The memorandum, submitted jointly by four major associations representing U.S. research universities and medical schools, addresses the Bureau of Industry and Security's Advance Notice of Proposed Rulemaking (ANPRM) regarding controls on certain emerging technologies. The associations express concern about the short 30-day comment period, arguing that it is insufficient for universities and other stakeholders to provide comprehensive, informed feedback on a complex and technically challenging subject. Given the significant potential impacts of new regulations on higher education institutions—especially amidst year-end operational constraints—the associations advocate strongly for extending the comment period to at least 60, and preferably 90, days. This extension, they argue, would support the intent of the Export Controls Reform Act by enabling thorough participation from knowledgeable campus experts, ensuring that regulatory decisions are informed by robust, expert-driven input.
This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on November 19, 2018.
