United States Government Accountability Office

GAO Report to the Committee on Armed 

Services, House of Representatives 

DEFENSE 

TECHNOLOGIES 

DOD’s Critical 

Technologies Lists 

Rarely Inform Export 

Control and Other 

Policy Decisions 

July 2006 

 

GAO-06-793 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2006

DEFENSE TECHNOLOGIES 

DOD’s Critical Technologies Lists Rarely 

Inform Export Control and Other Policy 

Decisions 

Highlights of GAO-06-793, a report to the 

Committee on Armed Services, House of 

Representatives 

Major acquisitions in the

Department of Defense’s (DOD)

force transformation rely on

maintaining technological 

superiority to ensure U.S. military 

dominance. Failure to identify and 

protect critical technologies makes 

U.S. military assets vulnerable to 

cloning, neutralization, or other 

action that degrades current and

anticipated capabilities. 

To help minimize these risks, 

DOD’s Militarily Critical 

Technologies Program developed

and periodically updates two lists 

of technologies—the Militarily

Critical Technologies List (MCTL) 

and the Developing Science and 

Technologies List (DSTL). While

the lists are primarily intended to 

inform U.S. export control 

decisions, they can also inform 

counterintelligence activities, 

research plans, and technology 

protection programs, making MCTL 

and DSTL fundamental resources

for security decisions. 

To ensure these lists are 

informative, GAO assessed the

Militarily Critical Technologies 

Program’s process for updating the 

MCTL and DSTL and determined

how the lists are used to inform

export control and DOD policy

decisions. 

What GAO Recommends

GAO is recommending that DOD 

take several actions to better 

ensure that efforts to identify

critical technologies meet user

requirements. DOD concurred 

with our recommendations. 

The Militarily Critical Technologies Program’s process for updating the 

MCTL and DSTL has generated lists that are of questionable value. To update 

the lists, working groups of experts from government, industry, and 

academia identify militarily critical technologies. However, participation in 

the working groups is voluntary, and some experts choose not to participate 

or do not participate fully. Validation of the updates—a critical check to 

ensure the lists are complete and accurate—also provides little assurance 

that the lists are of value. More than one-third of the reviewers 

acknowledged they do not have the technical expertise necessary to validate 

the updates, and one-quarter did not review the lists. The lists are also out of 

date. Although a stated program goal calls for all 20 sections of the lists to be 

completely updated at least every 4 years, about half of the sections on the 

MCTL—including technologies related to weapons, communications, and 

biological warfare—have not been updated for 10 years. The DSTL is also 

out of date; almost half of the sections have not been updated in the past 

5 years. 

With the limited value of the MCTL and DSTL, agencies tend to rely on other 

information sources to inform export control and DOD policy decisions. 

According to DOD and Department of Commerce export control officials, 

the MCTL is too broad, difficult to use, and out of date to inform export 

control proposals or export licensing decisions. Concerned about the 

MCTL’s accuracy and reliability, the Air Force instructed its personnel not to 

use the MCTL. The DSTL is also seldom used—in part because some DOD 

components were not aware of the list. For those components that were 

aware of the DSTL, some found it only marginally useful because it too is out

of date. Several DOD components have developed their own efforts to track 

global technologies. For example, the Army established international 

technology centers dedicated to identifying international cooperative 

opportunities as well as to maintain knowledge of foreign research efforts to 

avoid technological surprises for the warfighter. 

Most Recent Updates by Fiscal Year for MCTL and DSTL Sections as of April 30, 2006 

50% 45%

5%

One section has not

been created

1-4 years

5+ years

Source: GAO. 

MCTL DSTL

50% 45%

5%

One section has not

been created

1-4 years

10 years

www.gao.gov/cgi-bin/getrpt?GAO-06-793.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Ann CalvaresiBarr at (202) 512-4841 or

calvaresibarra@gao.gov. 
Contents 

Letter 1

Results in Brief 2 

Background 3

DOD’s Updates of the MCTL and DSTL Produces Lists of Limited 

Value 6

Agencies Tend to Rely on Information Other than the MCTL and 

DSTL to Support Decisions about Critical Technologies 11 

Conclusions 16

Recommendations for Executive Action 16 

Agency Comments and Our Evaluation 17 

Scope and Methodology 18 

Appendix I Agency Comments 20 

Appendix II GAO Contact and Staff Acknowledgments 24 

Related GAO Products 25 

Tables 

Table 1: Most Recent Updates by Fiscal Year for MCTL Categories, 

as of April 30, 2006 9 

Table 2: Most Recent Updates by Fiscal Year for DSTL Categories, 

as of April 30, 2006 10 

Figures 

Figure 1: Comparison of the MCTL and DSTL 5 

Figure 2: Categories of Technologies Covered by the MCTL and 

DSTL 6

Figure 3: Reviewers of Proposed Updates to the MCTL and DSTL 7 

Page i GAO-06-793 Defense Technologies
Abbreviations 

DOD Department of Defense 

DSTL Developing Science and Technologies List 

MCTL Militarily Critical Technologies List 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-06-793 Defense Technologies
United States Government Accountability Office

Washington, DC 20548 

 

July 28, 2006

The Honorable Duncan L. Hunter 

Chairman 

The Honorable Ike Skelton 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

The Honorable Duncan L. Hunter 

Chairman 

The Honorable Ike Skelton 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

Technological advantage is fundamental to U.S. military dominance in 

21st-century warfare. Major acquisitions in the Department of Defense’s 

(DOD) ongoing force transformation—including manned and unmanned 

aircraft systems, networkcentric communications systems, and air and

ground weapons—rely on maintaining technological superiority. Failure to 

identify and protect critical technologies makes U.S. military assets 

vulnerable to cloning, neutralization, or other action that degrades current 

and anticipated capabilities. 

