Art Pizza dedicated more than 38 years serving the U.S. Army in its Armament Research, Development and Engineering Center (ARDEC) (which is now known as the Combat Capabilities Development Command, Armaments Center) at Picatinny Arsenal. In that time, he spent 17 years as a project engineer on the Mk19 grenade machine gun. He spent five years on the Green Ammo project (5.56mm and 9mm). Then he became the center’s Technical Expert on 40mm ammunition. He later went back into design and became the ARDEC Project Officer on hybrid ammunition (including mortars) and the extended range guided 40mm projectile. Pizza spent the last five years before his retirement as the Project Integrator for Medium and Small Caliber Weapons, Ammunition, and Fire Control systems.

We sat down with Pizza to discuss his long and distinguished career.

Small Arms Defense Journal: Art, thank you for your service to the U.S. Army and the 40mm weapon platforms. We greatly appreciate you taking the time to connect with Small Arms Defense Journal. You have the unique perspective of spending significant time in both 40mm weapons and 40mm ammunition. To solve the age-old question – when there is a system failure, who’s usually to blame, the ammo guy or the weapon guy?

Art Pizza: Around the late-1970s or early ‘80s, when the U.S. Army transitioned the Mark19 40x53mm weapon from the Navy, they were hand fitting/gunsmithing each weapon making 3-7 guns a month at Navy Ordnance Station in Louisville, Kentucky. They were beautiful, hand-built weapons; however, the production numbers were nowhere near the rate the Army needed. The Army was looking to make over 250 weapons a month. They end up contracting to Saco Defense (now General Dynamics Saco, ME). The complete Technical Data Package needed to be reworked. They worked closely with Saco Defense in manufacturing the weapon and improving the mass production and tolerances to make it at a high production rate weapon.

At the same time, we needed to increase the production rate of 40mm High-Velocity ammunition. The Mark19 is an advanced primer, blowback-operated weapon in which the bolt never locks into the receiver and depends on the firing pin tripping as the heavy bolt is moving forward. The velocity of the bolt moving forward is critical to the functioning of the weapon. The contracted 40mm ammunition at that time was purchased as individual components and sent to Milan AAP for final load, assembly and packing into cartridges. Most of the issues pertained to the consistent crimping of the cartridge case (a new 360-degree roll crimp vs. the old, staggered stake crimp.) Unfortunately, the failure to obturate because of the crimp issues caused stuck projectiles in the Mark19. If a second round was fired into the first projectile, on rare occasions it could cause a low-order explosion. This was called an in-bore detonation.

Other ammunition issues early on were related to improper charge weight. They old systems were using a volumetric charge measurement system. These cartridges also often had missing or double copper closure cups, and material flaws in the aluminum cartridge cases. We were looking to increase the production of ammunition from 40,000 units a year to close to 1 million. The solution was to have completely automated loading with net-weight, check weight systems and liner voltage distance transducers (LVDTs) to have a machine check for presence and location of these items.

Mark 19 issues mainly pertained to the timing of the feed system on the weapon resulting in dropped rounds and what we called at the time banana cartridges (because they would get bent by the weapon). Both caused feeding issues and could cause a lodged projectile or even a dropped round. The Mark19 represented new challenges to the infantry in the form of a high explosive machine gun in a small package of 65 pounds. Another issue was using the right lubrication in the field. The Mark19 called for LSAT lubricant, which was in short supply. A lot of feeding issues were based on a lack of adequate lubrication or lubrication not in the right location on the receiver rails or feed tray. Every gun coming out of the Saco factory was function fired for firing rates. If I remember right, we fired three guns 50,000 rounds each for endurance testing each year.

