Comment on FR Doc # 2011-16399

I am writing in my capacity as Purdue University's Export Control Officer to endorse and support the written comments provided in a letter dated August 16, 2011, by the Association of American Universities (AAU) and Council on Governmental Relations (COGR) concerning the Notice of Proposed Rulemaking on Safeguarding Unclassified DoD Information (DFARS Case 2011 D039). Purdue University is Indiana's Land Grant University and is a major performer of research funded by the U.S. Department of Defense (DoD). Purdue acknowledges and appreciates DoD's response to earlier comments submitted by AAU and COGR in it's proposed revision of DFARS 252.204.7000 to include an exemption of results from fundamental research from disclosure restrictions. This inclusion significantly reduces the uncertainty noted by AAU and COGR in an earlier formulation of the revised clause. Purdue also shares the concerns expressed by AAU and COGR regarding the proposed scope of information subject to the definition of "DoD information" and with the requirements for Enhanced Safeguarding of certain categories of DoD information. In each case, AAU and COGR have suggested alternate language which would greatly reduce the negative impact of the proposed revised regulations on performing institutions of higher education. Purdue endorses these suggested alternatives for reducing negative impact. Thank you for the opportunity to submit comments on these proposed revisions.