7/20/2018 DOS-2017-0046-2430.html As of: July 10, 2018 Received: July 06, 2018 Status: Posted PUBLIC SUBMISSION Posted: July 09, 2018 Tracking No. 1k2-944e-n1fc Comments Due: July 09, 2018 Submission Type: Web Docket: DOS-2017-0046 Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Categories I, II, and III Comment On: DOS-2017-0046-0001 International Traffic in Arms Regulations: U.S. Munitions List Categories I, II, and III Document: DOS-2017-0046-2430 Comment on DOS-2017-0046-0001 Submitter Information Name: Aaron Karp Address: BAL 7006 Old Dominion University Norfolk, VA, 23529 Email:
[email protected] Phone: 17576835700 General Comment The proposed ITAR revision for firearms and ammunition promises little, and risks much. As an analyst of the global arms trade and weapons proliferation for thirty years, I recognize the transformative power of regulatory reform. But this is something else. The proposed revisions promise short-term benefits, which seem unlikely to amount to much in an already competitive global market. That makes this deregulation for the sake of deregulation itself. Meanwhile, the change unleashes three forces certain to accelerate long turn American industrial decline and loss of influence over global consequences. First, they show that the United States no longer will set global normative standards for all form of arms transfers and non-proliferation. Previously the United States Government has shown it will not further tighten restrictions. As the first outright relaxation of oversight standards in arms exports in over fifty years, the change marks a switch in policy dating from the Kennedy Administration.