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MINUTES OF MEETING
Committee Title: Information Systems Technical Advisory Committee (ISTAC)
Date: November 7-8, 2007
Time: November 7th from 9:00 AM to 4:00 PM
November 8th from 9:00 AM to 3:00 PM
Location: November 7th in Rm. 4830, HCHB
November 8th in Rm. 3994, HCHB
Public Presentations:
ANS Proposal: Roz Thomsen presented an ANS proposal for restructuring Cat 5 Part 2
(C5P2) into a positive list. This proposal uses section 740.17.b.2. of the EAR (encryption
export control placed on high-end network infrastructure products) as the starting point
for the positive list, and adds the following changes:
– Provides a definition of “network infrastructure” with specific reference to standard
“encrypted throughput”.
– Provides a definition of “encrypted throughput”.
– With regard to “air-interface coverage”, removes customer-location equipment that is
based on the WiMax standard.
– Removes the provision for controls on Open Cryptographic Interfaces (“OCI”), which
is believed to be a uniquely US only control.
– Extends the 740.17.b.2 list by adding 1) managed VoIP infrastructure and 2) network
security infrastructure for government use.
Agenda Item Presentations/Discussions:
PUBLIC SESSION (All day on Wednesday, November 7th)
SEMI: Maggie Hershey of SEMI commented on the state of the industry, VEU and the
CCL comprehensive review. Key points were:
– Hot topics in the industry are: 450 mm vs 300 mm prime; solar energy and the
resultant silicon shortage; escalating R&D costs; and intellectual property protection.
– VEU aligns well with the industry structure (i.e., repetitive licensing for a small
group of customers). Dave Robertson commented that his customers state that they
are being advised by the Chinese Gov’t not to apply for VEU status. Don Weadon
noted that only the ECCNs associated with VEU authorizations have been released,
and that it would be useful to also know the conditions associated with the VEU
authorizations.
– SEMI’s recommendations for the CCL comprehensive review include: A new Core
List exercise, as the last one was 17 years ago, to be conducted in face-to-face
meetings rather than through correspondence and approached as a blank-piece-of-
paper. Another recommendation is creation of a new license exception “SEM” that
would facilitate export but still provide for a method to track exports.
– The export control workshop at SEMICON was successful and well-attended this
year, and is planned to be held again next year.
Raytheon: Jonathan Wise of Agilent talked through a presentation by Jon Goding of
Raytheon that had originally been presented at the DEAC meeting in Cambridge, MA on
June 19, 2007. The purpose of this was to introduce Raytheon’s issues and suggestions to
the ISTAC. It was agreed to defer consideration of these suggestions until next year, due
to the large number of encryption-related proposals currently under review. Readers are
referred to the minutes of the June 19 DEAC meeting for additional detail of the
Raytheon presentation.
History of Encryption Hardware: Noel Matchett of Information Security provided an
information/educational overview of encryption technologies, including historical and
current encryption hardware, systems, uses and customers. This presentation was well-
received and prompted much discussion. As this presentation was educational, no further
action was required.
Range and Standards: David Robertson of Analog Devices presented a technical analysis
of effective transmission range for various telecommunications standards, with the goal of
providing a framework for interpretation and review of the current proposal pertaining to
short-range wireless. The presentation began with an overview of the various
transmission modes (broadcast, point-to-point, point-to-multipoint, and multipoint-to-
multipoint), the various categories of network (PAN, LAN, WAN, MAN), and the
underlying IEEE standards. Three general themes were identified: Modulation schemes
are becoming increasingly sophisticated; the fact that silicon (hardware) is cheaper than
spectrum leads to increased use of sophisticated signal processing; and in any individual
link, there is a range/data-rate trade-off that is determined by creating the link and then
raising data rate as much as permitted by the actual S/N on that link. The conclusions
were: that range is not likely to be useful as a control parameter; that caution is necessary
to distinguish between specifications of transmission range and claims of transmission
range; that design intent may serve as a useful differentiator for nominal transmission
range (e.g., PAN/LAN vs. MAN/WAN).
MIMO Technology Overview: Frank Quick of Qualcomm presented a technology
overview of MIMO (Multiple-Input Multiple-Output). MIMO as a technique that uses
multiple antennae at both the transmission and reception ends to increase data throughput.
A critical requirement for MIMO is slowly-varying channels (i.e, low velocity). Frank
opined that MIMO is not of sufficient concern that it warrants consideration by
Wassenaar, but suggested that at higher levels (above 4x4) it might be considered for US
AT-level controls. Dave Robertson suggested at AT-level controls should not be pursued
because MIMO is already commercially deployed in some systems in China.
