DoD Official Concerned About Unintended Consequences of USML and CCL Rewrites
The Department of Defense is concerned about the unintended consequences of licenses for some items and some aspects of Export Control Reform in general, said Rizwan Ramakdawala of the Defense Technology Security Administration (DTSA) during a panel on reshaping the control lists at the Bureau of Industry and Security’s Update 2012 Conference on Export Controls and Policy July 17-19 in Washington.
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Ramakdawala said DTSA, which makes recommendations on individual licenses and is involved in the Export Control Reform rewrite of export control lists, is attempting to strike a careful balance between facilitating allies’ military capability through exports while maintaining U.S. military superiority through controls. Referring specifically to controls on aircraft, he said this challenge is heightened by concerted efforts by many countries to acquire aviation and gas turbine engine technology through exports. The line is also blurred by several models of aircraft that serve both military and civilian applications, such as the Boeing 737 and the P-8, the H-92 and the S-92, or the F101 and the CFM56 engines.
Whereas the current broad U.S. Munitions List allowed DTSA to be more comprehensive when recommending denial, the Export Control Reform effort’s move towards positive lists has forced DTSA “to move at the speed of industry.” DTSA is optimistic, said Ramakdawala, but cautiously so.
BIS Says Comments Welcome; Positive List Will Require Continuing Action After ECR
During the panel discussion, Gene Christiansen offered BIS’ general perspective on the rewrite of the USML and the Commerce Control List. Christiansen in particular singled out for praise comments received from industry, through which the lists have gotten better as BIS has progressed in its rewrite. Christiansen noted that because the new lists will be positive, they will have to be constantly reviewed and updated, and industry’s help will continue to be requested in this process.