16 March 2001
Source: http://usinfo.state.gov/cgi-bin/washfile/display.pl?p=/products/washfile/latest&f=01031501.clt&t=/products/washfile/newsitem.shtml


US Department of State
International Information Programs

Washington File
_________________________________

15 March 2001

GAO Testimony on Relaxation of Computer Export Controls

(Clinton's January decision criticized) (1490)

A congressional investigative agency has criticized President
Clinton's January decision to relax controls on computer exports.

The criticism appears in March 15 testimony prepared by Susan Westin
of Congress' General Accounting Office (GAO) for a Senate Governmental
Affairs Committee hearing. Senator Fred Thompson, the committee
chairman, has become a leading opponent of export control relaxation.

Clinton's decision, announced January 10, in part would raise the
threshold for permissible computer sales to a group of countries
including Russia, China, India, Pakistan and Israel.

If not blocked by Congress the decision would raise the threshold for
the sixth time since 1995. It would allow exports of computers capable
of 85,000 million theoretical operations per second (MTOPs), up from
the existing 28,000 MTOPs threshold.

Westin testified that Clinton's decision failed to meet two of three
criteria for such action as required by a 1998 law: It neither
addressed all the military uses that could be applied at the new
threshold nor assessed the national security consequences of such
uses.

She said Clinton did meet the third criterion demonstrating that such
high-performance computer power is becoming available worldwide;
Clinton's report recognized that people can assemble such power by
connecting lower-performance computers together.

"The president's January 2001 changes in the export control thresholds
for high performance computer exports are not adequately justified,"
Westin said.

Following is an excerpt of the text as submitted for the committee's
record:

(begin excerpt)

United States General Accounting Office
Testimony
Before the Committee on Governmental Affairs,
U.S. Senate
March 15, 2001

EXPORT CONTROLS:

Inadequate Justification for Relaxation of Computer Controls
Demonstrates Need for Comprehensive Study

Statement of Susan S. Westin, Managing Director,
International Affairs and Trade

Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss export control issues for
high performance computers. My testimony is based on work we have
conducted over the past few years, particularly our December 2000
report,(1) and work we are currently completing for the Congress.

As you know, export controls continue to be a contentious part of our
national security debate. Over the past several years, there has been
continuing congressional concern over the rationale for revising these
controls and their effect on our national security. U.S. policy with
respect to the export of sensitive technology, including computers,
seeks to balance the national interest in promoting economic growth
and trade against the essential national security requirement to
prevent the proliferation of technologies related to weapons of mass
destruction, missiles, and advanced conventional weapons.

The United States has long controlled the export of high-performance
computers(2) to sensitive destinations such as Russia and China. These
computers have both civilian and military (dual-use) applications, and
the recent technological advancements in computing power have been
rapid. The Department of Commerce has primary responsibility for
licensing these dual-use items and other agencies -- State, Defense,
and sometimes Energy -- help to weigh promotion of commercial
interests in exporting items against protection of national security
interests. The regulations for high-performance computer control
thresholds are currently based on a computer's composite theoretical
performance as measured in millions of theoretical operations per
second (MTOPS).

We recently reported that the growing ability of other countries to
cluster lower performance computers has made the current computer
export-control system ineffective in limiting countries of concern
from obtaining high performance computing capabilities for military
applications.(3) In that report, we also reported that MTOPS is an
outdated and invalid means for determining whether individual
high-performance computers should be licensed for export. We
recommended that executive branch agencies convene a panel of experts
to (1) conduct a comprehensive assessment of available options to
address weaknesses of computer export controls and (2) make a
determination on what U.S. countermeasures, if any, are necessary to
respond to any computing-related enhancements of military or
proliferation capabilities in sensitive countries. The Departments of
Commerce and Defense disagreed with the need to implement these
recommendations because they said they were already engaged in
interagency reviews of similar issues. However, when asked for
documentation on how the agencies were pursuing the points covered in
our recommendation, the agencies provided none. As a result, we
believe our recommendations are still valid and we raised this matter
to the attention of Congress in the December report.

