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Last Updated: Mon Jan 27 11:18:09 UTC 2014

Is the Gordon England Letter
on F-22 Export to Australia
Fair Dinkum?

Air Power Australia - Australia's Independent Defence Think Tank

Air Power Australia Media Release

14th February, 2007

Contacts: Peter Goon Mob: 0419-806-476 / Dr Carlo Kopp Mob: 0437-478-224

In the light of rising public criticism of the proposed acquisition of the F-35 Joint Strike Fighter, from a wide range of sources, the Defence Minister has disclosed to selected journalists the existence of a letter from US Deputy Secretary of Defence Gordon England, purporting that the US will not sell the F-22 Raptor to Australia, said a spokesman for Air Power Australia today.

"It is now incumbent on the Defence Minister to table this document. The quoted source, Mr Gordon England, is merely a Deputy Secretary in the US Department of Defence. Decisions of this magnitude involving the export of leading edge military technology are decided by the Congress, not the civil service, and ultimately by the Office of the President himself."

"If Australia wished to buy the F-22,  this matter can only be negotiated at the highest level, directly between the Prime Minister and the US President."

"The letter, in fact, appears to say little more than there is no current plan to export the F-22, which given the prior history of this issue in the US could change at any time."

"Australia, Britain and Canada remain the most trusted allies of the United States, and there is no known precedent for the US flatly denying, by arbitrary ruling, the export of a major weapon system to any of these allies. In every known instance, the system was exported, but sometimes alterations were made to protect sensitive items."

"Does the Minister seriously believe that all top end US military systems will never be made available to the most trusted US allies, such as Britain, Australia, Canada, and as is currently under consideration, Japan? Historically this has always happened."

"The statement by the Deputy Secretary appears to have been made without the formal process of export evaluation for Australia, which is a requirement for all sensitive Low Observable (stealth) technologies."


"The US initiated an effort during the late 1990s to establish a formal internal government agency protocol to assess whether aircraft using these technologies can be exported to specific allies, and if so, with what specific design alterations to protect sensitive technology."

"The 'LOEXCOM' protocol, as it is known and is detailed in a public study authored by then LtCol Matthew Molloy, US Air Force, published in June 2000, was detailed as a four step process [1].

"The Molloy paper articulated the policy in detail, and concluded that only three US allies were considered at that time trustworthy enough to be sold the F-22. These allies were Australia, Britain and Canada."

"The much publicised 'Obey Amendment' to the defence appropriations bill does not detail policy, but prohibits the spending of US taxpayer's funds on marketing the technology in the F-22 overseas. The LOEXCOM protocol was developed in response to a request by Wisconsin Congressman, David Obey, who wanted a formal policy in place for determining what could be exported to whom."

"In the last days of the Clinton administration, President Clinton publicly stated that the F-22 would be exported to Israel. Since then Japan has been actively lobbying in Washington for the export of the F-22 to Japan as a replacement for Japan's  F-15CJ fleet."

"Last year the issue of F-22 export to Japan resulted in some very intensive debate in US defence circles, and a Congressional committee subsequently decided to remove the 'Obey Amendment' from the appropriations bill. In further Congressional debate, another committee reinstated the amendment, by a narrow margin in the vote."

"A number of US analysts are of the view that the US should export the F-22 to Australia and Japan to ensure stability in the Pacific Rim region, which has seen the largest buys of modern aircraft and missile technology since the last decade of the Cold War in Europe."

"There is a strong strategic case - in the US national interest - that Australia and Japan should acquire F-22 variants."

"It is known that during the 1999-2001 period the US Defense Department did go through the first step in the four step LOEXCOM protocol, and performed an Integrated Product Team assessment of the F-22's exportability to Australia. It is also known that this assessment, initiated at the request of the then RAAF leadership, concurred with Molloy's assessment that Australia was a safe export target for the F-22A."

The Integrated Product Team study defined two configurations of the aircraft, configuration 'A' with almost full capability, and configuration 'B' with a number of sensitive stealth and software features removed. Australia would have been offered the 'A' configuration, with some features turned off but available to Australia in time of conflict."

