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How ITAR Impacts Pakistan’s T129 ATAK Purchase from Turkey

In light of current tensions between Ankara and Washington – which escalated to Washington ordering a stay on the delivery of F-35A Lightning II fighter aircraft to Turkey through its newly-signed 2019 National Defence Authorization Act (NDAA) – observers are concerned that Pakistan’s recently-inked purchase of 30 T129 ATAK attack helicopters could be in jeopardy.[1] The concern primarily stems from the fact that the T129’s powerplant, the Light Helicopter Turbine Engine Company (LHTEC) CTS800 turboshaft engine, falls under the jurisdiction of ITAR (International Traffic in Arms Regulation). Exporting (be it first-party or third-party) items under ITAR require the approval of the US government.

However, it must be noted that no official decision has been made to stay third-party transfer licenses of the CTS800 to Pakistan at this time. Nonetheless, this is an issue worthy of substantive consideration – it follows the fact that the US has shut a NATO ally and well-integrated co-production partner out of the F-35 Lightning II program (albeit, for the time being). Thus, a block on the third-party transfer of CTS800s to Pakistan is plausible given the White House’s animosity to both Ankara and Islamabad, but the details could bring the program to fruition (unless Washington forces another unconventional turn).

How is ITAR Relevant to Pakistan?

Simply, exporting systems and services falling under the jurisdiction of ITAR require the approval of the US government. ITAR is a control regime designed to restrict access to sensitive technology, be it out of a concern of guarding US secrets or ensuring that US geo-strategic interests are not affected by the export of certain equipment (especially military equipment and critical technology inputs).

Regarding third-party transfers, the US State Department reduces the issue to the following:

“In considering a request for approval for any transfer of any weapon, weapons system (etc)…to another country, the President will not give his consent … to the transfer unless the United States would itself transfer the defense article under consideration to that country.”[2]

In practical terms, Turkey did not have a problem securing (or thinking it could secure) a third-party sale license for Pakistan. Firstly, the US had already cleared Pakistan to receive a spate of directly comparable ITAR-restricted equipment, such as the General Electric T700 turboshaft engines powering the Bell AH-1Z Viper attack helicopter. Secondly, the US did not sanction Pakistan. Rather, it has drastically cut down the military aid it was providing to Pakistan, but Pakistan has still been able to procure items (e.g. spare parts for its F-16 and C-130 aircraft) from the US, see export-import (EXIM) registries below:

According to the EXIM registry, on August 12 the Pakistan Air Force (PAF) imported aircraft parts from the US from the company SOI Aviation. SOI Aviation is a dealer managing spare parts for the C-130 and the F-16, which would indicate that the PAF is able to procure spare-parts for its fighters from the US, and that too through direct commercial channels (i.e. outside of Foreign Military Sales). Thus, in terms of what has been approved for sale to Pakistan, Pakistan is able to procure (albeit through its own funds, not military aid). Thus, the direct procurement of the CTS800 from the US should not be a problem.

Granted, the White House might act punitively towards Turkey by blocking third-party export licenses for the CTS800. However, Pakistan is not (albeit currently) under sanctions. In this case, Turkish Aerospace would have to set-up an assembly line at Pakistan Aeronautical Complex (PAC) configured to fit the T129’s engines (which would be ordered separately from the US) and requisite testing and certification facilities. Washington would have to exceptionally punitive to block such an arrangement.

Turkey’s Contingency Options for Supplanting the CTS800

Turkey has a contingency, or rather, a long-term plan to supplant the CTS800 in place through its national turboshaft engine program. Turkish Engine Industries (TEI) is spearheading the effort.[3] In February 2017, Turkey’s Undersecretariat for Defence Industries (SSM) awarded TEI and TA/TAI to develop a 1,400 shp turboshaft platform that would not only power Turkey’s future helicopters, but its fixed-wing trainer – i.e. the Hürkuş – as well.[4] The goal is to develop a family of turboshaft engines reaching up to 2,000 shp (i.e. for large transport helicopters, such as TA’s 10-ton General Purpose Helicopter).

However, the project scope is eight years.[5] In other words, TEI’s turboshaft engine does not fit within the framework of Pakistan’s T129 order. In fact, it is unlikely that the indigenous turboshaft engine is intended for the T129; rather, the goal appears to be to develop a family of new-generation helicopters – i.e. T-625, ATAK-2 and 10-ton General Purpose Helicopter – centered on a common engine and dynamic parts suite. In other words, to secure the TEI turboshaft engine, one would have to wait for the ATAK-2.