On January 10, 2001, President Clinton announced a significant
relaxation in export-control licensing and notification thresholds for
high-performance computers and a proposal to eliminate almost all
controls on exports of computer hardware. Today, I will discuss our
observations about these changes, specifically, (1) our evaluation of
the President's justification for changing the computer control
thresholds, (2) our evaluation of the support for the President's
policy proposal to shift the emphasis of controls from hardware to
software controls, and (3) implications of these changes.

To assess the President's justification for changing the computer
control thresholds and to evaluate the support for the President's
policy proposal, we reviewed the President's January 2001 report to
the Congress and announcement of computer control changes. We also
reviewed Defense documents showing the results of calculations in
support of the new control threshold. We interviewed officials from
the Departments of Defense, Commerce, and State; and the national
laboratories, Lawrence Livermore and Oak Ridge. We interviewed
officials from major computer manufacturers, IBM, and SUN
Microsystems, as well as the computer scientist responsible for the
Top 500 List of the most advanced high-performance computers in the
world. We also reviewed a Defense Department technical report and
interviewed its authors. In addition, we interviewed officials of the
Commerce Department's Information Systems Technology Advisory
Committee. To identify implications of the computer control threshold
and policy changes, we reviewed the President's report to the Congress
and White House fact sheet on computer control and policy changes. We
also reviewed interagency inspector general reports on export
controls. In addition, we interviewed officials of the Departments of
Commerce, Defense, and State. We also obtained and analyzed Commerce
Department statistics on the disposition of notifications and license
applications.

SUMMARY

The President's January 2001 changes in the export-control thresholds
for high-performance computer exports are not adequately justified.
While the President's report recognizes that high-performance
computing capabilities will become increasingly available to other
countries through computer clustering, the report fails to address all
militarily significant uses for computers at the new thresholds and
assess the national security impact of such uses, as required by law.
The inadequacies of the President's report are further compounded by
continued use of a flawed measure for assessing computer performance.

The support for the President's policy proposal for relaxed U.S.
computer controls also is not adequate. Although the new policy was
based on a conclusion that computer hardware exports can no longer be
controlled, the executive branch did not adequately assess alternative
control options. Our prior report identified several other options.(4)
In addition, the new policy would focus more attention on using new
software controls to protect U.S. national security interests, even
though such controls have yet to be identified and developed.

We identified several implications of the changes to the control
thresholds and the proposed change in U.S. computer export-control
policy related to increased risks for U.S. national security.

-- The inadequacies of the President's justifications again
demonstrate the need for a comprehensive study of the issues involved.

-- The new rules effectively eliminate routine prior U.S. government
review of computer exports below the licensing threshold to sensitive
countries. In the past, we found that establishing a notification
threshold lower than the licensing threshold was useful in that it
allowed the U.S. government to deny or defer some exports, or make
other exports conditional upon additional safeguards.

-- Raising licensing control thresholds in January 2001 increases the
risk that more powerful computers might be exported without a license
to sensitive customers nearly a year before Defense projects that
these customers could attain the same computing power by clustering
less powerful computers.

-- Defense and Commerce officials said that the U.S. government will
have to rely more heavily on computer vendors to "know your customers"
and assess their intentions to use computers for proliferation
purposes. Past evidence has shown this reliance may be misplaced.

-- The policy proposal would reduce information that might be useful
in detecting patterns of exports to customers engaged in proliferation
activities because it would eliminate an annual reporting requirement
that provides information on end users.

(1)Export Controls: System for Controlling Exports of High Performance
Computing is Ineffective (GAO-01-10, Dec. 18, 2000).

(2)The Commerce Department considers a high performance computer to be
one that exceeds a defined performance threshold, thus requiring an
export license.

(3)See Export Controls: System for Controlling Exports of High
Performance Computing is Ineffective (GAO-01-10, Dec. 2000).

(4)Export Controls: System for Controlling Exports of High Performance
Computing is Ineffective (GAO-01-10, Dec. 18, 2000).

(end excerpt)

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