology control – 9E003.k.
This had another very favorable result – clarity. The old 9E001 controlled “technology” for supersonic engines. It’s very hard to determine what information is “peculiarly responsible” for supersonic flight, and which is not. Is it the compressor design? The bolt torque for the ID plate? Your guess is as good as mine, and I’m supposed to know this stuff. Instead of a broad (and unclear) 9E001 “development” control, 9E003.k identifies exactly what “technology” is of concern.
A dirty little secret of supersonic engines is that supersonic engines aren’t supersonic. In a GTE for a supersonic aircraft, the inlet slows the supersonic incoming air down to subsonic speeds, where the engine does its engine thing, and then the nozzle accelerates the exhaust to supersonic speeds. Yes, the engine has to be designed for the flight profile, but there isn’t anything special about supersonic versus subsonic engine hardware. The design integration of the inlet, exhaust, engine, and airframe is very special, and that’s why it’s called out specifically. 9E003.k also lists out other enabling technologies, most of which are primarily military.
What you won’t see is a supersonic-specific “production” technology control. This was not an oversight. Really. Really, Really. “Production” technology is primarily controlled (1) when technology is applicable to both military and commercial items, and the learning one gets from making the commercial part could be diverted to making military parts, and (2) to prevent unwanted reproduction of a specific commercial part, because it may have a military application[5].
A lot of technology goes into “developing” an engine and inlets/exhaust to go supersonic, and that is controlled in 9E003.k. However, the resultant hardware doesn’t involve any supersonic-unique “production” technology. After much review, the “production” technology in the existing 9E003 covers all the critical aspects, and 9E003 is agnostic to if the GTE is supersonic, subsonic, on a boat, or bolted to the ground generating electricity. The only supersonic unique parts are the inlets and exhausts, and they aren’t unique or difficult to build; existing metal bending techniques work just fine, and if they use composites, we already have “production” controls in 1E001 and 9E003.a.3. All that’s left is part geometry, and that is fully exposed to the world to see and measure – inlet and exhaust part geometry isn’t controllable.
An inlet designed for a passenger aircraft, where the flight profile is intended not to spill your drink looks very, very different than one for a supersonic fighter, where the pilot wears a G-suit for a reason. The parts are NOT interchangeable. We don’t worry about someone being able to make copies the civil inlets and exhaust, as those parts are useful only on that particular civil aircraft – they would be useless for a military aircraft with a completely different flight profile.
Bottom line – there is no need for a “production” control because the existing controls are sufficient.
PSA – the FR notice asked for public comment on retaining STA eligibility for 9E003.k. What, streamline the sharing of information with our closest allies, who have strong re-export controls, and already built one decades ago? Whose Certification Authority we would need to share “development” data, for of all things, “safety”? Yes, please! The comment deadline is Monday, so get those typewriters going!
Got J&C questions? – please reach out to me at ArtOfJC@arinovis.com.
[1] In preparation for my planned four novel trilogy – Der Ring von Herr Lachman.
[2] I subscribe to the print edition with home delivery. You get the coupons that way.
[3] Go ahead, find it. I dare you.
[4] Yes, there is a carve-out for certain maintenance, but it’s hard to service an engine with just the data allowed.
[5] Dual use.