Comment on DOD-2006-OS-0039

DoD-2006-OS-0039 Mark, Good day to you. I am writing in regards to the proposed changes that the USGOVT has proposed and items 2-8 give me a little pause because the government really hasnt thought this one through too terribly much. Item 2-Has adequate export controls to preclude improper transfers. That should be spelled out as to what "proper controls" are. Ambiguity will send this stuff out of the country so fast it would be as fast as the fax and word processor can send and create it. Item 3, Demonstrate a history of compliance. If its your first time or even your tenth...What defines "compliance" Item 4. "Does not have have a history of acts involving fraud, ......" Come on, again a history. What defines history. If you were a criminal last week are you less of one this week. How about just stating anyone who is barred from shipping this stuff must go thru full state department/DoD review...at their cost to determine end use? Item 5. History again. Are you now or have you ever been a terrorist or corrupt, etc. etc. What do you think they are going to say, yes? Of course not. Item 6 while good in intent restricts the trade of legitimate operations. It should be a lot more wordy here and those people who are not in my opinion of good standing shouldnt be allowed to ship anything out of the country. E.g. If you are in bankruptcy then no, if your net worth would be substantially increased by the sale of this material out of the country and you are of questionable repute then you should go thru the state and DoD review. Item 7. History again. Compliance... Who in heck is going to determine that? Frequency? No way man. They need to do it each and every time someone wants to sell something out of the country. I have to say that I have gotten my hands on some stuff from third parties that if used properly could really screw up our troops in the past and that isnt going to happen on my shift. Medical testing and general equipment is one of my favorites that could be used. I suggest that a blanket process be adopted for people that want to sell this stuffoutside of the country. That should be reviewed by the S. Dept and the DoD prior to any sales happening. Undue delay. Both entities should review and approve/deny the sale within 60 days after application for a EUC and a risk analysis. Good example. I was in Curacao a few months back and saw some really keen computers on sale in the local computer store. I was looking around and found they had DoD asset stickers on them. Okay so they pull the hard drives on them when they leave of course, but its the processing power. You link up a bunch of those together and you have a super computer. Think not. Punch up SETI (Search for Extraterrestrial Intelligence). They have a program that if you leave your machine on, will access your system use that computing power to analyze signals. There are others that are using them to find information out on huge calculation programs. Those same huge calculation programs are used to simulate nuke explosions. You are I assume getting my drift here. Its not a good idea to let ANY computer out of this country because of all the bells and whistles we put on them. Munitions? Please-there are tons of the stuff moving thru Africa at any given time from Ethiopia. Its arms dealers paradise. We are the only ones that enforce this stuff. The French shipped stuff with just numbers on it to Iran and Iraq before Enduring Freedom and then we were fighting that equipment in the dirt. Framatome was one of the big centrifuge and high tech metal milling machine offenders. Third party? Why bother? They are all shipping it.