That sexy, sexy insulation

In his speech last Tuesday, President Obama defended the reputation of insulation, stating “See, I told you, insulation’s sexy.”  His assertion that insulation is a hot and sexy building material is based on the cost-effectiveness of insulation for both new construction and retrofits.  And when he stated that “if you saw $20 bills just sort of floating through the window up into the atmosphere, you’d try to figure out how to keep them,” he equates properly insulating a house with saving energy and money.   And we agree—without question, insulation saves energy and money.  Not only is insulation one of the least expensive and best methods of saving money on your utility bills, it also improves your house’s thermal comfort.  So while the Building Technologies Program doesn’t claim expertise at sexiness, we applaud the spirit and message of Obama’s speech.

And insulation is also a key component in the federal government’s energy efficiency strategy.  As the US seeks to reduce energy consumption from buildings in both the residential and commercial sectors, the concept of retrofitting or weatherizing existing building stock has come to the forefront of government policy.  Vice President Biden’s recent report, titled Progress Report: The Transformation to a Clean Energy Economy, backs up the message of the cost-effectiveness and job creation potential of weatherization.  According to the Progress Report, the $5 billion appropriated for the Weatherization Assistance Program (WAP) in the American Recovery and Reinvestment Act of 2009 (ARRA) will weatherize 500,000 houses by the end of 2010 and, combined with private investment, will weatherize 1 million houses by 2012.

In addition to increasing weatherization funding to $5B, ARRA has also increased the percentage of funding that can be used for training (to 20%), raised the WAP qualification cutoff from 150% of the poverty line to 200%, and increased the total per-house weatherization allotment from an average of $2500 to $6500.  This $5B is a good investment not just for the receiving families, but also in terms of job creation.  While the Progress Report fails to provide numbers on how many jobs weatherization should create, it does provide data on the expected job creation from other ARRA energy measures.

Public Investment Private Investment
Clean Energy Measure $ (Billions) Jobs created $ per job created $ (Billions) Jobs created $ per job created
Renewable energy generation and advanced energy manufacturing 23.4 253,000 92,490 43.3 469,000 92,324
Energy manufacturing facilities 2.3 17,000 135,294 5.4 41,000 131,707
Grid modernization 4.0 43,000 93,023 5.7 61,000 93,442
Weatherization (2009 data, no ARRA appropriations) 0.25 8,000 31,250
Weatherization (2010 ARRA FAS estimates 5.0 (48,000-160,000)



Weatherization’s Role in Job Creation

The ARRA cost per job created ratio is a valuable tool for determining which measures are likely to produce the most jobs at the lowest cost.  For example, while public sector investment in energy manufacturing facilities is very capital intensive and yields only one job for every $135,294 invested, renewable energy generation and advanced energy manufacturing is expected to yield one job per $92,490 invested.  By comparison, over the past several years the WAP received $250 million in public funding, directly creating 8000 jobs and weatherizing 100,000 homes annually.  This results in a job creation ratio of one job for every $31,250 of government investment—a highly efficient investment to job ratio. As the budget increases to $5B and the retrofit goal increases to 500,000 houses under the stimulus, the program can be expected to continue as one of the most efficient job creating programs in the clean energy sector.

Assuming that the current weatherization employment was scaled up directly with the additional funding, the additional funding would be expected to produce 160,000 new jobs.  However, several factors will limit weatherization job creation well below this point.

First of all, as more money is spent per house (from $2500 to $6500) houses will be retrofitted with more expensive, less labor intensive measures such as new high-SEER HVAC systems and EnergyStar rated windows.   And so while performing $6500 in retrofits will require more labor than $2500, it will not require over 250% more labor.

Second, as money spent on training and technical assistance increases from 10% to 20% of the budget, less money will go toward directly retrofitting the houses.  However, the higher training and technical assistance appropriation is essential as the nation currently lacks the qualified weatherization professionals necessary to meet the higher weatherization goals.  And without qualified retrofit professionals and specialists, weatherization money will be wasted as installation is not done properly and the program’s full energy efficiency benefits are not realized.

And finally, while the current $5B appropriation is theoretically enough to weatherize the 500,000 house goal at an average cost of $6500, additional program expenses for scaling up operations and state-level training are likely to decease the money available for weatherization wages.