Technological advantage is fundamental to U.S. military dominance in 

21st-century warfare. Major acquisitions in the Department of Defense’s 

(DOD) ongoing force transformation—including manned and unmanned 

aircraft systems, networkcentric communications systems, and air and

ground weapons—rely on maintaining technological superiority. Failure to 

identify and protect critical technologies makes U.S. military assets 

vulnerable to cloning, neutralization, or other action that degrades current 

and anticipated capabilities. 

To help minimize these risks, DOD’s Militarily Critical Technologies 

Program developed and periodically updates two lists of technologies—

the Militarily Critical Technologies List (MCTL) and the Developing 

Science and Technologies List (DSTL)—each consisting of 20 sections. 

These lists are primarily intended to inform U.S. export control decisions, 

but can also help inform counterintelligence activities, research plans, and 

technology protection programs. As such, the MCTL and DSTL are 

considered fundamental to identifying technologies critical to national 

security that can help inform decisions to ensure U.S. technological 

advantage for the warfighter. 

To help minimize these risks, DOD’s Militarily Critical Technologies 

Program developed and periodically updates two lists of technologies—

the Militarily Critical Technologies List (MCTL) and the Developing 

Science and Technologies List (DSTL)—each consisting of 20 sections. 

These lists are primarily intended to inform U.S. export control decisions, 

but can also help inform counterintelligence activities, research plans, and 

technology protection programs. As such, the MCTL and DSTL are 

considered fundamental to identifying technologies critical to national 

security that can help inform decisions to ensure U.S. technological 

advantage for the warfighter. 

Redefined national security threats, rapid technological advances, and 

increasing efforts by adversaries to gain access to U.S. military weapon 

system technology heighten the need to identify and protect militarily 

critical technologies. Given the importance of the MCTL and DSTL, you

asked us to (1) assess the Militarily Critical Technologies Program’s 

process for updating the MCTL and DSTL and (2) determine how the lists 

are used to inform export control and DOD policy decisions.

Redefined national security threats, rapid technological advances, and 

increasing efforts by adversaries to gain access to U.S. military weapon 

system technology heighten the need to identify and protect militarily 

critical technologies. Given the importance of the MCTL and DSTL, you

asked us to (1) assess the Militarily Critical Technologies Program’s 

process for updating the MCTL and DSTL and (2) determine how the lists 

are used to inform export control and DOD policy decisions.

To assess how the lists are updated, we met with officials from the 

Militarily Critical Technologies Program and the Institute for Defense 

Analyses—the contractor that develops list updates—and also reviewed 

relevant program guidance, directives, and applicable statutory provisions. 

Using program guidance, we evaluated how the last five section updates to

To assess how the lists are updated, we met with officials from the 

Militarily Critical Technologies Program and the Institute for Defense 

Analyses—the contractor that develops list updates—and also reviewed 

relevant program guidance, directives, and applicable statutory provisions. 

Using program guidance, we evaluated how the last five section updates to

Page 1 GAO-06-793 Defense Technologies
the MCTL and DSTL were conducted. We identified 20 DOD components 

responsible for validating updates prior to issuance and interviewed 19. 

We compared when sections of the MCTL and DSTL were last updated 

over the past 10 years with stated program goals for updating the lists. We 

identified intended uses of the MCTL and DSTL through interviews with 

program officials and review of program documents and applicable law. 

To determine how the lists are used, we interviewed officials from various 

DOD organizations within the offices of the Under Secretary of Defense 

for Acquisition, Technology, and Logistics and the office of the Under 

Secretary of Defense for Policy, military services, several combatant 

commands, Defense Intelligence Agency, as well as officials from the 

Department of Commerce. In addition, we identified other mechanisms 

DOD has used to identify critical technologies and determined how these 

efforts are coordinated with the MCTL and DSTL process. We conducted 

our work from October 2005 to June 2006 in accordance with generally

accepted government auditing standards. 

The Militarily Critical Technologies Program’s updates of the MCTL and 

DSTL have generated lists that are of limited value because they are not 

appropriately validated and are largely out of date. Tasked by DOD, the 

Institute for Defense Analyses developed a process for updating the lists 

by creating technology working groups of experts from government, 

industry, and academia to identify militarily critical technologies. There 

are a number of inherent challenges to the process. For example, expert 

participation in the working groups is voluntary, so some experts chose 

not to participate or do not participate fully in the process. These inherent

challenges increase the importance for DOD to validate section updates—

a critical check to ensure the lists are complete and accurate. However, 

the validation process provides little assurance that the lists are of value. 

For example, more than one-third of the reviewers stated they do not have

the technical expertise necessary to validate the updates. Further, DOD 

assumes that reviewers concur with the updates if it receives no 

comments—yet one-quarter of the reviewers did not review the lists. At 

the same time, the lists have not been kept up to date. For example, 9 of 

the 20 MCTL sections—including technologies related to weapons, 

communications, and biological warfare—have not been updated for 

10 years, although a stated program goal calls for these lists to be 

completely updated at least every 4 years. The DSTL is similarly out of 

date; nearly half of the sections have not been updated in the past 5 years. 

Results in Brief 

The MCTL and DSTL have generally not been used to inform export 

control decisions as originally intended as well as DOD policy decisions. 