The bottom line was that most of the early stoppages were attributed to ammunition. Improvements to modern manufacturing methods and inspection reduced these to almost non-existent in the early stages. The weapon went through changes, as well. The cocking lever was modified to a two-piece design that reduced the possibility of an out-of-battery firing. Lubrication became more prevalent, and attention was spent on the timing of the feed system. If you had a problem with the Mark 19, it could usually be attributed to either the feed shuttle timing, a dirty weapon, or a broken part. One time I was called in to look at some weapons having issues. It turned out they did not have LSAT lube and were instead using WD40 and Break Free. They would run through maybe a box or two of ammo (32 to 64 rounds) before the gun stopped. We brought one tube with us, and we painted it on using a paintbrush to get through the training until a supply was sent in.

Over time, I was involved in several malfunctioning investigations and would try to get on-site within 48 hours. As an infantry weapon, we were not doing round counts (of how many rounds had been fired through the weapon) so we would never know what to expect, especially at training locations. I would say 80% were attributed to ammunition. If you are making over 1 million rounds a year, it is possible to get one or two bad rounds. The fuses were made back then at KDI and were difficult to manufacture but had double safeties (spin and setback). Most in-bores were attributed to a low order detonation from a round striking a stuck projectile lodged in the barrel.

Therefore, to answer your original question in the 40x53mm platform, at that time, it would have typically been the ammunition guy causing the problem.

SADJ: As an ammo guy, I will humbly accept the criticism. As far as the rest of the story, all I can say is wow! That is an amazing summary of decades of work. Over the course of your nearly 40 years in 40mm, what do you feel was your greatest accomplishment?

AP: The transitioning of the Mark19 to the Army and the rework of the technical data package. Getting it into full-rate production and fielding to the U.S. Army was a terrific feeling. Seeing what you worked on and talking to soldiers about the use of it in combat and how it saved their lives meant a lot to me. I met with some soldiers that were involved with the rescue mission of the “Black Hawk Down” incident in Somalia. The largest weapon they had available on the ground was two or three Mark19s mounted on HMMWVs. They were using it as an anti-sniper weapon and fire was directed by a captain using a laser pointer. The captain talked about the leveling of a hotel in Somalia that was stopping their rescue attempt and which they were receiving heavy fire from. The Mark19 took down the entire building. Knowing what we did at ARDEC saved a lot of U.S. lives, and knowing it was instrumental to the rescue operations, made it all come together for me. I still remember talking to this captain about what the Mark19 enabled him to do. It was hard not getting teary-eyed for him and me while listening to his story.

SADJ: Looking back over your career, was there a particularly fun project that you remember?

AP: The Extended Range Guided 40x46mm cartridge (EGR40) was the most fun. This projectile was for the handheld M79, M203, and the M320 low-velocity 40mm weapon. I was the technical expert for some time in 40mm ammunition engineering and I was asked if I wanted to lead a design team in the development of the early R&D effort. It was an easy choice going from riding a desk to getting back into a real hands-on engineering development project.

My senior design engineer, Ronny Alzamora, and I designed a new finned projectile and cartridge case with an improved combustion chamber. We had a team of engineers working on guidance navigation and control, camera, transmitters, laser receptor, and also working on wings and canards. Every week we were cutting metal and going to the range firing projectiles. It was all hands-on design work which you just didn’t usually see in the government. We had between 20 and 40 people working on various parts of it, along with a contractor and universities. We even did some early work with some students from West Point as a capstone project. We also looked at a rocket assist system. It was a lot of work. We pushed the envelope… a lot. We worked the engineers very hard. I was very lucky to have had that opportunity and it was a lot of hard work getting the separate teams focused on the end game. I learned a lot about human relationships and forming a team.

SADJ: What project was the most challenging?

AP: It was, by and large, the EGR40 because of the hands-on work we did.

SADJ: Are there any projects that you wish you could’ve had a second chance at it?