Thus, any contingency to the unavailability of the CTS800 would have to be an existing engine. However, such a scenario would require non-recurring engineering (NRE) fees for design, integration, testing and certification. It would also require time and, ultimately, may cut too close to the ATAK-2 (and TEI’s engine) for it to truly be a beneficial outcome. It would essentially be a case of procuring the T129 for the sake of the T129, not the fact that it (and the CTS800) offered strong high-altitude and endurance performance.

In effect, it is the CTS800 or no T129. There will be criticism towards the Pakistan Army for selecting the T129, but one must consider other factors as well. First, as discussed in an earlier Quwa Premium article, Pakistan is utilizing Turkey’s existing production capacity and, in turn, it is procuring variants identical in configuration and capability to those meant for the Turkish Armed Forces (TSK).[6] Second, the helicopters were being bought in incrementally-sized batches (i.e. five or six aircraft per year). Third, Ankara offered a credit or financing mechanism to back the purchase. However, this is unlikely to be a conventional loan; rather, since the Pakistani T129s are identical to those of the TSK and are rolling-off the production at the same time as those for the TSK, the “loan” is likely a fiscal transfer to TA. In other words, should Pakistan fail to procure the T129s (e.g. insufficient funds or permits), then the T129s would be rolled into the TSK’s inventory. In effect, both Turkey and Pakistan took a relatively low-risk approach.

In lieu of the T129 or alternative attack helicopters, the Pakistan Army Aviation Corps (PAA) would need to endure with its legacy AH-1F/S until a truly ITAR-free option is available (e.g. in China or Turkey). There can be an alternative in a non-ITAR version of the CTS800. In fact, LHTEC is a joint-venture between Rolls-Royce and Honeywell. However, it would require NREs and time to build an ITAR-free CTS800.

Alternative Attack Helicopter Options for Pakistan

Should a scenario where both the AH-1Z and T129 are untenable, the Pakistan Army would need to revise its next-generation attack helicopter plans. However, Pakistan’s current macroeconomic challenges would also limit the armed forces’ ability to undertake big-ticket procurement, so a near-term pivot (even from China) could be difficult. Nonetheless, the approach laid-out with the AH-1Z and T129 was one where the PAA would maintain a combination of heavyweight and lightweight platforms. If this is to continue (which may not be the case seeing that it the AH-1Z was likely procured through Foreign Military Financing, i.e. military aid), then an off-the-shelf heavyweight design could be sought. Russia’s Mi-28NE – especially in a configuration where it has engine commonality with Pakistan’s Mi-171s – could be a plausibility, but there are no signs of substantive traction in procurement from Russia at this time.

Alternatively, the PAA could abandon the idea of a bifurcated (i.e. heavyweight and lightweight) fleet and instead consolidate on a single next-generation platform. Be it the ATAK-2 or an improved variant of the Chinese Z-10, the Pakistan Army could wait. Moreover, the Army could emulate the PAF’s Project Azm initiative by joining these programs with the aim of having a domestic attack helicopter (albeit one made via a foreign partnership). Granted, it would force a delay in a crucial piece for wartime as well as internal security and counterinsurgency, but such delays are not new to the Army (see: al-Khalid main battle tank, the 8×8 armoured fighting vehicle, the 155 mm self-propelled howitzer, etc).

However, working with PAC and a foreign partner (China or Turkey) for an ITAR-free attack helicopter can enable for sharing development overheads and scale. In turn, Pakistan can push for domestic production as well as a sizable workshare commitment to support its domestic aviation industry growth.

Although it would be a fit with the Kamra Aviation City initiative, the Army is likely warmer to a more tangible, near-term outcome (i.e. off-the-shelf). Ultimately, both Turkey and Pakistan are likely betting on Washington’s policies at this time to be temporary in nature and, in the case of the CTS800, a non-factor (at least from a first-party sale to Pakistan, if not a third-party sale from Turkey to Pakistan).

[1] Burak Age Bekdil. “Diplomatic row jeopardizes $1.5B helicopter deal between Turkey and Pakistan.” Defense News. 13 August 2018. URL: (Last Accessed: 17 August 2018).

[2] Types of Third Party Transfers. US Department of State. URL: (Last Accessed: 17 August 2018).

[3] “TEI is Developing the First Domestic Turboshaft Engine.” TEI Post. Issue 132. 2017. URL: (Last Accessed: 18 August 2018).

[4] Ibid.

[5] Ibid.

[6] “Pakistan Chief of General Staff – T129 ATA Show Flight Tracked at Farnborough Air Show.” Defence Turkey. 16 July 2018. URL: (Last Accessed: 13 July 2018).

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