Jun

22

DDTC Solicits Public Comment on New Application System Sight Unseen


Posted by at 8:03 am on June 22, 2016
Category: DDTC

Cockers for the Nationals by Clif Burns [All Rights Reserved], via Flickr https://flic.kr/p/F2FiEi

So, I’ve decided to give you the contents of this box over here. Of course, the deal is you must keep the contents whatever they are. So, please tell me what you think about what’s in the box and whether you will like whatever it is. Nope, no peeking. You tell me whether you like what’s in the box and then I’ll give it to you. That way if the box contains an 80-foot Burmese python, you can’t say I didn’t give you a chance to object before saddling you with your new pet.

On Monday, the Directorate of Defense Trade Controls did just that when it announced that it is overhauling its export licensing system. No more DSP-5s. No more DSP-83s. Instead, according to the agency

licensing operations will move from the current, largely form-based submissions to an intuitive system which will allow both industry users and DDTC staff to smoothly and securely navigate the submission and review process.

DDTC is giving the public 60-days to comment on this new system. No details on the system have been provided beyond what’s quoted above. So the box that DDTC is proposing to drop on your doorstep may have a cute puppy inside. Or maybe a hungry python. So, speak up now. Tell us what you think!

Of course, if DDTC revises the utterly ridiculous mess surrounding agreement submissions (where, among other things the transmittal letter is longer than the agreement and where the submission process is described in a constantly changing 223-page document that rivals War and Peace for prolixity and Finnegan’s Wake for obscurity) there will be general rejoicing all around. But there isn’t a scintilla of a suggestion in the notice that this monstrosity is going away.

So, which will it be? Puppy or python?

Photo Credit: Cockers for the Nationals by Clif Burns [All Rights Reserved], via Flickr https://flic.kr/p/F2FiEi. Copyright 2016 Clif Burns

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Copyright © 2016 Clif Burns. All Rights Reserved.
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4 Comments:


Whatever the change it will be a nightmare for those with licensing in their ERP systems.

Comment by Hamish on June 23rd, 2016 @ 3:14 am

Was this new proposal socialized with industry through NDIA, AIA, DTAG or SIA?

Comment by t kaine on June 24th, 2016 @ 9:21 am

10 out of 10 times anything with “ITAR” in it is bad news. But you are commended for putting in a picture of a good dog. Dogs are good. He/she looks like a good dog. Certainly a good looking dog. Mixing metaphors, a good dog image helps the medicine go down. Thanks. You help bring sanity to our jobs!

Comment by GWS on June 30th, 2016 @ 11:38 am

    It’s my dog and she is, if I do say so myself, a good dog. She’ll be delighted to hear you called her good looking as well! 🙂

    Comment by Clif Burns on June 30th, 2016 @ 9:33 pm