AP: What we learned about the LV 40x46mm, we never got a chance to put into practice. We found that course correction could not be accomplished in the time of flight and was not enough to make a difference at impact. We did successfully put a camera in the projectile, survive launch, and transmit and receive video and course correction signals. What we did learn was that the current 40mm round is spin-stabilized and lost spin and wobbled, making it difficult to hit a target at 400 meters. When we made our fin-stabilized projectile, we were more accurate out to 600 meters and had some variations that we were able to fly to 1,000 meters. Toward the end of the R&D project, we were pushing to drop the guidance (wings and canards) and convert to just a tail-fined projectile that had the ability to double the range of the standard HEDP projectile. We were able to increase HE and fragmentation by designing a new larger warhead. We could not get the funding to pursue this option and the team was dispersed. They tried to make improvements to the existing spinning projectile but could not demonstrate any major improvements with a spinning projectile. A finned projectile is more accurate and will fly further than a spin-stabilized one.

SADJ: Are there any other areas of your work that you would like to share with our readers?

AP:What we (Army Engineering) do has an impact on soldiers’ lives even if we don’t know about it. Don’t believe that it can’t be done. So many times in my career I was told that this or that wouldn’t work. I was told we would never get a camera to survive a gun launch. We were told we would not be able to transmit a clear image. You have to look at new innovative ideas and methods. Modeling, simulation, and design of experiments are the keys to success. You have to get away from the build-and-break mentality and think about the design of experiments. You need to test statistically with multiple variants to reduce iterative designs. Design decisions are made on statistical-based results.  

SADJ: Can you paint of picture of what the 40mm systems families will look like 40 years into the future?

AP: What I envision for a 40mm low-velocity grenadier M203/M320 weapon:

• 1-2 camera rounds with a GPS location that will transmit enemy positions back. Detect behind berms, buildings, or in defilade.
• Several extended-range projectiles with a higher velocity and flatter trajectory with increased range out to 1,000+ meters. Finned projectile with improved warhead and increased lethal radius.
• Several HE dual purpose projectiles with improved armor penetration.
• Possible netted projectile or an airburst anti-UAV projectile
• Specialty blast overpressure round for room clearing or tunnels.
• Specialty non-lethal projectiles.
• Specialty flechet round for room clearing. HEDP is useless in urban areas, room clearing, etc.
• Specialty door breaching projectile (may be able to do this with a blast overpressure).
• An improved fire control system that would allow the rounds to take on a semi-mortar-like role.

And, for the Mark19 High-Velocity system:

• A camera round that can be used for GPS and intelligence. These rounds will be able to provide intelligence out to 2000 + meters.
• An anti-UAV projectile; blast overpressure, net, etc.
• Flechet round for urban areas.
• Flare rounds, including IR flares, with higher altitudes and longer burn time. These are not currently in the HV systems. This would give night vision extended range.
• Improved cartridge case hemispherical powder chamber.
• Extended range, fin-stabilized rounds for ranges over 2,000+ meters.
• Improved fire control system to allow indirect fire applications.

By the time you read this, the XM25 Counter Defilade Target Engagement System with its uncannily accurate airburst ammo will undoubtedly have drawn its first blood in Afghanistan.  This sci-fi looking individual armament, initially the “grenade gun” upper half of the ill-fated Objective Individual Combat Weapon, has been in combat operational test mode for several months now with selected elements of US Special Operations Command.

It‘s the hottest new man portable grenade launcher anywhere, boasting indirect fire capabilities with “smart” ammo that can kill enemies smugly squatting behind walls and boulders, until now unreachable by squad level weapons.

At their recent press briefing and live fire event at historic Aberdeen Proving Ground, Maryland, top officials of PM Soldier Weapons told Small Arms Defense Journal and reporters for other military and defense industry publications how the XM25’s unique capabilities would have been of particular value to defenders in the now-famous “Keating” firefight.

Among many lessons learned in the near-annihilation of this small, fortified camp in what’s formally known as the Battle of Kamdesh, Afghanistan, they said, is the need for unit level indirect fire capability that is highly flexible and immediately available.

