Overview
Title
30-Day Notice of Proposed Information Collection: Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Related Classified Technical Data
Agencies
ELI5 AI
The State Department is asking people to share their thoughts about a special form needed to move secret military stuff between countries. People have until April 9, 2025, to say what they think, which will help decide if the form is necessary or too much work.
Summary AI
The Department of State is seeking public comments on a proposed information collection regarding the application or license required for the export or import of classified defense articles and technical data. Individuals and organizations have until April 9, 2025, to submit their comments, which will help evaluate the necessity and burden of the collection process. This form, known as DSP-85, is crucial for obtaining authorization for the permanent or temporary export or import of such classified items. Comments submitted will become part of the public record.
Abstract
The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.
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Sources
AnalysisAI
The document in question is a public notice from the Department of State, published in the Federal Register, inviting comments on a proposed information collection related to the export and import of classified defense articles and technical data. The process involves filling out Form DSP-85, which is required to legally export or import such sensitive items temporarily or permanently. The notice is part of a routine cycle under the Paperwork Reduction Act, which allows public input into how governmental data collection is conducted.
Summary of the Document
This public notice announces a 30-day period during which individuals and organizations can provide feedback on the necessity and efficiency of collecting information via Form DSP-85. The form is required for transactions involving classified defense items identified under the U.S. Munitions List. The document outlines the collection process, applicable regulations, and the number of anticipated respondents. It notes that the collected data is crucial for maintaining compliance with International Traffic in Arms Regulations (ITAR) and the Arms Export Control Act.
Significant Issues and Concerns
One major concern with the notice is the complexity of its language and assumptions regarding the audience's familiarity with terms and regulations like ITAR and USML. This could deter public engagement from individuals not well-versed in these subjects. Additionally, the lack of detail regarding the cost and resource implications of this data collection process might hinder a comprehensive evaluation of its efficiency.
Another significant issue is the absence of information on how public comments will be utilized following the feedback period. This omission could lead to uncertainty regarding the substantive impact of stakeholder input. Moreover, there is no discussion about the use of modern, automated techniques to reduce the burden on respondents, which might make the process less efficient than it potentially could be.
Impact on the Public
For the general public, the immediate impact of this notice is minimal, unless they are directly involved in the export or import of classified defense items. However, the broader implication revolves around governmental transparency and the opportunity for public participation in regulatory processes. By soliciting feedback, the Department of State opens a dialogue that may influence how sensitive information is managed and controlled.
Impact on Specific Stakeholders
Businesses and organizations directly engaged in defense trading might find the notice highly relevant. The Form DSP-85 is integral to legally conducting their operations when dealing with classified materials. Therefore, any inefficiencies or burdens in this information collection process might affect their operations. By participating in the comment period, these stakeholders have the opportunity to advocate for changes that could streamline processes and potentially reduce costs.
Nonprofit organizations involved in arms control advocacy might view the notice as an opportunity to push for stricter controls or highlight potential loopholes in the current system. Similarly, individuals working in legal and compliance roles within defense industries are likely to pay close attention to any updates or changes in the regulatory requirements that might arise from the public comments.
In summary, this public notice serves as an important mechanism for transparency and stakeholder engagement in regulatory affairs at the intersection of national security and international trade. However, its efficacy could be improved by simplifying language, providing clear explanations of the collection's necessity, detailing its impacts, and clarifying the post-comment process.
Issues
• The document does not include detailed information on the costs associated with the information collection process, which could help evaluate potential wasteful spending.
• The language used in the notice is somewhat complex and legalistic, which may be difficult for the general public to fully understand without specialized knowledge of arms export control regulations.
• The purpose of the information collection is not thoroughly explained in the text itself; it assumes a certain level of prior knowledge about the ITAR and USML which might not be common among all respondents.
• There's no mention of how public input will be integrated or addressed following the comment period, which may leave respondents unclear on the impact of their participation.
• The document does not specify whether the automated collection techniques for minimizing the reporting burden are currently in use or planned for future implementation.