"The Gordon England letter, if it has been cited correctly, raises a number of challenging questions which should of very serious concern to Australia's foreign policy and defence community:
  1. The first question is whether Australia's standing in the eyes of the Bush Administration has been diminished, to the extent that the favourable conclusions of the Molloy paper and 1999-2001 Integrated Product Team analysis of the exportability of the F-22 to Australia no longer apply?
  2. The second question is whether the established four step LOEXCOM protocol still remains in existence, and if it has been abandoned, what actual protocol will be applied in the future on the export of stealth technology in aircraft such as the F-22 and Joint Strike Fighter. If the F-22 will not be available in even a 'reduced stealth' configuration to Australia, will the Joint Strike Fighter be available in a 'full stealth' configuration?
  3. The third question is whether this effective policy change will remain applicable in the future. Historically, all restrictions on the export of sensitive military technologies have eventually been waived, particularly in the case of the closest allies of the US.
The Gordon England letter sets an important precedent, as this is the first time Australia has ever been flatly denied access to a major US weapon system, rather than offered the system even with some detail features altered to protect US technology.

In practical terms, the Gordon England letter, as cited, qualifies the unavailability of the F-22 to Australia as 'our current position', which means that a future policy change is not ruled out."

"This means that policy changes at a Congressional or Administration level over the next two years could result in changes to the cited US position."

"What has not changed is Australia's strategic need for the capability in the F-22, which cannot be provided by the Joint Strike Fighter or the F/A-18F Super Hornet."

"What has also not changed is that the premature retirement of the F-111 results in around a 50 percent reduction in Australia's strike capability."

"The non-viability of the current Defence plan, which will cost $22 billion or more, should the Super Hornet be acquired, remains also unchanged."

"The need for fundamental policy change in Australia's planning for the future of the RAAF remains a key imperative. Australia must actively seek policy change in the US to gain access to the F-22, longer term."

[1] "The 'LOEXCOM' protocol, detailed in a public study authored by then LtCol Matthew Molloy of the School of Advanced Air power Studies at the Air University at Maxwell AFB, published in June 2000, was detailed as a four step process [1]:
  1. An Integrated Product Team comprising Air Force, defense department and defense contractors examines export issues for a specific ally.
  2. Integrated Product Team findings are then submitted to a Defense Department Tri-Service Committee for review.
  3. The Integrated Product Team and Tri-Service Committee findings are submitted to the Low Observable Executive Committee (LOEXCOM) for review.
  4. These findings are then submitted to the State Department for an Exception to National Disclosure Policy Committee review.
After the State Department has approved the export, the Foreign Military Sales [FMS] sales protocol would apply, which is that Congress must approve the sale."

Cited: "Air-exports with advanced or stealth technologies, such as are found on the F-22, require a specialized, component-by-component review as specified by export regulation. This process starts at the service level (in the F-22's case it would be the USAF) who will initiate an export feasibility evaluation through a four-step process. First, an "Integrated Product Team," consisting of members from the Air Force, DOD, and defense contractors, will be created to examine potential export issues specific to the aircraft under consideration. Next, the Product Team will notify the Tri-Service Committee on their findings. This committee reviews the weapon system and its technologies comparing them to the Critical Military Technologies List, the Low Observabilities (LO) List, and the Counter-LO List and then makes a decision whether the aircraft needs to be reviewed by the Low Observable Executive Committee (LOEXCOM), the third step in the process. For aircraft as advanced as the F-22 and JSF, LOEXCOM review is required."

"Once the weapon system has been approved by LOEXCOM for export, the review process moves to the State Department which forms an Exception to National Disclosure Policy Committee. This committee is comprised of the CIA, the NSA and other senior government representatives."

"After the State Department approves the export, state-to-state negotiations between the U.S. and the importing country may begin. Since the F-22 sale will be under the auspices of FMS, negotiations remain at the government level (including USAF inputs)."


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