Combat Outpost Keating
More than 300 Taliban fighters launched a surprise attack on Keating in the predawn darkness of October 3, 2009, saturating the small base with mortar rounds, RPGs and heavy small arms fire.

They quickly breached the perimeter, routed the panicked Afghan Army detachment and nearly overran the American soldiers of Bravo Troop, 3rd Squadron, 61st Cavalry Regiment.

The AN/PSQ-20 Enhanced Night Vision Goggle, seen helmet-mounted in this posed publicity photo, provides significantly improved capability by combining traditional image intensification and long-wave infrared sensors. The resulting output is electronically presented to the wearer in color, giving a much higher recognition probability for man-sized targets out to 300 meters or better. The Multifunction Aiming Light on this soldier’s M4 carbine works with the ENVG, showing a bright aim point even in total darkness. (PEO Soldier)

Bad weather and slow response from artillery and air support assets combined to give the enemy special advantages in their initial assault from the high ground “bowl” around the camp, leaving the defenders below with little more than basic individual and crew-served weapons to fight back with.

Their direct fire arms and single shot M203 grenade launchers were of limited value against battle-seasoned attackers who skillfully used abundant cover from boulders and depressions in the surrounding rough terrain and defensive positions inside the wire.

Relief came slowly but soon built to a decisive level as artillery, helicopter gunships, jet fighters and bombers combined to rout the enemy.

When the smoke cleared an estimated 150 Taliban were dead at the cost of 30 U.S. troopers killed or wounded.

Cost/Benefit Ratio
Richard Audette, Deputy PMSW, responding during the press conference at Aberdeen, to implied criticism in a reporter’s question noting the projected $25,000 cost per XM25, called it a bargain compared to far more expensive weaponry wielded by external support elements like those that turned the tide at Keating.

“They were hitting the attackers with Apache gunships, Hellfire missiles and Excaliber artillery rounds,” he said, “far more costly, cumbersome, and slow to arrive.”

5 May 2010, Aberdeen Proving Ground, MD. Iron-jawed Master Sergeant Paul Wilcock, Senior NCO for PMSW, stands ready to demonstrate the door-busting capabilities of the 12 gauge M26 Modular Accessory Shotgun System in stand alone configuration. MASS is a straight-pull bolt action, magazine fed shotgun that can also be fitted underneath the barrel of M16/M4 series assault weapons. (Robert Bruce)

“The XM25,” he emphasized, “is an immediately available, squad level weapon that pays for itself, but more importantly it saves solders’ lives because it can take out those defilade (behind cover) targets.”

Lieutenant Colonel Christopher Lehner, Product Manager Individual Weapons, underscored the XM25‘s remarkably fast target engagement capability against fleetingly-glimpsed targets.

“In under five seconds I can lase for range, get my adjusted reticle on target and pull the trigger,” he said.  “At four hundred meters it takes another two seconds to get there and explode.  Seven hundred meters another second or so.  It really doesn’t give the Taliban a lot of time to reposition himself.”

Then, adding his perspective on the XM25‘s $25,000 price tag, Lehner invited a comparison to the total cost of the current, less capable combination of weapon and accessories.

“Add up the cost of an M4 carbine with M203 grenade launcher, STORM laser rangefinder, plus night vision and aiming modules,” he said, noting that the XM25 fully integrates these components with the added benefit of a ballistic computer and airbursting ammunition.

SADJ has been closely following the sixteen year saga of this 100 million dollar engineering marvel and we are pleased to know that it has finally made its way into the hands of the snake-eating fraternity.  If all goes well, we’re told, it will be available in limited quantities for muddy-boots grunts in the 2013-14 time frame.

Lehner explained that the plan for fielding this exotic grenade launcher was under development but not to expect it to become a standard squad weapon.  “It’s potentially an arms room weapon,” he said, “like a shotgun or other specialized weapon that you’d draw for certain missions where you need the (XM25’s) unique capability.”

While the wizardry embodied in the XM25 is spectacular, there are several other developments from the dedicated team at Program Manager Soldier Weapons that also deserve special recognition.

