Sep

25

DDTC Chief: “D-Trade is De-Lovely”

Posted by at 5:02 pm on September 25, 2006
Category: DDTC

Robert MaggiIn response to industry complaints about increased processing times for license applications at DDTC, Robert Maggi, the Managing Director of DDTC, said last week to an industry group that D-Trade would soon make everything better:

Robert Maggi, DDTC chief, agreed with many of the complaints, and promised that improvement is at hand. A computer-based system called D-Trade should speed up and increase consistency in the licensing process, Maggi told an audience of defense company representatives and congressional staffers Sept. 22.

Although the D-Trade system has been in operation for more than two years, it is only gradually making a dent in DDTC’s workload, Maggi said.

By Christmas, D-Trade will have processed about 7,000 arms export license applications. That’s out of about 70,000 the directorate receives each year, he said.

The system has developed “way more slowly” than expected, Maggi conceded, but “I’m pretty optimistic” it will improve the licensing process.

Mr. Maggi admits that almost three years in D-Trade, only 10 percent of all license applications are filed through the system. This should be considered an admission that D-Trade, by any conceivable measure, is an abject failure. Rather than continuing to “happy-talk” the system and hope that things will improve, DDTC needs to try to figure out why the system doesn’t work and why 90% of applicants, when given the choice, file their licenses on the “dead tree” forms.

I know of at least one reason many applicants don’t use D-Trade: the digital signature requirement is burdensome and unwieldy. When the procedure for obtaining digital certificates is explained to potential applicants, I know a number who have opted instead to file paper forms with old-fashioned ink signatures. In case you don’t believe that the process of getting a certificate is cumbersome, take a look at this 15-page instruction sheet provided by one of DDTC’s approved vendors of digital certificates.

What makes this all the more baffling is that there is no need for a digital certificate to sign D-Trade applications. The digital certificate verifies that the signature on the electronic document is authentic, but DDTC has never required any proof of authenticity for signatures on paper licenses. If D-Trade applications could be signed by submitting a certification letter in pdf format, I suspect that more applicants would use the system.

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Copyright © 2006 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)

One Comment:

Just as important as your criticism of the DDTC’s D-Trade “happy talk” is that fact that the D-Trade problems will get significantly worse and soon. D-Trade will be “mandatory” on October 12. DDTC will shut down the manageable ELLIE and ROBB licensing systems. While this does leave two routes, D-Trade and paper-based forms, the paper-based is not an option because it will become even slower process. At a D-Trade training meeting, the Licensing Officer threatened that the paper-based forms would wait for administrative staff to entered them by hand.

An additional burden will be placed on D-Trade when Agreements are added to the system. “Turk” insisted that Agreements capabilities would be added to D-Trade “by the first of the year.” While this seems unreasonable, considering that they will still be dealing with the problems created by the October 12th mandate, it is possible that the “heedlessly forge ahead” mentality will still hold sway at DDTC.

Maybe, just maybe, these things will make it bad enough that DDTC will begin asking themselves questions, questions that industry has been answering with shouts.

Comment by Paul Lauper Ellison, Esq. on October 2nd, 2006 @ 4:33 pm