September 9, 2013
Mr. Brian Baker
Director, Electronics and Materials Division
Office of National Security and Technology Transfer controls
Regulatory Policy Division
Bureau of Industry and Security
U.S. Department of Commerce
14th Street and Pennsylvania Avenue, NW
Room 2099B
Washington, D.C. 20230
Re: RIN 0694—AF64
Dear Mr. Baker:
We write on behalf of the Council on Governmental Relations (COGR) and the Association of American Universities (AAU) in response to the proposed rule (78FR45026) to transfer military electronic equipment from the United States Munitions List (USML) to the Commerce Control List (CCL). COGR is an association of 189 U.S. research universities and their affiliated academic medical centers and research institutes that concerns itself with the impact of federal regulations, policies, and practices on the performance of research and other sponsored activities conducted at its member institutions. AAU is an association of 60 U.S. and two Canadian preeminent research universities organized to develop and implement effective national and institutional policies supporting research and scholarship, graduate and undergraduate education, and public service in research universities.
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