Mulberry Point Range
PM Soldier Weapons had wisely set aside several consecutive days for hands-on demos for congressional and military VIPs, efficiently utilizing the considerable time and expense required for such things.  These focused opportunities gave a wide variety of purse-keepers and decision-makers the chance to see for themselves what was in the weapons development pipeline.

Press day was a continuation of the process, with PMSW hoping that knowledgeable reporters would convey to the public how America’s defenders were armed.  More than a dozen reps turned up, from outlets ranging in credibility and seriousness from USA Today to Army Times, with Small Arms Defense Journal in there on the right side of the scale.

5 May 2010, Aberdeen Proving Ground, MD. Engineers Emmanuel Marasigan (left) and Brian Forsberg of Product Manager Crew Served Weapons, demonstrate the highly realistic computer simulator for low-cost, remarkably effective training on the XM25. Cleverly, it draws on the growing popularity of the ‘America’s Army’ interactive video game that anyone can play online: www.americasarmy.com. (Robert Bruce)

After the obligatory meet, greet and ground rules briefing, Aberdeen Test Center’s Mulberry Point Small Arms Range went hot with a HE (high explosive) demo shot from the XM25.  Safety concerns kept us inside the ballistic glass windowed observation building.  (continued on page 69) 

We could see the gunner just outside the thick glass window and his actions were explained in real time by Lieutenant Colonel Lehner.  Using the weapon’s highly sophisticated fire control system with on-board laser rangefinder, he said, the shooter gets exact distance to the front wall of a simulated building with an open window.

With the simple push of a button he adds a meter to the range and the chambered “smart” round is electronically programmed with the precise distance from launch to detonation point.  In this case right through the window and inside the room.

The fire control’s ballistic computer calculates angle of elevation based on range and displays a red dot in the electro-optical sight with the correct aiming point.  Windage can be programmed as well.

When the round was fired, a computer chip in the 40mm HE warhead counted revolutions in flight and initiated detonation at approximately the center of the “room,” showering it with lethal fragments.  A remote video camera linked to a large screen in the observation building provided dramatic evidence of the effectiveness of this programmable airburst weapon’s precision lethality.

Then, we were herded outside to observe a series of live fire demonstrations of selected current weaponry, starting with the lock-busting 12 gauge M26 Modular Accessory Shotgun System and moving down the firing line to see grenade launchers, machine guns, sniper rifles and the new “dazzling” laser on a hulking armored vehicle.

M240 Light
While highly reliable and very accurate, a standard 7.62mm M240B medium machine gun weighs a hefty 27 pounds, making it a burden for dismounted troops on the move.

PM Crew Served Weapons has responded with the M240L (Light), incorporating a titanium receiver and other refinements to drop 5.7 pounds without sacrificing combat performance.

28 July 2008, Fort Hood, Texas. John Moses Browning’s 80 year old “Ma Deuce” M2HB machine gun might eventually be able to enjoy retirement when this new .50 caliber XM806 is fielded in the not-too-distant future. Derived from the convertible .50 caliber XM312 – 25mm XM307 Advanced Crew Served Weapon, it’s about half the weight of the M2 and boasts reduced recoil that facilitates mounting optical sights for superior accuracy. This new weapon is of particular interest to U.S. Special Operations Command as well as the Army‘s light infantry formations. (PEO Soldier)

Further weight reduction is realized when pairing it with the new M192 Lightweight Ground Mount tripod, boasting better stability and an improved traversing and elevating mechanism at a weight saving of six pounds.

Old Warhorse Returns
Soldiers and Marines of a certain age (including a few of us at SADJ) should take special pleasure in seeing the honored return of the post-WW2 generation’s venerable M14 rifles.

This hard-hitting, long reaching 7.62x51mm NATO caliber battle rifle was pushed aside by the pipsqueak 5.56mm M16 in the Vietnam War when it was deemed that an “assault rifle,” characterized by light weight and high volume of fire, was better for jungle fighting.

