…amend the International Traffic in Arms Regulations (ITAR) to update the definitions of “defense article,” “defense services,” “technical data,” “public domain,” “export,” and “reexport or retransfer” in order to clarify the scope of activities and information that are covered within these definitions and harmonize the definitions with the Export Administration Regulations (EAR), to the extent appropriate.
This rule change would expand the definition of what digital information could be classified as ITAR restricted, including but certainty not limited to the firearms industry.
One aspect of these proposed changes that was implied but not blatantly addressed is the restriction it could place on 3D printed firearms and components. Technical data including “blueprints, drawings, photographs, plans, instructions or documentation.” would become restricted from “export”, or being published on the internet, which includes 3D printer files for firearms and components. We’ve already seen a restriction on 3D firearms plans when Defense Distributed was told to remove the plans for the Liberator Pistol from their website.
But what can I do?
You can comment. This rule change hasn’t taken effect yet and you can let the Federal Government know how you feel about this proposal by providing feedback.
If you are going to do so, we suggest these pointers:
You’ve got until, August 3, 2015 to submit your feedback. Comments may be submitted online at regulations.gov or via e-mail at DDTCPublicComments@state.gov with the subject line, ‘‘ITAR Amendment—Revisions to Definitions; Data Transmission and Storage.”
Read everything posted about the proposed changes. It’s dry, but know what you are referencing.
Post your comments.
Begin your comments with “I am in opposition of the proposed changes” so that, in the odd chance that you agree with some points and oppose others you will not be considered in the “I love the proposed changes” column even though you don’t agree with all of it.
We suggest you point out the hypocrisy of such a move considering the extensive amount of commercial and government (think US Patent and Trademark Office holdings and military publications) data already available.
Concentrate on the free speech implications of the proposed change.
Consider the negative implications for academia, research, industry and individual Americans.
We suggest you use your own voice, keep it civil, direct and to the point, and use proper grammar to be most effective. Do not use a form letter. They carry less weight than individualized comments.
I initially heard about the H2gO from a Soldier Systems Daily article on April 9, 2013. I immediately bought into the Indigogo campaign which promised to deliver the system used in the MSR Miox into a more user-friendly unit with a flashlight, storage compartment for salt, an internal rechargeable battery, and a solar panel. The H2gO is everything I want in the “purifier” market; it’s portable, easy to use, and requires little outside supply or disposable items besides salt. Are you near brackish water? I haven’t tried it yet, but I’d put dollars to doughnuts this would create your chlorine solution with a slosh of brackish water and not need any additional salt! I still recommend mechanically/physically filtering your water to remove small detritus, but the H2gO is perfect for the biological components I’ve never had a sustainable answer to.
On a full charge the battery will provide for treatment of approximately 150 liters of water. Though the settings will correctly dose chlorine solutions for 1, 2, 3, 5, and 10 liters you can easily add doses to make for appropriate solutions. Using the three setting, then the five setting, to achieve an 8 liter solution, for example. Whether you’re purifying one liter or 5 gallons it will take approximately an hour for the added solution to kill biological contaminants in your water. The buttons on the face sport incredibly intuitive pictographs leading you through the process and telling you how long to press the buttons for what effect. The kit comes with test strips to tell you if there is a high enough concentration to feel good about the water; there’s no way to tell for sure the quality of the water so the strips instead test for how high the chlorine level is. I wouldn’t use them every time, but if I was especially suspicious that a water source might be biologically contaminated and couldn’t find another better source I would be happy the strips are there.
I salute Rodney Herrington, Aqua Research, and his faithful for pulling together a tech wonder bordering on magic. There have been unbelievable delays due to equipment loss, manufacturer change, helping those living in the wake of natural disaster, and plain bad luck. I received my unit the first week of January and I feel it was worth every moment of that wait and I look forward to the chance to buy additional units on the open market.
When the Army initially launched the Soldier Protection System program in 2013, contracts for soldier systems items were falling off drastically and companies were more than happy to participate with the promise of developing a new, leap ahead system consisting of multiple components. It was exciting. SPS was touted as the future and industry wanted to be a part of it.
To give readers a frame of reference, here is a basic description of Soldier Protection System – Torso and Extremity Protection:
SPS-TEP is a PEO Soldier sponsored development program managed by LTC Kathy M. Brown, PM Soldier Protective Equipment. While it includes armored combat clothing (BCS), Blast Pelvic Protector (BPP), and new Load Distribution System (LDS), the heart of SPS TEP is the Modular Scalable Vest, one of four systems which integrates into the SPS TEP and consists of a low profile vest with four soft armor panels (one front, one back, and two side cummerbunds) covered in a camouflage cloth and hook and loop. Like current systems, soft armor panels are inserted into a tactical outer carrier that also accommodates hard armor protective inserts. The tactical outer carrier also contains two side plate pocket that will accommodate soft armor inserts. The outer carrier is made of a flame resistant outer cloth, webbings, hook/loop, polyethylene stiffener, a quad-release system, and several other non-ballistic materials.