Page 2 GAO-06-793 Defense Technologies
According to DOD and Commerce export control officials, the MCTL is 

not used to develop export control proposals or to inform individual 

export licensing decisions because the list is too broad and out of date. In

fact, in 1996, the Air Force instructed its personnel not to use the MCTL 

because of concerns about its accuracy and reliability. Military officials 

involved in anti-tamper decisions associated with weapon system 

development agree that the MCTL’s usefulness is limited for these reasons. 

The DSTL is also seldom used—in part because many of the DOD 

components we interviewed were not aware of the list. For those 

components that were aware of the DSTL, some found it only marginally 

useful because, like the MCTL, it is out of date. Some DOD and military 

services have developed efforts to track global technologies similar to the 

DSTL. However, these efforts are more expansive, further eclipsing the 

value of the list. For example, the Army established international 

technology centers dedicated to identifying international cooperative 

opportunities as well as to maintain knowledge of foreign research efforts 

to avoid technological surprises for the warfighter. 

We are recommending that the Secretary of Defense take several actions 

to include determining user requirements, reassessing and clarifying the 

MCTL’s purpose based on those requirements, determining an approach 

and implementation plan that meets user needs, and considering the utility 

of the DSTL. DOD concurred with our recommendations. However, it 

does not plan to take any action beyond what it has already completed or

planned to do. We believe DOD needs to take additional steps to 

implement our recommendations. 

DOD considers maintaining military superiority a key priority and has 

established an agencywide policy to treat defense-related technology as a 

valuable, limited national security resource that should be invested in and 

protected to pursue national security objectives.1

 Many DOD organizations 

and other federal agencies have a need to know what is militarily critical

to assist in planning program activities related to technology and to help 

inform decision making. Within DOD specifically, knowledge about 

militarily critical technologies is needed for such activities as 

Background 

• consideration of anti-tamper protection of critical technologies on 

defense systems, 

 1

 DOD Directive 2040.2, January 17, 1984. 

Page 3 GAO-06-793 Defense Technologies
• counterproliferation programs and activities, and

• research and development planning. 

Similarly, other federal agencies depend on DOD to identify militarily 

critical technologies. For example, the Departments of Commerce and 

State rely in part on DOD’s input on what is militarily critical to inform 

export control decisions. The Federal Bureau of Investigation also needs 

to be aware of DOD-identified critical technologies to determine which 

technologies need protection from being acquired or exploited by foreign 

intelligence collection efforts. 

In response to the Export Administration Act of 1979,2

 which governs the 

exports of items with both military and civilian applications, DOD 

established the Militarily Critical Technologies Program in 1980 to 

periodically identify and assess technologies that are critical to retaining 

dominance for the warfighter. The Militarily Critical Technologies 

Program produces a restricted and a public version of both the MCTL and 

the DSTL. DOD has contracted with the Institute for Defense Analyses, a 

federally funded research and development center, since the inception of 

the program to furnish scientific and technical support in developing and 

maintaining the lists. The MCTL covers technologies that are of concern in

the near term, while the DSTL covers those in the longer term. (See fig. 1 

for comparison of the lists.) Program oversight is provided by DOD’s 

Office of International Technology Security.3

 Over the past 5 years, DOD 

has provided approximately $2 million annually to support the Militarily 

Critical Technologies Program. 

 2

 50 U.S.C. app. § 2401 et seq. Authority granted by the Act expired on August 20, 2001. 

Executive Order 13222 continues the export control regime established under the Act and 

the Export Administration Regulations. 

3

 The Office of International Technology Security has been under the Directorate for

Defense Research and Engineering since fiscal year 2004. In prior years, the office was 

under the Defense Threat Reduction Agency.

Page 4 GAO-06-793 Defense Technologies
Figure 1: Comparison of the MCTL and DSTL 

Source: DOD documents.

• Compendium of goods and technologies that DOD has

 determined would permit significant advances in the develop-

 ment, production, and use of military capabilities.

• Contains detailed technical descriptions of technology areas

 that DOD assesses as being crucial to the continued superior

 performance of U.S. military systems or as being able to

 improve the affordability of U.S. military systems.

Today 5 Years Beyond

MCTL DSTL

• Compendium of scientific and technological capabilities being

 developed worldwide that have the potential to significantly enhance

 or degrade U.S. military capabilities.

• Focuses on technologies that are likely to emerge and includes basic

 research, applied research, and advanced technology development.

The lists are divided into 20 technology sections (see fig. 2), and each

section is developed and updated by a technology working group led by a 

chair and cochair and composed of experts. Each working group identifies

militarily critical technologies and the parameters at which they are 

critical, based on definitions of what is militarily critical established by the 

Export Administration Act.4

 Each working group is responsible for one 

MCTL and one DSTL section covering the same topic, such as aeronautics 

technology. The Institute for Defense Analyses has established broad 

guidance for the chairperson of the technology working groups to use 

regarding the update process. This guidance in part indicates that working 

groups should consist of experts from government, industry, and academia 

and that they should reach consensus on what is critical. 

 4

 The Export Administration Act established a process for the Secretary of Defense to 

identify militarily critical goods and technologies that should be considered by the

Secretary of Commerce for inclusion on the Commerce Control List. To identify critical 

technologies, DOD is required to consider (1) arrays of design and manufacturing knowhow; (2) keystone manufacturing, inspection, and test equipment; (3) goods accompanied 

by sophisticated operation, application, or maintenance know-how; and (4) keystone

equipment which would reveal or give insight into the design and manufacture of a U.S. 

military system. 

Page 5 GAO-06-793 Defense Technologies
Figure 2: Categories of Technologies Covered by the MCTL and DSTL 

Source: DOD.