But now that the battlefields are in Iraq and Afghanistan – mostly treeless, arid plains and mountains – the M16 and its little brother M4 are noticeably lacking in necessary range (maximum approximately 500 meters) and knockdown power.

Spurred by urgent Operational Need Statements from combat units, the Army started pulling mothballed M14s out of storage, adding day scopes, and rushing them off to CENTCOM’s AO for use by “Squad Designated Marksmen.”

This eminently practical solution has since been kicked up a notch at PM Soldier Weapons by creation of the Enhanced Battle Rifle, a classic M14 retro-fitted at the Army’s Rock Island Arsenal with a modern chassis stock and capable of mounting a full range of day and night sights.  More than 5,000 have been fielded so far and 1,700 more are in the pipeline.

LTC Lehner says that the EBR’s dramatically increased effective range, as much as 800 meters in capable hands, has forced the Taliban to “change its tactics,” backing way off when initiating an attack.

More Sniper Stuff
The 7.62mm M110 Semi-Automatic Sniper System (SASS) from Knight’s Armament – apparently just about everything it needs to be already – will be outfitted with a collapsible buttstock, deemed better for close quarter engagements.

The awesomely powerful .50 caliber Barrett M107 Semi-Automatic Long Range Sniper Rifle is going to lose a little weight, get a specially designed suppressor and a new protective exterior coating.

The new rifle, which will bear the official service designation L129A1 is being manufactured by Lewis Machine & Tool Co. in the United States.  According to LEI, the L129A1 is based on a proven design, with new features, including a one piece upper receiver and a “free floating” barrel, which offers better accuracy at longer ranges.  LEI was short listed and then awarded the contract with final award on the basis of overall performance and price.  Deliveries start early in 2010.

Aimpoint
Aimpoint has been awarded a new contract from the U.S. Army for supply of up to 565,783 M68 Close Combat Optic rifle sights.  The Aimpoint CompM4s was chosen following an extensive evaluation and competitive trial of available optical sights by the Army Research & Development Command (ARDEC) at Picatinny Arsenal, NJ.  Aimpoint was the only manufacturer whose product fulfilled the Army’s rigorous testing criteria during this evaluation, and is the only manufacturer to be selected as a qualified vendor for this contract.

The sight chosen by the Army, the Aimpoint CompM4s, features a battery compartment positioned near the sight base, which gives the sight a streamlined profile and places the switch and battery in a more protected position.  A ruggedized switch knob has been integrated as part of the battery compartment housing and features seven night vision compatible settings and nine daylight settings.  The modular QRP2 mount maximizes product application for all M4 Carbines and M16 rifles, and eliminates the need for a separate mounting ring.  The electronic components in the CompM4s include the latest ACET diode circuitry, which allows the sight to run continuously for up to eight years on a single battery, and features an internal voltage regulator that makes it possible to utilize any AA sized battery found worldwide for power.

The sight features a 2 minute-of-angle (MOA) dot size, making it perfectly suited for use with Aimpoint’s 3X Magnifier (3XMag), Aimpoint Concealed Engagement Unit (CEU), and all generations of night vision devices.

Alliant Techsystems
Alliant Techsystems received an initial $105 million contract award as part of a three-year contract by the U.S. Army Sustainment Command in Rock Island, Ill., to supply various types of non-standard (non-NATO) ammunition for the security forces of Afghanistan.  If all options are fully exercised, the contract value could potentially exceed $200 million.  This is ATK’s second contract from the U.S. Army to supply non-standard (non-NATO) ammunition for the security forces of Afghanistan.  The first $87 million contract award was announced in December 2008.

In this new contract, ATK will integrate a larger team of international manufacturers for the delivery of non-standard (non-NATO) munitions, including small, medium and large-caliber ammunition, as well as mortars and rockets.  ATK’s program and technical expertise, coupled with its global supply chain management capability, will ensure continued timely deliveries of quality non-standard (non-NATO) ammunition to Afghanistan.