There is also a Load Distribution System designed to offer the capability to redistribute the weight burden on the torso vest and load bearing while being carried horizontally, close to the body’s center of mass. The LDS is an integral part of the SPS TEP design with the LDS belt containing soft armor that provides fragmentation and handgun protection to the lower back and abdomen region. The LDS will provide Warfighters with the ability to mount additional equipment directly to the belt using the MOLLE retention system. The ruck integration component includes: a frame adapter, torso vest compatible shoulder straps, and an LDS belt adapter.
Unfortunately, the program faced an early misstep when the original solicitation was released, canceled and then a revised version reissued not long after. Industry trust was shook when elements of industry bids were integrated into this new requirement for all to see. What companies considered advantages over others in the process were now there for all to integrate into their proposals. Interegtating good ideas is something that should have happened earlier in the requirement process, during the Sources Sought phase, when industry is expected to help government refine their requirement by serving as a barometer and forming a vision of the state of the art. It’s not fair to write a requirement, open a solicitation and then close it, rewrite the requirement with elements of proposals and then resissue it with those new elements. But, this isn’t the first point of contention in the SPS TEP program. It’s an issue that has been constant throughout all components of the overarching program strategy. The big issue is that they were trying to save a buck on Personal Protective Equipment.
Across the board, within all SPS components and in spite of language in the 2014 and 2015 National Defense Authorizations Acts calling for the use of “Best Value” contracting, the solicitations have been issued under “Lowest Price, Techically Acceptable” criteria. This is an oversimplification, and I’m sure a contracting officer will comment, trying to justify the Army’s defiance of the Congressional language, but LPTA means that your body armor is assured to be made by the lowest bidder.
(Former PM SPIE COL Robert Mortlock (right) and current PM SPE LTC Kathy M. Brown (center) explains SPS-TEP to Vice Chief of Staff GEN Daniel B. Allyn (left) during a June 2015 visit to PEO Soldier.)
With SPS-TEP, the Army has taken LPTA to a new level. Despite having three vendor teams (Hawk, Point Blank and Safariland) with competitive systems that met all of the solictation’s requirements, PEO Soldier decided to enter a fourth, government owned solution cobbled together from different components. Naturally, that is what they selected. Of course, industry was disappointed. Why wouldn’t they be? They had spent millions of dollars to prepare their submissions. The heart of this winning government solution is a developmental USMC modular scalable vest that the Marines do not plan to field. After testing the vest, the Marines chose rather to purchase additional Plate Carriers.
These photos show Maj James Pelland, former team lead for Marine Corps Systems Command’s Individual Armor Team demonstrating the Modular Scalable Vest. Below, you can see him negotiating an obstacle course wearing the MSV. The bottom portion of the Load Distribution System is also visible in the photo, which allegedly still has some issues. Additionally, Maj Pelland doesn’t appear to be wearing any plates in the MSV.
On 21 July, 2015, Bethel Industries, Jersey City, New Jersey, (W91CRB-15-D-0019); Hawk Protection Inc., Pembroke Pines, Florida, (W91CRB-15-D-0020); and KDH Defense Systems Inc., Eden, North Carolina, (W91CRB-15-D-0021), were awarded a $49,000,000 shared firm-fixed-price contract for the Soldier Protection System modular vest by the US Army. These lowest bidders are manufacturing the Army’s design. It all sounds great for the bean counters. In fact, everyone would be impressed if what they were buying was what the Army said it actually needed at the outset of the program. Unfortunately, it would take a requirement change to do that, and that’s just what they did.
In spite of all of the other issues, this next bit is probably the most disheartening part of the entire affair. The “Army” system didn’t meet all of the requirements of the solicitation, so they changed them mid-program. There are several minor conundrums such as the Load Carrying Equipment not quite working in concert with the Marine Corps body armor vest, and an immature Load Distribution System, but the most dramatic of these changes is the decision to drop the requirement for female fit body armor. The MSV option the Army has selected, doesn’t feature a female fit at all.
(PFC Cheryl Rogers grins as 2LT Chelsea Adams helps her into the new Generation III Female Improved Outer Tactical Vest, Nov 28, 2013. The Soldiers, who are part of the 1st ABCT Female Engagement Team, Third Infantry Division, were preparing to deploy to Afghanistan.)
The Army, who not long ago drew praise from Congress for their multi-year effort to develop a female version of the Improved Outer Tactical Vest (IOTV), decided to leave female Soldiers high and dry in the future by simply eliminating the requirement. They’ve put years into developing female body armor and now, they just toss it aside. To make matters worse, they are still under contract to work on improving female body armor fit with the firm, Body Lab.