 

• Aeronautics technology

• Armament and energetic technology

• Biological technology

• Biomedical technology

• Chemical technology

• Directed and kinetic energy technology

• Energy systems technology

• Electronics technology

• Ground combat systems technology

• Information systems technology

• Lasers and optics technology

• Manufacturing and fabrication technology

• Marine systems technology

• Materials and processes

• Nuclear technology

• Positioning, navigation, and time technology

• Information security

• Signature control technology

• Space systems technology

• Weapons effects technology

In updating the MCTL and DSTL, the technology working groups face 

several challenges, including identifying and engaging experts in the 

process and interpreting the definition of militarily critical. These 

challenges increase the importance of DOD’s validation process—a critical 

check to ensuring the lists are complete and accurate. However, this 

process is not adequate to provide this assurance. At the same time, the 

lists are significantly out of date. As a result, the lists are of questionable 

value. 

Working group chairs face two key challenges in identifying and selecting

experts to participate in the technology working groups that update the 

MCTL and DSTL. First, participation in the working groups is voluntary, 

and according to several chairs we spoke with, engaging the experts—

including those employed by DOD—can be challenging since some 

selected experts participate only informally or are unable to participate at

all because of competing work priorities. Second, according to DOD and 

Institute for Defense Analyses officials, it is challenging to determine the 

parameter at which a particular technology becomes militarily critical and 

is therefore subject to interpretation by the working group. One chair 

defines “militarily critical” for the working group, while others rely on the 

individual interpretations and judgments of the working group members. 

DOD’s Updates of the 

MCTL and DSTL

Produces Lists of 

Limited Value 

Validation Process 

Provides Little Assurance 

That Lists Are Complete 

and Accurate 

These inherent challenges in the process place greater importance on the

need to validate the lists. To ensure the lists are complete and accurate, 

DOD components review and validate the working groups’ updates— 

a process DOD program officials consider a critical check of the working 

groups’ efforts. Figure 3 lists the DOD reviewers. 

Page 6 GAO-06-793 Defense Technologies
Figure 3: Reviewers of Proposed Updates to the MCTL and DSTL 

Source: DOD.

• Office of Assistant Secretary for Defense,

 Homeland Defense

• Office of Assistant Secretary for Defense,

Special Operations/Low Intensity Conflict

• Office of Assistant Secretary for Defense,

 Defense Security Cooperation Agency

• Defense Advanced Research Projects Agency

• Defense Threat Reduction Agency

• Deputy Director of Defense, Research and

 Engineering

• Defense Contract Management Agency

• Transportation Combatant Command

• Joint Forces Combatant Command

• Strategic Combatant Command

• Special Operations Combatant Command

• Defense Intelligence Agency

• Pentagon Force Protection Agency

• Defense Logistics Agency

• Department of the Air Force

• Defense Security Service

• Department of the Army

• Joint Chiefs of Staff

• Department of the Navy

• Missile Defense Agency

However, we found a number of weaknesses in this critical check. First, 

reviewers are unclear about how to validate proposed updates or what 

factors to consider when reviewing proposed updates. For example, one 

reviewer indicated that the purpose of the MCTL is to inform decisions on 

technologies that may need to be export controlled, but was unsure 

whether the review should validate that the technologies in proposed 

updates need to be controlled or whether to ensure that parameters of 

technologies listed are accurate. Reviewers stated that they are not 

informed as to what is added, deleted, or otherwise changed from one 

update to the next. Without instruction or information on the updates, 

validation of the changes to the lists may be little more than a reviewer’s 

guess. Two reviewers were unsure how to interpret “militarily critical” 

when reviewing the proposed updates and therefore did not know how to 

comment. In addition, no guidance is provided to reviewers on factors to 

consider during the validation process. 

Second, the reviewers may not have the technical knowledge to validate 

the updates. Eight reviewers stated they or their organizations lack the 

necessary expertise to determine whether the lists were complete or 

accurate. Program officials stated they do not currently have a process to 

determine whether they have the proper reviewers or if these reviewers 

are adequately validating proposed updates. 

Finally, program officials assume concurrence with the lists if reviewers 

have not provided feedback within 30 days. According to program 

officials, the process is working well because reviewers seldom provide 

feedback or comments on proposed MCTL or DSTL updates. However, 

one-quarter of the reviewers did not review the lists. Specifically, five

reviewers told us that they receive MCTL and DSTL updates but do not 

Page 7 GAO-06-793 Defense Technologies
comment on them. In addition, according to our analysis of the last five 

updates to the MCTL and DSTL, eight reviewers have provided comments 

to at least one update. 

MCTL and DSTL Lack 

Currency 

A Militarily Critical Technologies Program goal is to completely update the 

MCTL and DSTL at least every 4 years by updating about 5 sections of 

each list every year. According to program officials, this goal was set to 

keep the lists as current as possible within budget limitations. However, 

this goal has not been met. The Institute for Defense Analyses produced 

only one update of the MCTL in fiscal year 2004 and four updates in fiscal 

year 2005 (see table 1). Furthermore, 9 of 20 MCTL sections have not been 

updated since 1996—the last time the MCTL was completely updated. 

Page 8 GAO-06-793 Defense Technologies
Table 1: Most Recent Updates by Fiscal Year for MCTL Categories, as of April 30, 2006 

Technology 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Aeronautics z

Armament and energetics z

Biological z

Biomedicala

Chemical z

Directed and kinetic energy z

Electronics z

Energy systems z

Ground systems z

Information security z

Information systems z

Lasers and optics z

Marine systems z

Materials and processing z

Nuclear z

Positioning, navigation, and time z

Processing and manufacturing z

Signature control z

Space systems z

Weapons effects z

Source: DOD. 

a

The biomedical section of the MCTL has not yet been created. 