“ATK continues to expand its global presence through international outreach initiatives,” said Mark DeYoung, President ATK Armament Systems.  “By using ATK’s core strengths and the in-depth knowledge gained during the original Afghanistan non-standard ammunition program, we are providing low-risk armament systems solutions to meet the continuously emerging requirements of our customers.”

DS Arms
D S Arms, Inc. is proud to introduce the ZM4 AR-15/M16 upper receiver.  The high quality flat top upper features melded feed ramps for enhanced reliability and a forged 7075-T6 Mil-Spec flat top upper.  To ensure maximum durability and accuracy, each barrel is Nitride finished providing a smoother and more consistent surface finish than chrome plating.

BLACKHAWK!
BLACKHAWK! announced the selection of the BLACKHAWK! SERPA retention holster system and select accessory components for use by the United States Joint Special Operations Community.

In a head-to-head comparison, the BLACKHAWK! SERPA system was selected by a panel of active duty service personnel representing the various SOF Commands.  Key to the SERPA selection was the active weapon retention, system modularity, speed and commonality of training.  The basis of the system is built around the award winning SERPA Auto Retention holster which combines an intuitive drawing motion when presenting the weapon with automatic engagement of the locking mechanism upon re-holstering.  Mounting platforms include a traditional belt mount, drop leg platform and a MOLLE chest mount.  Color selection for all models and accessories include Black, Olive Drab, Foliage Green and Coyote Tan.

“The active retention of the SERPA Holster combined with BLACKHAWK!’s Quick Disconnect system allows SOF to configure their equipment based on mission or environmental needs,” stated Steve Matulewicz Executive Director of Operations for Blackhawk.  “The versatility of the Quick Disconnect system allows operators to rapidly move their weapon from a thigh or belt mounted platform when on foot patrol to a vest mounted position for easy access when on a vehicle mounted operation.”

The SERPA holster system and components are now fully authorized for use within the Joint SOF arena, approved for purchase at the Command/Unit levels and will become an issued item as part of the U.S. Government Load Carriage System (LCS) supplied to all of SOF.

Remington Arms Company
Remington Arms Company, Inc., through a wholly owned subsidiary, has entered into a purchase agreement to acquire certain assets of Advanced Armament Corp (AAC).

Located in Norcross, Georgia, AAC supplies noise reduction, flash reduction devices, and combat-related accessories for the military, government and commercial markets.  AAC will continue day-to-day operations at their Georgia-based location under the guidance of company founder, Kevin Brittingham, and report to the Remington Military Products Division (MPD).

“We welcome Kevin and his team of engineers and designers on board,” commented Theodore (Ted) Torbeck, CEO of Remington and its parent, Freedom Group, Inc.  “With the acquisition of AAC, we can enhance our research and development capabilities and deliver a more competitive product to the end user; further strengthening Remington’s position in the domestic and international markets.”

Reported Violation of UN Sanctions Against Iran
Hansa India, a ship owned by the German company Leonhardt & Blumberg, and chartered to the Islamic Republic of Iran Shipping Lines (IRISL), was boarded in early October 2009 by U.S. troops in the Gulf of Suez.  During the search, eight containers of 7.62×39 ammunition was discovered.  It is believed that the ammunition was destined for the Syrian Army or the Lebanese militant group Hezbollah.  German government authorities ordered the U.S. Navy to divert the Hansa India to Malta, where Maltese customs officials seized the cargo.

