Plus, and perhaps just as importantly, the licensing staff at DTCL are now significantly more helpful and responsive. We no longer live in mortal fear of RWAs being issued because of minor oversights or ambiguities in our applications. We now get actual phone calls from licensing officers with questions. All sarcasm aside, this is an outstanding improvement.

At a certain point, though, DTCL’s reforms will reach the point of diminishing returns, largely because of the requirement to staff so many applications. It doesn’t matter how efficient DTCL becomes; an application that has to be reviewed by DTSA, DOC, other State bureaus, etc. simply cannot be processed any faster.

So how else to streamline? Cutting back on licensable transactions would help. For starters, updating the $500 spare parts exception at 123.16(b)(2) to reflect 2009 dollars strikes me as a pretty common-sense step, especially given the increased responsibility that 21st-century contractors have for exporting aftermarket hardware outside the defense transportation system.

Even better, though, would be an ITAR analog to the EAR’s GOV exception, at least with respect to US military customers and perhaps even close allies. (And to be fair, I believe something along these lines this is already under consideration at DDTC.) It’s odd to me that contractors have played an unprecedented role in providing direct logistical support to allied warfighters for six or seven years now, and we still generally have to have a DSP-5 for every shipment of ITAR-controlled widgets exported in support of US and allied military operations overseas.

To be sure, there are ITAR exemptions for shipments for or on behalf of the USG at 126.4(a), and for USG end-use at 126.4(c), but these have requirements that often make them generally inapplicable for day-to-day exports of significant volume. And while the OIF/OEF process is a very helpful option, it’s still unduly cumbersome, especially now that the military customer has to furnish a written statement explaining the urgency of the export for which authorization is being sought.

Of course, perhaps the biggest efficiencies could be achieved by a wholesale reform of the USML itself to remove controls from non-sensitive technologies and widgets. But even a whiny industry back-seat driver like me understands what a big, messy, lengthy ordeal that would be. Indexing 123.16(b)(2) to inflation at a minimum and creating an exception for exports to the U.S. military and close allies would be relatively simple changes.