The DSTL is also out of date. The institute did not update any sections in

fiscal year 2004 and produced only one update in fiscal year 2005. Over the 

past 5 years, only half of the DSTL sections have been updated (see 

table 2). 

Page 9 GAO-06-793 Defense Technologies
Table 2: Most Recent Updates by Fiscal Year for DSTL Categories, as of April 30, 2006 

Technology 1999 2000 2001 2002 2003 2004 2005 2006

Aeronautics z

Armament and energetics z

Biological z

Biomedical z

Chemical z

Directed and kinetic energy z

Electronics z

Energy systems z

Ground combat systems z

Information security z

Information systems z

Lasers and optics z

Manufacturing and fabrication z

Marine systems z

Materials and processing z

Nuclear

a

Positioning, navigation, and time z

Signature control z

Space systems z

Weapons effects z

Source: DOD. 

a

The nuclear section of the DSTL has not yet been created. 

Program officials explained that delays were in part the result of internal 

disruptions to the program due to frequent changes in senior leadership, 

but were unable to provide information on how they monitor or measure 

whether goals for updating the lists are being met. Regardless, program 

officials stated they are satisfied with how the process for updating the 

lists is working and noted that the lists are available on the Web site for 

public comment. In 2005, program officials held forums to obtain feedback 

from list users and participants in the technology working groups about 

the process for updating the lists. In response to user feedback expressing 

concern about the process, program officials developed an action plan that 

Page 10 GAO-06-793 Defense Technologies
in part called for an independent assessment of the MCTL and DSTL 

process for updating the lists, which was not completed. Instead, a 

program official began an internal review, concluding that problems 

stemmed from funding constraints and a lack of senior DOD leadership to

support the program. 

While the MCTL was created to help determine items that need to be 

controlled, the list has generally not been used to inform export control 

and DOD policy decisions. Several DOD components have developed their 

own efforts to catalog critical technologies to meet their needs. The DSTL 

is also seldom used and may be eclipsed by more extensive DOD efforts. 

A number of DOD components, including the armed services, as well as 

the Department of Commerce, do not rely on the MCTL to inform export 

control or DOD policy decisions. While the MCTL is expected to inform 

review of export license applications or export control decisions, the 

Defense Technology Security Administration—which represents DOD on 

export control decisions—does not use the MCTL for export licensing 

decisions or to inform DOD’s input to U.S. government export control 

proposals that are considered by the multilateral export control regime 

known as the Wassenaar Arrangement.5

 Instead, the Defense Technology 

Security Administration relies on other sources of information, including

technology-specific information from subject matter experts associated 

with the Institute for Defense Analyses, who may also participate in MCTL 

updates. According to Defense Technology Security Administration 

officials, the MCTL is too broad, out of date, and difficult to navigate to be 

an effective tool for informing export licensing decisions or export control 

proposals. 

Agencies Tend to Rely 

on Information Other 

than the MCTL and 

DSTL to Support 

Decisions about 

Critical Technologies 

MCTL Rarely Informs 

Export Control or DOD 

Policy Decisions 

 5

 The Wassenaar Arrangement is an agreement among 40 nations to promote transparency 

and greater responsibility in transfers of conventional arms and dual-use goods and 

technologies.

Page 11 GAO-06-793 Defense Technologies
Officials from the key export control regulatory agencies6

 agreed that the 

MCTL lacks the specificity and currency needed for export control 

decisions. These have been long-standing issues. In 1982, we reported that 

the Departments of Commerce and State and private industry were 

concerned that the MCTL was not specific enough to be useful as a 

practical daily guide for export control decisions.7

 Presently, Commerce 

officials expressed additional concerns that because of delays in updating

sections of the MCTL, the list contains items that they have already 

determined need not be controlled or limited. Further, the chair for the 

Militarily Critical Technologies Program’s electronics technical working 

group acknowledged that microprocessors are included as militarily 

critical on the MCTL at parameters no longer controlled on Commerce’s 

control list. Because of the lack of specificity and lack of currency, 

Commerce officials told us that they do not use the MCTL to inform items 

to control. Instead, they rely on the judgment of the Defense Technology 

Security Administration. 

The military services also seldom use the MCTL when reviewing export 

license applications. In 1996, the Air Force issued guidance instructing 

personnel not to use the MCTL to inform export control and other 

decisions. This guidance, which is still in effect today, specifically 

prohibits the Air Force’s export control specialists, intelligence analysts, 

investigators, system security engineers, operations security officers, and

public affairs officers from using the MCTL to inform export decisions or 

to determine the importance of military-related technologies. The 

guidance further states that because the MCTL is out of date, its utility is 

substantially limited and it may only serve as a desk reference or 

dictionary to obtain a description of a particular dual-use technology. 

While Navy officials responsible for export control decisions stated that 

the MCTL occasionally serves as the starting point to inform decisions, 

they rely on their own export licensing databases for export control 

policy. In addition, a senior Navy official stated that even though extensive 

time and effort go into the development and maintenance of the MCTL, the 

list does not provide significant value. Navy officials also noted that the

MCTL is out of date and raised concerns regarding its accuracy. The Army 

 6

 Regulation of the U.S. export control system is primarily divided between the 

Departments of State and Commerce. DOD is a reviewer of both State and Commerce 

export license applications. 

7

 GAO, Comptroller General: Export Control Regulation Could Be Reduced without 

Affecting National Security, GAO/ID-82-14 (Washington D.C.: May 26, 1982). 

Page 12 GAO-06-793 Defense Technologies
Director of Policy for Security Cooperation, Resources, and Exports 

similarly stated the MCTL is inappropriate for being used to inform export 

control decisions because the lists are too component- and materialfocused and do not list specific systems. 

