* Increasing controls on parts that currently are available without restriction, and creating ambiguity among proposed ECCN 3A611 and existing ECCNs 3A001 and 3A982, would create an unlevel playing field for U.S. manufacturers and jeopardize thousands of high paying jobs.
* This commenter urged removal of discrete microwave transistors and MMICs from proposed 3A611 altogether, because proposed control thresholds overlap with existing controls on the CCL. Alternatively, if they are to remain in 3A611, the commenter stated that BIS should tailor the provisions narrowly so that they apply only to a limited range of products that truly are specially designed for military use, with no potential commercial applications in the designated power, frequency, and efficiency ranges. There should be a logical progression from ECCNs 3A001 to 3A983 to 3A611. Additionally, the units of measure should be harmonized for all three ECCNs.
Response: BIS has substantially revamped the criteria for proposed ECCNs 3A611.c and .d in this proposed rule compared to the
In this proposed rule, paragraph .c would control
The MMIC power amplifiers subject to paragraph .c would be described in 13 subparagraphs. Each subparagraph would apply to a specified operating frequency range, starting with subparagraph .c.1, which would apply to
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