The Council on Governmental Relations (COGR) and the Association of American Universities (AAU) respond to the May 24, 2013 Federal Register Notice (78 FR 31431) on the changes proposed by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) with regard to the transfer of spacecraft systems and related items from the United States Munitions List (USML) to the Commerce Control List (CCL) (RIN 0694-AF87).