As with export control decisions, we found that the MCTL is seldom used 

to inform various DOD policy decisions, including those related to 

identifying and protecting critical technology on weapon systems, 

counterintelligence efforts related to critical technologies, and programs 

reporting on the protection of the defense industrial base. For example, 

DOD officials stated that they do not directly use the MCTL to inform 

decisions related to determining whether to use anti-tamper protections.8

Yet the MCTL is intended to be a primary resource in DOD’s process for 

identifying critical technologies in defense systems that may require antitamper protections to discourage or delay reverse engineering. While 

officials stated that the MCTL is a starting point to select critical 

technologies for protection, the MCTL’s limitations—including the fact 

that it is out of date and does not incorporate previously identified critical

technologies or anti-tamper decisions—led the anti-tamper executive 

agent to develop a more comprehensive tool for identifying and tracking 

critical technologies that may need anti-tamper protection. 

The MCTL is intended to be used as a reference for counterintelligence 

initiatives throughout the DOD intelligence community. 

Counterintelligence program officials need to know what technologies are 

critical and which ones are being targeted through foreign intelligence 

collection activities. Some counterintelligence entities, including the 

Defense Intelligence Agency and Army Counterintelligence, indicated that 

the MCTL informs decisions about technologies that should be examined 

to ensure that each military service protects them in a consistent manner, 

but have found limitations in using the list. For example, officials from 

Army Counterintelligence stated that the MCTL is not current enough to 

inform decisions needed to help the military services consistently track 

and protect their current technologies. Due to the difficulties in using the 

MCTL, the Army has developed a program to identify technologies that are 

critical to individual Army acquisition programs. Defense Intelligence 

Agency officials stated that the taxonomy of the MCTL technology 

 8

 For more information on DOD’s anti-tamper program, see GAO, Defense Acquisitions:

DOD Needs to Better Support Program Managers’ Implementation of Anti-Tamper 

Protection, GAO-04-302 (Washington, D.C.: Mar. 31, 2004). 

Page 13 GAO-06-793 Defense Technologies
categories is useful. However, officials have found that some MCTL 

sections must be augmented with more current critical technology 

information to help inform decisions. Outside of DOD counterintelligence 

activities, Militarily Critical Technologies Program officials stated that 

they are entering into an agreement with the Federal Bureau of 

Investigation to provide support to the bureau’s critical national assets 

program. 

The MCTL is also intended to inform decisions made by the Committee on 

Foreign Investment in the United States, an interagency committee 

responsible for reviewing foreign acquisitions of U.S.-based companies to 

determine whether the proposed acquisition could pose a threat to 

national security.9

 DOD, which is a member of the committee, provides 

input through its Office of the Deputy Under Secretary of Defense for 

Industrial Policy on decisions related to proposed transactions that may 

involve technologies critical to DOD interests. According to a DOD official, 

the MCTL is not used to inform these decisions. Instead, DOD relies on 

input from technical experts in the Directorate for Defense Research and

Engineering, who may use the MCTL as one of their many sources of 

information. 

In addition, DOD Industrial Policy officials have created a Defense 

Industrial Base Capabilities Study Series,10 which in part identifies critical 

technologies and companies that produce them to help inform DOD input 

to Committee on Foreign Investment in the United States decisions as well 

as other DOD policy decisions. The Defense Industrial Base Capabilities 

Study Series was completed in June 2005 and lists over 1,400 critical 

technologies. The study series notes that it includes examples of critical 

technologies that the MCTL should consider incorporating. However, 

Militarily Critical Technologies Program officials said that the series uses a 

 9

 In 1988, Congress enacted the Exon-Florio amendment to the Defense Production Act, 

which authorized the President to investigate the impact of foreign acquisitions of U.S. 

companies on national security. The President delegated the authority to conduct

investigations to the interagency Committee on Foreign Investment in the United States, 

which is chaired by the Secretary of the Treasury. For more information on the committee 

see, GAO, Defense Trade: Enhancements to the Implementation of Exon-Florio Could

Strengthen the Law’s Effectiveness, GAO-05-686 (Washington D.C.: Sept. 28, 2005). 

10 The Office of the Deputy Under Secretary of Defense for Industrial Policy Directorate 

published five reports under the Defense Industrial Base Capability Study Series from 2004

through 2005. The studies identified critical enabling technologies that support Joint Chiefs 

of Staff’s operational requirements and the industrial base capabilities needed to meet the

requirements. 

Page 14 GAO-06-793 Defense Technologies
different definition of critical technology and has not coordinated the 

MCTL and the series’ lists of critical technologies. 

DSTL Is Seldom Used and 

May Be Eclipsed by More 

Extensive Efforts 

Many DOD officials we spoke with were either not aware of the DSTL or 

seldom used it. For example, officials from the Office of Naval Research 

and the Naval Research Labs were unaware of the DSTL. Officials from the 

Army’s Office of the Deputy Assistant Secretary for Research and 

Technology/Chief Scientist, who were aware of the existence of the DSTL, 

stated that the DSTL is not useful for informing science and technology 

decisions because it is overly broad, its taxonomy does not align with 

Army Research and Technology taxonomy, and its assessments are rarely 

in consonance with Army Research and Technology subject matter 

experts. Furthermore, the Army’s Deputy Assistant Secretary for 

Research and Technology/Chief Scientist maintains sufficient in-house 

expertise for all required program planning activities and does not require 

the DSTL to complete mission requirements. In addition, Defense 

Advanced Research Projects Agency officials indicated that the DSTL has 

limited applicability to the agency’s research efforts. 

