We previously reported a change announced by the Directorate of Defense Trade Controls (“DDTC”) adding a sixth exception to National Security Presidential Directive–56 which mandated a 60-day processing time for export license applications. Sharp-eyed reader Robin noted that there was more in that notice than meets the eye, or at least met my eye.

Although the notice announcing the change characterized the change as simply adding a sixth exception, in fact the notice also changed, without any mention, the fourth exception to the processing guidelines. Previously, the fourth exception read as follows:

(4) Department of Defense has notified the Directorate of Defense Trade Controls that an overriding national security exception exists.

But now take a look at exemption 4 in the DDTC notice announcing the sixth exception:

(4) The Department of Defense has not yet completed its review.

Sneaky. I suppose DDTC didn’t really want to highlight that the Pentagon feels that it’s above such silly civilian nonsense as processing deadlines. Or that the last time DDTC asked the Pentagon about where it was on an application, the Pentagon told DDTC to “take a hike” although it likely did so using somewhat more “colorful” terms.

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