I share your concerns about the longer arc of these export controls, but it's important to note that this is not naming these categories in a broad brush. It's a request for public comment to help "determine whether there are specific emerging technologies that are essential to the national security of the United States".

It also specifically names (a) impact of controls on reducing our ability to advance and (b) the potential (in)effectiveness of controls as things needing discussion. A lot of folks here work at companies with uniquely informed perspectives on those two things! This is the time to push your company towards publicly responding to this request for comment, so that others can see and be encouraged to share their view.

I agree. You can complain and ascribe intent, or you can help. The people writing these controls are specifically admitting their need for assistance.

My interaction with EAR/itar has been annoying, but has not stopped me from working with foreign researchers, publishing papers, or openly discussing most of my work.

Yeah and "national security" has always been a form of rhetorical special pleading around the constitution and any check on power.

I personally have this heuristic for if it is potentially valid - if they can't even explain why it is important for National Security it is utter bullshit as a power grab.

This is a request for public comment. Logistics is a key function in the military and a decisive capability in waging war. Position, Navigation and Timing technology improvements can be a decisive factor on the battlefield. Much of this technology is of course in the public domain. However leading research & developments are not. So I’d expect to see responses that seek to define leading areas of research that are sensitive.

>This is a request for public comment.

The page says comments closed 12/19/2018

This may not be objective coming from a non-US person but it seems strange to me that the US likes to have that cloak of respecting others, standing for freedom, equality etc. and using that around the world as a cover for a lot of meddling they're doing, while at the same time openly admiring that other people are simply lesser and if we ban tech that could save lives elsewhere, so be it.

This is one of the reasons why am strongly for a multipolar world order, maybe the other player would be China/Russia/India, at least the US would actually have to prove that they do in fact stand for the values that they use to buy themselves so much leeway around the world.

Export control has huge downsides and I agree with the general sentiment that the US overdoes it. However, logistics and navigation have obvious military applications. A state-of-the-art GPS receiver can slot straight into a missile.

So? A state-of-the-art CPU can also slot straight into a missile. As can nuts and bolts, batteries, radios, and all sorts of other equipment.

Speaking of state of the art CPUs, I own a couple years old "KiwiSDR" web-ui receiver which devotes some CPU cycles to implementing a GPS rx and it uses the GPS lock to discipline the internal oscillators such that the radio is driftless and perfect frequency accuracy. It works pretty well. My receiver is somewhat more frequency stable than some local AM broadcasters, which is weird to see in the waterfall display; many local broadcasters do GPS discipline, of course.

Pretty sure the code is at

https://github.com/jks-prv/Beagle_SDR_GPS

Note that the hardware Skyworks SE4150L chip is an RF front-end, all the math is done in software, the chip merely attaches to the GPS antenna and squirts out a very raw digital bit-stream of data, its hardly a full GPS squirting out NMEA RS232 serial data. I am aware of SDR hardware that does the RF work in software, which is a slight step beyond the KiwiSDR.

Technology is not distributed smoothly and software defined GPS is cheap enough that everyone except cheap consumer gear can implement it. Someday, presumably, computing power will be cheap enough that your microwave oven and clothes washer will not bother with expensive hardware to have a semi-accurate timer, they'll just use cheap SDR code in a FPGA to listen to GPS to time your microwave popcorn and clothes spin cycle. That's the fundamental problem with regulations like this, they don't slow down "state actors" they just stand in the way of (taxable, profitable) commercial exploitation.

Post 2000, post 2010 at worst, no serious missile program will ever lack an unlimited GPS, but post regulation, the technology will be crippled from entering consumer goods.

Now what is interesting to speculate is it would be destabilizing if we know that they know how to crack the military P(Y) code or the newer M code for higher resolution positioning. I'm not sure that would help with missiles but if our secret squirrels are freaking out about the generic topic of software GPS, that would imply some state level actor (or lower?) has a crack or exploit for the math behind P(Y) code or M code streams, which has interesting implications for other crypto systems.

I think if they have the rocket scientests to design and manufacture missiles in the first place then export control of GPS chips is security theater - they have advanced mathematics and supercomputers by missle tech standards with just a desktop computer.

Food has military applications as well - because soldiers need to eat.

> A state-of-the-art GPS receiver can slot straight into a missile.

I thought civilian grade GPS didn’t work at high speed or high altitude (meaning missile rather than aircraft) for exactly that reason?

What about the plethora of cheap chinese ones?

Does the USA actually manufacture any of the things on the list any more?

Chinese hardware designs are generally third rate. Everyone just prefers to focus their ire on butterfly keyboards.

> Chinese hardware designs are generally third rate.

Depends on the price bracket, but this is generally an outdated view.

It's worth noting that the EU, Russia and China all either have developed, or are developing, state of the art navigation systems of their own and thus there's no dependence on GPS as there once was and thus the utility of any export controls on it is limited at best.

On a similar list (aka "not to be discussed/shared with a non-US citizen) is thermal/night vision technology. And yet, a veritable cornucopia if videos on YouTube, and images in marketing materials online, clearly showing the capabilities and features.

Overly broad? Certainly. Just another tool in an enforcement agency's toolbox? Likely.

I work with thermal imaging cameras. The rules are very specific on what can be exported, but it's not a blanket ban. I've asked FLIR for CAD documents before and they just sent them. The actual technology inside the systems is very hush hush though, very difficult to find anything publicly.

Basically anything below 9fps is fine to send anywhere except countries on the USA naughty list.

Anything above that can be exported with minimal effort to countries on the USA "nice" list (called STA). If you're in a non "terrorist" country, but not in the friendly group you can apply for an export license which isn't particularly onerous.

There are specific exceptions for high resolution cameras, high speed cameras, cooled options and so on. That's not to say you can't export them, but you need additional clearance.