The DSTL is intended to forecast worldwide technology capabilities that 

could threaten U.S. technological superiority or surprise warfighters in 

theater as well as to assist DOD science and technology planning. 

However, the Defense Technology Security Administration has developed 

a “Top Ten Technologies” list that identifies emerging technologies. 

According to Defense Technology Security Administration officials, the 

Top Ten list is designed to help DOD identify paradigm-shifting 

technologies on or approaching the horizon to provide a basis for defense 

proposals on how these technologies should be controlled and to inform 

decisions on how these technologies might benefit the military. In 

addition, officials who represent the military services and DOD research 

and development components have established more extensive efforts to 

aid science planning and track developing and future technologies. For 

example, both the Army and the Navy maintain offices and technology 

centers worldwide to monitor and assess research efforts of foreign 

governments and industries to both inform science and technology 

planning and identify rapidly evolving or breakthrough technologies. Army 

officials explained that the Army’s science and technology research 

activities, with a fiscal year 2005 annual budget of approximately 

$1.7 billion, have more expertise to comprehensibly track all areas of 

developing global technology than the Militarily Critical Technologies 

Program, which has an average annual budget of $2 million.

Page 15 GAO-06-793 Defense Technologies
At the same time, the Directorate for Defense Research and Engineering 

has developed a Global Technology Knowledge Base, which incorporates 

the DSTL along with other information provided by the military services. 

Like the DSTL, the Global Technology Knowledge Base is intended to 

serve as a broad-based evaluation of foreign technology and an assessment 

of foreign technology development efforts to assist in the planning of 

DOD’s science and technology efforts and offers insight into potential 

collaboration opportunities with foreign entities or utilization of foreign 

technologies. Although the knowledge base incorporates DSTL 

information, a Directorate for Defense Research and Engineering official

responsible for the knowledge base told us that the DSTL’s value to the 

database is limited because of currency and reliability issues. 

DOD has widespread requirements to know what critical technologies are 

needed to ensure a technological edge for the warfighter. These 

requirements demand that DOD leadership develop a solid framework for 

identifying the technologies that will guide critical decisions on what to 

control and protect. Relying on militarily critical technology lists that are 

of questionable value is risky—especially in an environment of rapid 

technological change and redefined national security threats. Without 

clear and current information on what items are militarily critical, many 

DOD components have developed their own mechanisms for identifying 

and tracking critical technologies. While these separate efforts may satisfy 

parochial concerns, they do not ensure an effective approach for 

identifying and coordinating information on critical technologies needed 

to inform decisions on how to protect U.S. security interests. 

Given the need of numerous programs to know what is militarily critical, 

we recommend that the Secretary of Defense direct the Director for 

Defense Research and Engineering to determine users’ requirements and 

on the basis of those requirements, reassess and clearly define the MCTL’s 

purpose. If the purpose deviates from its original intent to inform export 

control decisions, DOD should seek necessary legislative relief. 

Conclusions 

Recommendations for 

Executive Action 

To ensure that users’ requirements are met, we recommend that the 

Secretary of Defense direct the Director for Defense Research and 

Engineering, in conjunction with the Under Secretary of Defense for 

Acquisition, Technology, and Logistics, to 

Page 16 GAO-06-793 Defense Technologies
• examine existing efforts within the department to catalog critical 

technologies and determine best practices for identifying 

technologies; 

• using these best practices, develop an approach that best meets 

user requirements in a timely manner; 

• on the basis of the new approach, identify duplicative efforts, if any; 

ensure the efficient use of resources; and determine what level of 

funding is appropriate; 

• develop an implementation plan for the approach, including

timelines for execution and implementing guidance or directives; 

and 

• establish an oversight mechanism to ensure that user needs are met. 

Given the more expansive existing efforts in DOD to track global science

and technology efforts, we also recommend that the Secretary of Defense

direct the Director for Defense Research and Engineering to determine the 

utility of continuing to maintain the DSTL. 

We provided a draft of this report to DOD and Commerce. DOD concurred 

with our recommendations. However, it does not plan to take any action 

beyond what it had already completed or planned to do. DOD asserts that 

the International Technology Security’s 2005 action plan, developed prior

to our review, addresses most of our seven recommendations. DOD also

maintains that the MCTL is the only list that assesses technologies from an 

export control viewpoint. 

Agency Comments 

and Our Evaluation 

DOD’s comments do not recognize that identifying militarily critical 

technologies serves multiple interests and that many DOD organizations 

and other federal agencies have a need to know what is militarily critical.

Our findings show that shortcomings in the program have led to products 

that are not adequately validated as well as too broad and out of date to 

satisfy users’ needs. DOD’s action plan, which in part discussed steps to 

meet users’ requirements, was limited. For example, DOD, in the 

development of the plan, did not include Defense Technology Security 

Administration or the Department of Commerce—-two key agencies that 

program products are intended to inform for export control decisions. 

Further, DOD does not see the possibilities of how examining efforts in 

the department to catalogue critical technologies and determine best 

practices could benefit the program. By leveraging knowledge and 

potential best practices from other efforts, DOD would have an 

opportunity to take a strategic approach to identify and coordinate 

information on critical technologies that satisfy users’ needs. Therefore, 

Page 17 GAO-06-793 Defense Technologies
DOD will need to take additional steps to implement our 

recommendations. 

DOD’s letter is reprinted in appendix I. We incorporated DOD technical 

comments as appropriate. Commerce did not provide formal comments 

but submitted one technical comment, which we addressed. 

