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J.A. GREEN & COMPANY, LLC Specialty Metals Compliance: What’s the problem? Jeff Green J.A. Green & Company, LLC March 2007
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J.A. GREEN & COMPANY, LLC 1. Why are specialty metals critical? 2. Supply chain management 3. Concern with DPAP guidance 4. What’s the real problem here? 5. A workable compromise OVERVIEW
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Why Are Specialty Metals Critical? Titanium 9 th most abundant element in earth’s crust High performance specialty metal Superior physical properties Rare Earth Magnets Four primary types used by DOD Magnequench sold to Chinese in 2000 Many don’t even know they’re covered
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Fighters & Transports F-18 E/F C-17 Military Transport F-15 F-16
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J.A. GREEN & COMPANY, LLC
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Titanium Nickel-based superalloys Steel Rolls-Royce Jet Engine
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M777 Lightweight Howitzer 7,000 lbs. of titanium per gun 1,000 + anticipated production units
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High Performance Magnets Aegis Radar - used widely by Army and Navy Aegis Radar - used widely by Army and Navy Valves in nuclear submarines Valves in nuclear submarines Hellfire missile guidance systems Hellfire missile guidance systems Military aircraft, including F-18, F-22, F-35 Military aircraft, including F-18, F-22, F-35 Power klystrons Power klystrons ground-based earth-to-satellite communications amplifiers and troposcatter communication terminals ground-based earth-to-satellite communications amplifiers and troposcatter communication terminals Minuteman IV ICBM Minuteman IV ICBM
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High Performance Magnets Consider number of US producers: 3 alnico magnet producers 3 alnico magnet producers 1 samarium cobalt magnet producer 1 samarium cobalt magnet producer 0 neodymium iron boron magnet producers 0 neodymium iron boron magnet producers 2 electrical steel producers (mills) 2 electrical steel producers (mills) If domestic magnet industry disappears, China will become a critical US defense supplier.
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Supply Chain Management Basic manufacturing ensures components are accountable Quality assurance Accounting – how do you pay? Auditing = accountability Customer specifications – production changes Accountability Defense contractors are sophisticated This is law
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Concerns With DPAP Guidance Dec. 6 th guidance Applies to all tiers of primes and subs Lacks transparent waiver process Adds arbitrary “third-tier” exemption Jan. 17 th guidance Expands definition of “required form” Adds consideration of “end item” price Joint Aeronautical Logistics Commanders Corporate-level multi-service waivers
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What’s The Real Problem? Compliance with the specialty metals provision has a cost But isn’t this passed-through? Leveraging DOD volume against the commercial production line Outsourcing our strategic materials to the lowest bidder
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J.A. GREEN & COMPANY, LLC A WORKABLE COMPROMISE 10 U.S.C. 2533a and 2533b Separates specialty metals and textiles Separates specialty metals and textiles Bitter battle between House/Senate and Aerospace/Specialty Metals Bitter battle between House/Senate and Aerospace/Specialty Metals Results- Results- 4 year “get-well” period 4 year “get-well” period Non-availability waiver for “form” Non-availability waiver for “form” Exemption for “commercially available electronic components” Exemption for “commercially available electronic components”
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J.A. GREEN & COMPANY, LLC 1. Why are specialty metals critical? 2. Supply chain management 3. Concern with DPAP guidance 4. What’s the real problem here? 5. A workable compromise SUMMARY
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J.A. GREEN & COMPANY, LLC For additional information contact: J.A. Green & Company, LLC Jeff Green – (202) 641-3215 jeff@jagreenandco.com jeff@jagreenandco.com QUESTIONS?
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