Consider this; as of fiscal year 2014, women represent about 14 percent of the active Army, 23 percent of the Army Reserve and 16 percent of the Army National Guard as of fiscal year 2014. With the Army working to open additional positions in combat formations to women, this move can only be seen as a step backward.
Ultimately, SPS remains a developmental ‘science project’ with limited buys and actual system testing to commence after the new year. There is no promise of full type classification and issue across the force. However, while the Army was sure to have learned much from the program, and in particular from the commercial designs it evaluated, millions of dollars and countless hours were expended by both industry and government in pursuit of this requirement. It would be a pity if it turns out in further testing that the Army backed the wrong horse while trying to save a couple of bucks. Their actions regarding PPE contracts have certainly garnered the attention of those on the Hill who hold their purse strings. To make matters worse, they’ll probably have to explain why they failed to capitalize on their work to offer PPE for females and end up spending even more taxpayer money when several viable options were at their fingertips throughout the down select portion of this program. Conducting program after program where there is no return on investment for industry is starting to wear thin.
Shellback Tactical now has Banshee Plate Carriers in Black and Coyote in-stock and available for purchase. MultiCam and Ranger Green will be available in a few weeks.
Tactical Maturity And Growth
Aaron Barruga
July 22, 2015
As a young recruit going through the Special Forces Qualification Course, I was naively upset with how uncool I thought training was. I wanted to learn how to fast-rope out of helicopters and hotwire cars; instead I endured months of boring training that emphasized small unit tactics that the Army learned from Vietnam. There was nothing special about this training because it focused on basic infantry patrolling techniques.
During a class about movement formations, an instructor caught me falling asleep. I was appropriately punished with a healthy amount of calisthenics, and afterwards he pulled me aside and said:
“I get it, with you young guys you expect to do something cool, and that’s alright. But first, I need you to show me that you can handle the basic stuff before we teach you anything else.”
Although studying Vietnam-era tactics lacked sex appeal, it formed the invaluable foundation from which I would build combat judgment and tactical maturity.
Tactical Adolescence
Two years later I was a junior Operator in Special Forces. At range events my primary focus was often on how cool I felt wearing body armor instead of the day’s learning objectives. Tied to ego, wearing kit satisfied the most dominant territories of my vanity, but completely obstructed my mastery of fundamental tactical skills.
I spent an obnoxious amount of money on gear during the first year I was on an ODA. Despite being issued shopping carts full of equipment from my Unit, I would still seek out commercial gadgets purported as newer and better. This behavior attracted a healthy amount of criticism and I was often the subject of jokes in the Team Room.
However, my teammates understood the underlying cause of my behavior. Because they too had been “the new guy,” my teammates understood that my behavior was both infatuation and anxiety. In my mind, maximizing the layout (or uniqueness) of my kit correlated with improved combat performance.
Although gear is a prerequisite for battle, it is not be the determinant that influences our judgment. Gear does not lead a chalk of Rangers onto a beachhead in France, or a platoon of Afghan militia in the Hindu Kush. Gear certainly does not help you make hard decisions, in which there are no respectable outcomes.
What Others Think
In Iraq, my ODA was located on a small FOB that was relatively secure. Our team house was the target of sporadic rocket and small arms fire, however, we were able to walk around in normal clothes with just a pistol on our hip. A few compounds from my team house lived a contractor named “Carl” (real name redacted) that would perform logistical tasks for my team. Despite force protection protocol only requiring a pistol for personal safety, Carl wore body armor at all times.
Driving on the camp, body armor. Liaising with other units, body armor. Eating in the chow hall, body armor.
This individual was so enchanted with the idea of combat (something he would not participate in) that he didn’t realize he was portraying himself as a liability. Because he behaved outside of the social norms of our FOB, and lacked professional credibility (in regards to realistic combat expectations), individuals that understood his situation did not take him seriously.
However, Carl was real popular with the lowest ranking soldiers on the FOB. Because these soldiers lacked judgment and were still developing their tactical maturity, Carl looked like the real deal.
My recollection of Carl makes him an easy character to dislike. However, I’m sure that at certain points in my career I was disliked for exhibiting similar qualities. Fortunately I had mentors that would recalibrate my errant focus and misperceived abilities.
In order to mature tactically, we need to reevaluate both the physical aspects of our shooting abilities, and the mental constructions we have about ourselves. If a shooter is incapable of identifying areas for improvement in both of the aforementioned, he is being dishonest with himself.
So… when have you been a Carl?
Aaron is a Special Forces veteran and competitive shooter. He teaches classes in Southern California for law enforcement and civilians. Check out his company’s website and Instagram for more information. (www.guerrillaapproach.com, instagram.com/guerrilla_approach)
This article was first posted at the RE Factor blog and is reposted here at the request of the author and full cognizance of RE Factor in the interest of increased dissemination. I want to thank Aaron and the team at RE Factor for thinking of us.