To assess how the lists are updated, we met with officials from the 

Militarily Critical Technologies Program and the Institute for Defense 

Analyses and reviewed relevant program documents, task orders, 

guidance, directives, and applicable statutory provisions. Using program 

guidance and documents, we evaluated how the last five updates to the 

MCTL and DSTL were conducted. Specifically, we reviewed program 

information on the number and types of experts used to conduct the 

updates. We interviewed technology working group chairs responsible for 

10 MCTL and DSTL sections to determine how experts are engaged in the 

process for identifying critical technologies as well as how the definition 

of “militarily critical” is applied to specific technology areas. We identified 

20 DOD components responsible for validating updates prior to issuance. 

We interviewed officials from 19 of the 20 components and determined 

how they reviewed and validated the updates. We also compared MCTL 

and DSTL updates over the past 10 years with program-stated goals for 

updating the lists. 

Scope and 

Methodology 

To determine how the lists are used, we first identified the uses of the 

MCTL and DSTL through interviews with program officials and review of

program documents and applicable statutory provisions. We discussed 

uses of the lists with officials from the Office of Industrial Policy, Defense 

Technology Security Administration, military services, Executive Agent for 

Anti-tamper, Defense Intelligence Agency, Defense Security Service, 

Missile Defense Agency, Defense Security Cooperation Agency, Defense 

Threat Reduction Agency, Joint Chiefs of Staff, Joint Forces Command, 

Special Operations Command, Strategic Command, and Transportation 

Command, Defense Directorate for Research and Engineering’s Office of

International Programs and Science and Technology, Defense Logistics 

Agency, Pentagon Force Protection Agency, Defense Contract 

Management Agency, Office of Special Operations and Low Intensity 

Conflict, Defense Advanced Research Projects Agency, as well as officials 

from the Departments of Commerce and Homeland Security. In addition, 

through interviews with some of these organizations and review of 

documents they provided, we identified other mechanisms DOD has used 

Page 18 GAO-06-793 Defense Technologies
to identify critical technologies and determined how these efforts are 

coordinated with the MCTL and DSTL update process. 

We are sending copies of this report to interested congressional 

committees, as well as the Secretaries of Defense, Commerce, and 

Homeland Security; the Director, Office of Management and Budget; and 

the Assistant to the President for National Security Affairs. In addition, 

this report will be made available at no charge on the GAO Web site at 

http://www.gao.gov. 

Please contact me at (202) 512-4841 or calvaresibarra@gao.gov if you or 

your staff have any questions concerning this report. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found on

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix II. 

Ann Calvaresi-Barr 

Director 

Acquisition and Sourcing Management 

Page 19 GAO-06-793 Defense Technologies
Appendix I: Agency Comments Appendix I: Agency Comments 

Page 20 GAO-06-793 Defense Technologies
Appendix I: Agency Comments

Page 21 GAO-06-793 Defense Technologies
Appendix I: Agency Comments

Page 22 GAO-06-793 Defense Technologies
Appendix I: Agency Comments

Page 23 GAO-06-793 Defense Technologies
Appendix II: GAO Contact and Staff Acknowledgments 

Page 24 GAO-06-793

Appendix II: GAO Contact and Staff 

Acknowledgments 

Ann Calvaresi-Barr (202) 512-4841 or calvaresibarra@gao.gov

In addition to the contact named above, Anne-Marie Lasowski, Assistant 

Director; Noah Bleicher; Andrew Edelson; W. William Russell IV; Karen 

Sloan; Hai Tran; and Joseph Zamoyta made key contributions to 

this report. 

GAO Contact 

Staff 

Acknowledgments 

Defense Technologies
Related GAO Products 

Page 25 GAO-06-793

Related GAO Products 

Defense Trade: Enhancements to the Implementation of Exon-Florio 

Could Strengthen the Law's Effectiveness. GAO-05-686. Washington D.C.: 

September 28, 2005. 

Industrial Security: DOD Cannot Ensure Its Oversight of Contractors 

under Foreign Influence Is Sufficient. GAO-05-681. Washington D.C.: 

July 15, 2005.

Defense Trade: Arms Export Control Vulnerabilities and Inefficiencies 

in the Post-9/11 Security Environment. GAO-05-468R. Washington, D.C.: 

April 7, 2005. 

Defense Trade: Arms Export Control System in the Post9/11Environment. GAO-05-234. Washington, D.C.: February 16, 2005. 

Defense Acquisitions: DOD Needs to Better Support Program Managers’ 

Implementation of Anti-Tamper Protection. GAO-04-302. Washington, 

D.C.: March 31, 2004. 

Nonproliferation: Strategy Needed to Strengthen Multilateral Export 

Control Regimes. GAO-03-43. Washington, D.C.: October 25, 2002. 

Export Controls: Processes for Determining Proper Control of DefenseRelated Items Need Improvement. GAO-02-996. Washington, D.C.: 

September 20, 2002. 

Defense Trade: Mitigating National Security Concerns under 

Exon-Florio Could Be Improved. GAO-02-736. Washington, D.C.: 

September 12, 2002. 

Export Controls: Department of Commerce Controls over Transfers of

Technology to Foreign Nationals Need Improvement. GAO-02-972. 

Washington, D.C.: September 6, 2002. 

Export Controls: More Thorough Analysis Needed to Justify Changes in 

High Performance Computer Controls. GAO-02-892. Washington, D.C.: 

August 2, 2002. 

Export Controls: Issues to Consider in Authorizing a New Export 

Administration Act. GAO-02-468T. Washington, D.C.: February 28, 2002.

Export Controls: Clarification of Jurisdiction for Missile Technology 

Items Needed. GAO-02-120. Washington, D.C.: October 9, 2001.

(120486) Defense Technologies
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