First, it repeatedly emphasizes “dual use” controls, without distinquishing between controls for national security purposes and those for CBW or antiterrorism purposes, which are often far broader, and utterly fails to mention embargo controls. The latter is not insignificant because unlike the Cuban embargo, the Iranian Transactions Regulation and their complementary provisions of the EAR prohibit all export of technology subject to the EAR, including EAR99 technology; but, the IRT does not prohibit travel to and from Iran and the US. Therefore, it is possible for an Iranian engineer or scientist to travel to the US (unless he or she is on the SDNL) if they can get a visa and there are Iranian students at many universities.

It seems to have been concocted with only the input of industry, academicians, and government, without the input of labor or other organizations that represent the American scientists and engineers that must compete with foreign nationals for jobs and/or admission and assistance to graduate schools in engineering, math and the sciences. It should be remembered that the Y2K scare produced a surge of hiring of foreign software engineers, supposedly due to a shortage of engineers, when in fact, as plaintiffs in a number of individual and class action suits under the Age Discrimination Act proved (often through internal documents and communications) many of the employers passed over qualified American engineers, many of whom had originally worked with the legacy software systems needing Y2K patches, in favor of inexperienced but cheap foreign engineers. Many members of the DEAC have a vested interest in reordering the system in their favor to the detriment of qualified Americans.