WA Proposals for 2008: Discussion time for the draft Wassenaar proposals for 2008 was
offered, but there were no new proposals and no comments. A summary of the draft
Wassenaar proposals for 2008 is in the minutes of the July 27, 2007 ISTAC meeting.
Systematic Review of the CCL: Discussion time for the CCL Comprehensive Review was
offered. There were no specific comments regarding the drafts reviews that have already
been submitted by the ISTAC to BIS. It was agreed that these drafts would be posted on
the ISTAC website. Michael Angelo agreed to provide comments for biometric devices
as they pertain to Cat 3 and Cat 4. Roz Thomsen offered to write white papers for
encryption proposals that are not forwarded to Wassenaar in 2008.
CLOSED SESSION (All day on Thursday, November 8th)
BIS Update: Matt Borman and Bernie Kritzer joined the meeting for a discussion of
topics of current interest.
– Bernie Kritzer commented on the following:
– The DEAC is in the final stages of preparing its report and it is expected that the
report will contain recommendations. He noted that a recurring theme among the
public comments to the DEAC was “higher fences around smaller areas”.
– There are many activities pertaining to encryption, including:
– Work on a rule to relax reporting requirements
– Review of the various industry-initiated Wassenaar proposals.
– Increased attention to foreign encryption licensing practices and recognition that
the 2000 encryption rule, although progressive then, is now dated and should be
updated.
– Michael Angelo commented that there has been a proliferation of ‘secondary
encryption”; that is, encryption in products whose primary functions do not
require encryption. Bernie responded that BIS recognizes an emerging trend of
chips and chipsets that would otherwise be 3A001 or 3A991 containing security
features that cause them to become 5A002, and that this will require a new
approach to encryption export control.
– Matt Borman commented on the following:
– Early indication is that the VEU program is being favorably received;
– Although China publicly complains about the VEU program, we believe they will
nevertheless allow companies to apply for VEU status because they recognize that it
is a benefit to China.
– The ISTAC comments for the CCL review are appreciated, but there is no formal BIS
response yet.
– The Coalition for Security and Competitiveness has made comments pertaining to
export control that may be of interest to the ISTAC; the URL is
http://www.securityandcompetitiveness.org/.
– Regarding the June 19, 2007 regulation, to date there have been no IVL applications
related to military end use in China.
Defense Proposals for 2008 WA List Review: There was a discussion of DoD’s draft
Wassenaar proposals for 2008. The results of this discussion are provided in Attachment
1.
Industry Proposals for 2008 WA List Review: The discussion of draft Wassenaar
proposals turned to DoD comments on the various industry-initiated proposals. The
results of this discussion are provided in Attachment 2.
ANS Proposal for C5P2: There was further discussion of the ANS proposal for a Cat 5
part 2 positive list. Frank Quick cautioned that the complex exclusion note in the current
C5P2 may not map cleanly into ANS positive list; therefore, we should be careful to
ensure that there is no inadvertent rollback in moving from the current list to the new list.
Michael Angelo agreed to review this. Joe Young opined that this proposal is the most
forward-looking of the encryption proposals and therefore the most deserving of further
effort. He suggested that with additional work, including resolution of the issue raised by
Frank Quick, we might want to submit the idea of recasting C5P2 into a positive list in a
white paper for discussion in 2008 with a more thought out formal proposal for the 2009
WA List Review.
(Note: Given the scope of some of the proposals, Joe Young suggested that some tasks should
be referred to the ISTAC working groups. It was agreed that the Cat 5 Part 2 working group
would look at the various encryption proposals that have been raised and in particular at the
ANS proposal for a Cat 5 Part 2 positive list. It was also agreed to ask Henry Brandt to lead a
review of computers and APP.)
Miscellaneous:
– Joe Young mentioned that the GAO has been requested by the House Foreign Affairs
Committee to study Chinese capability in semiconductor manufacturing equipment,
although the full scope of the study is still being defined. It is believed that there are
four firms in China that manufacture fab tools.
– Brian Baker of BIS provided a summary of the outcome of the fall Wassenaar EG
meeting. This information will eventually be published by Wassenaar and so is not
included here.
– Tim DiVincenzo of IBM provided a summary of the technical issues leading to and
the implications of the July 17, 2007 regulation that relaxed the single event upset
rate threshold in the USML paragraphs XI(d)(4). The purpose of this talk was to
review the situation. It is expected that there may be further discussion of rad-hard
issues when an industry-agreed protocol for testing is issued.
