The Association of American Universities (AAU), which represents 60 leading U.S. research universities, appreciates the opportunity to comment on the Advance Notice of Proposed Rulemaking for “Revision and Clarification of Deemed Export Control Regulatory Requirements” and, specifically, the recommendations made by the Commerce Department’s Office of the Inspector General (OIG) in its report entitled “Deemed Export Controls May Not Stop the Transfer of Sensitive Technologies to Foreign Nationals in the U.S.” (Final Inspection Report No. IPE-16176-March 2004).
Ladies and Gentlemen: We are writing on behalf of the Section of International Law of the American Bar association in response to the Advance Notice of Proposed Rulemaking concerning the Revision and Clarification of Deemed Export Related Regulatory Requirements published the U.S. Department of Commerce, Bureau of Industry and Security (BIS), on March 28, 2005 (70 Fed. Reg. 15607) (the “Notice”). The views expressed herein are presented on behalf of the Section of International Law. They have not been approved by The House of Delegates or the Board of Governors of the American Bar Association and, accordingly, should not be construed as representing the policy of the American Bar Association.
To Whom It May Concern: The American Association for the Advancement of Science (AAAS) appreciates the opportunity to comment on the Advance Notice of Proposed Rulemaking (ANPR) published in the Federal Register on March 28, 2005, (RIN 0694-AD29) on the “Revision and Clarification of Deemed Export Control Regulatory Requirements.” Founded in 1848, AAAS is the world’s largest general science society with some 262 affiliated societies and academies of science, serving 10 million individuals. Since the Cold War, AAAS has upheld the standard that “freedom and national security are best preserved by adherence to the principles of openness that are a fundamental tenet of both American society and of the scientific process.” 1
Dear Mr. Lopes: I write on behalf of the Association of American Medical Colleges (AAMC) in response to the request for comments on the Advance notice of proposed rulemaking: Revision and Clarification of Deemed Export Related Regulatory Requirements, appearing in the Federal Register on March 28,2005 (70 FR 15607) [hereinafter ANPR]. The AAMC is a non-profit organization representing all 125 U.S. accredited allopathic medical schools, some 400 major teaching hospitals, and 94 academic and professional societies representing 109,000 faculty members. The APNR invites comments on the impact on the academic community, industry, and government agencies involved in research of certain recommendations that are contained in the March 2004 Department of Commerce Office of Inspector General Report entitled: “Deemed Export Controls May Not Stop the Transfer of Sensitive Technology to Foreign Nationals in the U.S.”
The following constitutes the National Science Foundation’s Comment to the Advance Notice of Proposed Rulemaking (ANPR), RIN 0694-AD29, “Revision and Clarification of Deemed Export Related Regulatory Requirements”. With an annual budget of approximately $5.5 billion, The National Science Foundation is the funding source for approximately 20 percent of all federally supported basic research conducted by America’s colleges and universities. In many fields such as mathematics, computer science and the social sciences, NSF is the major source of federal backing.
Dear Mr. Lopes: This letter responds to the Advance Notice of Proposed Rulemaking (ANPR) published in the Federal Register on March 28, 2005 (RIN 0694-AD29) asking for comments on the recent recommendations of the Department of Commerce Inspector General (IG) with regard to “deemed exports” in the context of university fundamental research.
DearS ecretaryG utierrez: We appreciateth is opportunityt o providec ommentso n the advancedn oticeo f proposedru lemaking (ANPR) on "Revisions and Clarification of Deemed Export Related Regulatory Requirements."O neo f the key roleso f theN ationalA cademiesc, onsistenwt ith our 1863 CongressionaCl harteri,s to adviset he nationo n importanti ssuesin volving sciencee, ngineering, andm edicines ucha st his one. Them emberso f our threeh onorarya cademie-s the National Academyo f Sciencest,h e NationalA cademyo f Engineeringa ndt he Instituteo f Medicine- and the scientifice xpertsw ho serveo n the studyc ommitteeso f our operatinga rm,t he National ResearchC ouncil,a rew orking at industrial,a cademica, ndg ovemmentailn stitutionst hat are potentiallya ffectedb y the proposedre gulatoryc hanges.W e providet hesec ommentsin light of our backgrounda nde xperiencew ith the U.S. scientific,e ngineeringa, ndm edicale nterprise
Dear Mr. Lopes: I appreciate this opportunity to submit these comments on behalf of the National Association of State Universities and Land-Grant Colleges(NASULGC) in response to the Advance Notice of Proposed Rulemaking (APRM), published on March 28, 2005, in the Federal Register seeking public input on a number of recommendations from the Office of Inspector General (OIG) with respect to deemed exports. More specifically, I write in reference to RIN 0694-AD29 and the recommendations to the Bureau of Industry and Security (BIS) contained in Deemed Exports May Not Stop the Transfer of Sensitive Technology to Foreign Nationals in the U.S. (Final Report Number IPE-16176-March). NASULGC is an organization which represents approximately 215 public universities, many of which are this nation’s largest research universities.
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