New DDTC Guidance on the Submission of Technical Assistance Agreements
On October 9, 2009, the Directorate of Defense Trade Controls (DDTC) released revised guidelines for the submission of Technical Assistance Agreements (TAA), Manufacturing License Agreements (MLA) and Warehouse and Distribution Agreements.  Similar to the DTrade2 system, electronic submission of TAA and MLA will become mandatory in 2010.  Additional information may be found online at the DDTC website: www.pmddtc.state.gov/licensing/documents/PreparingElectronciAgreements-Guidelines.pdf

Proposed Changes to the U.S. State Dept. Regulatory Definition of Brokering
On November 23, 2009, the U.S. State Department announced proposed changes to the definition of “Broker” and “Brokering Activities.”  A copy of the proposed regulatory changes may be found on the DDTC website:  http://pmddtc.state.gov/DTAG/documents/Brokering_FRN_November_09_Version.doc

According to the DDTC explanation printed within the Federal Register notice, it appears that the definition of “brokering” will be modified such that the International Traffic in Arms Regulations definition will mirror the Arms Export Control Act definition.  Look for more in-depth analysis within a future Legal Affairs column.

New Processing Times for U.S. State Dept. Export Permits
On December 7, 2009, the U.S. State Department, Directorate of Defense Trade Controls announced that a sixth exception was being added to the National Security Presidential Directive – 56, which mandated a 60-day processing time for export license applications.  The 60-day processing time will not apply “when a related export policy is under active review and pending final determination by the Department of State.”  The obvious question is whether Hillary Clinton, the U.S. Secretary of State, is contemplating (or has already initiated) a wholesale review of current export regulations.  While the future cannot be predicted with any certainty, one could reasonably assume that if a wholesale review of the current U.S. export regulations is being contemplated, future export license applications are likely to be scrutinized and examined in detail, with extra long processing times being the norm, rather than the exception.

For those unaware of the five current exceptions to the 60-day rule, they are:

(1) Congressional Notification is required.

(2) Required Government Assurances have not been received (i.e. Missile Technology Control Regime Assurances, and Cluster Munitions assurances.)

(3) End-use Checks have not been completed. (Commonly referred to as “Blue Lantern” checks.)

(4) The Department of Defense has not yet completed its review.

(5) A Waiver of Restrictions is required.

U.S. Commerce Dept. Bureau of Industry and Security
BIS released an advisory opinion on the download of mass market encryption software by international customers.  Of note, BIS states that, “Publishing ‘mass market’ encryption software on the internet where it may be downloaded by anyone neither establishes ‘red flags’ necessitating the affirmative duty to inquire under the ‘Know Your Customer’ guidance provided in the EAR (see 67 Fed. Reg. 38857, June 6, 2002).  Therefore, a person or company would not be in violation of the EAR if it posts ‘mass market’ encryption software on the Internet for free and anonymous download and then at a later time the software is downloaded by an anonymous person in Iran, Cuba, Syria, Sudan, or North Korea.”  The complete advisory opinion may be found online at: www.bis.doc.gov/policiesandregulations/advisoryopinions/encryption_internet_ao.pdf

Malaysia Becoming a Major Hub of Diverted Goods to Iran
According to a Bloomberg published article, Iran is increasingly obtaining U.S. military equipment and technology through shipments to Malaysian middlemen that illegally circumvent trade restrictions.

The U.S. has charged, convicted or sentenced defendants in at least six cases involving Malaysia since August 2008.  The shipments have included parts for bombers and items sent to firms linked to Iran’s nuclear and ballistic missile program, according to court papers.  More Malaysia shipments are under investigation, according to a law enforcement official who spoke to Bloomberg on condition of anonymity.

The shipments illustrate how difficult it is for U.S. law enforcement to keep military secrets and equipment from reaching Iran, a country the U.S. accuses of developing nuclear weapons and sponsoring terrorism.  As most readers know, the U.S. bans most trade with Iran.  Those involved in the international trade of firearms and other defense articles are advised to know your customer as to avoid becoming an unknowing pawn in the transshipment of defense articles to Iran.  Readers that export to Malaysia are advised to regularly review the various watch lists posted to the Bureau of Industry and Security website: www.bis.doc.gov/complianceandenforcement/liststocheck.htm