– There was a discussion of possible topics for the February meeting. There was
general agreement that the ISTAC would appreciate more classified briefings. The
Committee received a classified briefing on strategic export controls, particularly
regarding exports to China.
Next Meeting Date: The ISTAC will meet in SPARWAR, San Diego on Wednesday and
Thursday of February 20 and 21, 2008.
CLOSED SESSION
Attachment 1: Defense Proposals
Entry Short Title Comments
3.A.1.a.7. Update of FPLD This proposal originated as a French proposal in 2007, which
Control sought to relax some of the existing control thresholds. In the
ensuing review/discussion, it was found that the existing control
parameters are problematic. A US counterproposal was almost
agreed to, but was held up due to concerns over translation into
languages other than English. Nevertheless, there seems to be
broad agreement that the existing controls can be improved. It
was agreed to have side meetings with the affected US industry.
3.A.1.b.10. Phase Noise Jonathan Wise stated that industry had looked at this proposal
Instrumentation through the summer and had agreed in principle to an earlier
version. The current draft may need some adjustments to the
language but is otherwise acceptable.
3.A.1.h. High Temperature Discussion of this proposal was deferred because the affected
Power Switches US industry representation was not present. It was agreed to ask
Henry Brandt to forward this proposal to Power-X.
3.B.1.a.4. Atomic Layer Pat Sullivan wondered whether the existing CVD controls may
Deposition already capture ALD and explained that the DoD concern is that
ALD is an enabling technology and that this control, if enacted,
would close a loophole. There was near-unanimous industry
opposition to this proposal.
3.B.1.j. Wide Bandgap There were no specific comments.
Semi. Crystal
Growth Equip.
3.E.3 3-D Semi. IC IBM expressed concern about this proposal, explaining that
there is confusion regarding the definitions of terms, and also
that this technology is currently used in memory ICs. Intel and
IBM believe that there may be no portions of 3-D technology
that are “peculiarly responsible” for the features of export-
control concern. Concerned industry members were requested
to send comments to Al Courduff.
5.E.1 Ultraviolet Non- Industry raised concerns on whether the LEDs that are used in
line-of-sight the ultraviolet communication would be subject to control by
communication this entry. DoD experts explained that they would not.
5E1d Cats 3 & 5 tech. DOD notes that this proposal is to plug a loophole in current
carve out coverage of MMIC communications amplifiers. Industry
experts on MMIC were not present at this meeting; therefore
industry comments on this proposal were deferred.
CLOSED SESSION
Attachment 2: Industry Proposals
Entry Short Title Comments
3.A.2.d.3. frequency DoD needs additional information, specifically examples of
switching change products that would be decontrolled and examples of products
that would remain controlled (essentially, the product
landscape). Tektronix agreed to provide this information.
4.D.3.a. O/S software DoD indicated that they will support this proposal, but may
request language to clarify the implications of this decontrol vis-
à-vis Cat 5 Part 2.
4.A.3.g. external DoD disagrees with the core argument of this proposal, namely
interconnects that the items of concern would remain controlled by 4A3c, and
advised that this will not go forward. DoD further advised that
even a proposal to relax the existing 4A3g threshold would be
unlikely to go forward.
4.D.1.b. APP adjustment This proposal offers to change the WT threshold for software
and and technology controls from 0.04 to 0.1. DoD is generally
4.E.1.b. supportive of this proposal. The USG plans to consult with
Japan prior to submission to Wassenaar.
C5P1 Technical This proposal corrects cross-references in C5P1. DoD supports
corrections the corrections.
5.E.1.c.2.d. WDM threshold This proposal offers to change the WDM threshold from 8 to 40
carriers. DoD probably will support, but may ask for language
to clarify that certain imaging sensors are controlled in Cat 6.
5.B.1.b.2.b. Optical This proposal clarifies optical amplifiers controlled under
amplification 5.B.1.b.2.b. applies to praseodymium-doped fluoride fiber
amplifiers (PDFFA) only. DoD experts express no objection to
this proposal.
5.A.2. Note Short Range NSA representative was not present at this meeting.
(g) Wireless
Encryption
5.A.2. Note Performance NSA representative was not present at this meeting.
(h) monitoring
5.A.2.a.1.a. Key length NSA representative was not present at this meeting.
increase
C5P2 Note Equipment and NSA representative was not present at this meeting.
1 components in
C5P2
C5P2 Scope of control NSA representative was not present at this meeting.
C5P2 Recast of C5P2 This is the ANS positive list proposal. NSA representative was
not present at this meeting.
