LOWELL DEFENSE TRADE LLC Corporate Trade Compliance http://ldt.us.com William J. Lowell Managing Director February 7, 2011 Via E-mail
[email protected] Charles B. Shotwell, Director Office of Defense Trade Controls Policy Directorate of Defense Trade Controls SA-1, 12th Floor Bureau of Political Military Affairs U.S. Department of State Washington, DC 20522–0112. Re: “Category VII Revision” and ‘‘USML—Positive List.’’ Dear Mr. Shotwell: Please find below and in several listed attachments, hereto, comments on two notices of proposed rulemaking published in the Federal Register on December 10, 2010: Public Notice 7256 Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Category VII; and Public Notice 7257 Revisions to the United States Munitions List. Please also consider these comments in the context of my letter dated September 10, 2010 raising concerns with respect to a separate Federal Register notice that would reverse longstanding U.S. Government policy barring access by proscribed nationals (e.g., China, Iran, North Korea) to U.S. weapons technology in the possession of foreign corporations overseas. The major focus of the Administration’s export control reform initiative is military export controls and commercial arms sales. Its proposal is to: (1) Reduce the U.S. Munitions List by about 75 percent1; (2) Integrate what remains of the Munitions List with the Commerce Control List into a single new list; and (3) Seek agreement from other countries to make conforming changes to the international Munitions List (on which they base their national controls). The context is that the U.S.