IEEE-USA
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25 February 2002

The Honorable John H. Marburger, III
Assistant to the President for Science and Technology
Office of Science and Technology Policy Eisenhower
Executive Office Building
17th and Pennsylvania Avenue, N.W.
Washington, DC 20502-0001

Dear Dr. Marburger:

On behalf of the Institute of Electrical and Electronics Engineers-United States of America (IEEE-USA), I am writing to urge your prompt attention to an issue of considerable importance, the International Traffic in Arms Regulation (ITAR), 22 C.F. R. Part 120, et. seq. As you are aware, the FY 2002 VA/HUD appropriations conference report states that, "The conferees agree that the Office of Science and Technology Policy should make the clarification of ITAR a high priority for resolution." IEEE-USA heartily endorses this request and offers the following specific recommendations:

  • Clarify what can and cannot be published under ITAR;
  • Reaffirm National Security Decision Directive-189 and consider broadening it to include unclassified basic research (6.1) and exploratory development (6.2) and include it in ITAR;
  • Support the enactment of legislation that, while protecting sensitive matters, makes it easier and faster to obtain licenses to export technologies and systems not falling in the sensitive category; and
  • Conduct a workshop among all affected parties, i.e., federal agencies, technical industries, and academia. IEEE-USA is willing to help plan and implement the workshop.

I would like to request a meeting, at your convenience, for our representatives to further discuss this issue and how we can be of assistance.

The goal of ITAR is to control the export and import of defense articles and services vital to our national security and other national interests. However, as currently structured, implementation of ITAR is too complex and places unnecessary restrictions on the flow of commercially relevant technology, systems and information in areas that are already well known to our adversaries. The varied interpretations and inconsistent enforcement of ITAR by the federal agencies involved is impeding U.S. competitiveness in key technology areas. Because of ITAR's vague definition of the information to be controlled, the free flow of scholarly information is also interrupted. IEEE has seen instances where speakers have withdrawn from technical conferences and research was withheld from publication in IEEE technical proceedings because of ITAR uncertainties. I sincerely appreciate your help in addressing this important matter. (Please find enclosed a letter concerning this matter that IEEE-USA sent to President George Bush on August 28 2001.)

IEEE-USA is an organizational unit of the Institute of Electrical and Electronics Engineers, Inc, created in 1973 to promote the careers and public policy interests of the more than 230,000 electrical, electronics, computer and software engineers who are U.S. members of the IEEE. If you have questions or need additional information, please contact Bill Williams at (202) 785-0017 ext. 8331, or bill.williams@ieee.org.

Sincerely,

LeEarl A. Bryant, P.E.
IEEE-USA President


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Last Update:  25 Feb. 2002
Staff Contact: Bill Williams, bill.williams@ieee.org

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