BLUE LANTERN LEVEL 2: PRE-LICENSE END-USE CHECK

UNCLAS STATE 069991

SIPDIS
ABU DHABI FOR OLIVER JOHN

E.O. 12958: N/A
TAGS: ETTC KOMC TC
SUBJECT: BLUE LANTERN LEVEL 2: PRE-LICENSE END-USE CHECK
ON APPLICATION 050105887

REF: 2006 BLUE LANTERN GUIDEBOOK


1. This is an Action Request. See paragraphs 2-4.


2. The Department's Office of Defense Trade Controls
Compliance (PM/DTCC) requests post's assistance in conducting
a pre-license check on application 050105887 for the export
of fuel pump bearings to the United Arab Emirates. Post is
requested to complete this Blue Lantern check within 30 days.
Lack of response to a Blue Lantern check will affect pending
and future licenses involving parties to this license.


3. Reason for request: Concerns over true end use of fuel
pump bearings listed on license. The bearings on application
appear to be custom manufactured and specifically designed
for the PAR radar (AN/MPQ 35) which is part of the Hawk
Missile System. It appears unlikely that such a bearing is
used in the fuel pump of the aircraft center wing fuel tank
(as stated on license) since the bearing measures more than
two feet in diameter. Also, the application states the part
is intended for use on the IL-76TD aircraft, a Russian
manufactured civilian derivative of a cargo plane, which does
not commonly use such bearings. Adding to concerns over this
transaction is the fact that Iran operates the Hawk Missile
System and may be seeking similar bearings.


4. ACTION: Embassy is requested to make inquiries with
appropriate officials to determine if ByAero Aviation, the
end user, and Ringfield General Trading, the foreign
consignee, have ordered the items listed below and plan to
use them in the IL-76TD aircraft. Department requests that
Embassy conduct a site visit to both companies in order to
assess their business operations, on-site security, and
general reliability as a recipient of United States Munitions
List (USML) items. ByAero POC is John Brehun, Operation
Manager, TEL: 971-4-2347172, reference contract # R76TD-6815
dated March 20, 2008. No POC information was provided for
Ringfield; therefore post is encouraged to leverage knowledge
of locality to contact appropriate Ringfield representatives.
The following questions are offered as suggested guidance
with ByAero and Ringfield:

- Can each party confirm that the items will be used for the
IL-76 aircraft? If so, where will this aircraft operate and
for what purposes?

- Who are ByAero and Ringfield's main clients?

- Do they appear to understand the restrictions on United
States Munitions List (USML) articles, particularly regarding
re-export and retransfer?

If site visits are not possible, please inform PM/DTCC case
officer. END ACTION.



5. Details of license application:

DTC Case: 050105887

QUANTITY/COMMODITY:

10 PN: 101084333 NSN: 3110-00-967-9194 Description: Annual
Ball Bearing, 21.5 inch bore diameter bearing. Bearing used
with fuel pump of wing center fuel tank on Russian aircraft
(Ilyushin IL-76D)

License Value: USD 108,000.00

SELLER:

WBParts, Inc
2300 Commerce Park Drive Unit 15
Palm Bay, FL 32905

FOREIGN CONSIGNEE:

Ringfield General Trading Co LLC
Office No. 707 AL Dana Center AL Maktoum Street
Deira, Dubai UAE

FOREIGN END-USER:

ByAero Aviation Group of Companies
AL Dana Center Box 172529
Dubai, UAE

PURPOSE:

ByAero, a charter company in Dubai, will use items on the
IL-76D as a replacement bearing for the fuel pump of the wing
center fuel tank.



6. Please slug reply for PM/DTCC - BLUE LANTERN COORDINATOR
and include the words "Blue Lantern" and the case number in
the subject line. Department can fax documentation to post
upon request. POC is Tim Watkins, Phone: 202-663-2814;
Email: WatkinsTR@state.gov; SIPRNET:
WatkinsTR@state.sgov.gov. The Blue Lantern Guidebook (ref)
is available as a PDF file in the Bunche Library's E-Book
Collection on the DOS Intranet:
http://buncheelectroniclibrary.state.gov/eboo ks/
BlueLanternGuidebook2006%20 final .pdf


7. Department is grateful for post's assistance in this
matter.
RICE