Assuming a ratio of houses retrofitted per job created similar to the 2009 WAP ratio (12.5 houses/job), the program could be expected to create 48,000 jobs.  However, this number is likely to under predict the job creation potential of weatherization as additional retrofit professionals will be needed on each house in order to perform the more extensive retrofit.  Accounting for the additional workers needed to blow interior insulation and replace or repair HVAC systems, doors, and windows, a more realistic ratio would be 9 houses per job.  This yields an estimate of about 70,000 jobs created at $71,429 of government investment per job.  Even this fairly conservative job creation estimate demonstrates the relative cost effectiveness of the WAP and energy efficiency retrofits as compared with other clean energy sector investments.

And at a household level…

The WAP program metrics show that under the $2500/house program households save on average $350 annually on their utility bills, representing a 23% reduction in total utility bills.  This reduction is especially important for low-income families as this sector pays, on average, 16% of their income toward utility bills, as opposed to a national medium of 4-5%.  A key to reducing energy use is to decrease space heating and cooling needs as they together account for on average over 1/3 of a house’s energy use.  And the key to reducing heating and cooling loads?

Insulation.  See, just like President Obama told us, insulation could be a seriously sexy building material.

A few fun facts about insulation and using it in retrofits

What is referred to as insulation is a term for any material that significantly slows down or retards the flow or transfer of heat.  Insulation is measured in terms of its R-value, which is a measure of resistance to heat flow/conductivity.  This equation [DT/QA or, in the US, 1 hour* ft2*°F/Btu] measures only conduction, to which 25-40% of air infiltration is attributed in an average house.  The other two means of air infiltration, convection and radiation, make of the remaining 60-75% of air infiltration in a given house, but are not generally considered when looking at the insulating properties of a material. The higher the R-value, the greater the resistance of the material and the better it insulates.

Insulation is classified primarily by form and by material.  Insulation forms, for example, include rigid, semi-rigid, loose-fill, batt, flexible, reflective, and foamed in place.  And common insulation materials include mineral fiber, organic fiber, and foam glass.

While not all types of insulation are appropriate for retrofitting, many interior and exterior/sheathing insulations can be effectively applied.

Surveying the retrofit case studies from the DOE Building America program, the most popular forms of insulation for retrofitting or weatherizing buildings include blown interior and rigid exterior insulations—specifically blown cellulose and polyisocyanurate rigid insulation/board.  Additional types of insulation utilized include fiberglass bat, sprayed polyurethane foam, spray and rigid foams, and rigid insulation integral to both house wraps and siding.  In all cases, the needs of the particular climate must be taken into account, but some form of insulation is almost always the most cost effective retrofit solution.  For example, in Pasadena, “if you have 300 square feet of glass and you replace it, you go from R-1 to R-3 [which is the typical R value for new windows].  For a fraction of the cost, you can take the 2,000-square-feet of ceiling surface area and increase it from R-6 or R-10 to R-38 at the place where it really matters, in the attic.”  (quote courtesty of Andrew Durben at HartmanBalkwin )

The chart below breaks down the cost savings and types of insulation used in six Building America retrofit cases.

Location Cost Savings Key Insulation Materials in Retrofit
Concord, MA $2031/year Rigid foam on roof and walls, sprayed polyurethane foam in attic and foundation, blown cellulose in walls, XPS insulating sheathing under slab
Pasadena, CA Electric bills halved Blown cellulose in attic
Tucson, AZ 66-75% less heating and cooling House and roof wrapped in polyisocyanurate board/rigid sheathing
Pittsburgh, PA 180 mBtu annually Interior rigid foam in basement, fiberglass batt in basement, blown cellulose in walls and ceilings, sheathing with integral rigid polystyrene insulation, rigid foam and band joist spray foam in ceilings
Newburgh, NY Habitat remodel—HERS of 89.7 Rigid foam XPS extruded polystyrene foam in walls and ceilings, fiberglass batt in floor joists
Wapato, WA 47% or 136.9 mBtu Blow cellulose in walls and ceiling, fiberglass batt in ceiling, rigid insulation house wrap and integral foam insulated siding on walls, fiberglass batt floor assembly

GAO: Release of Nuclear Document Caused No Damage

A five-month long investigation by the Government Accountability Office determined that the inadvertent publication of a 267 page document describing U.S. civilian nuclear research facilities caused no damage to national security and did not require any remedial security measures at the cited facilities.  Yet surprisingly, even though its publication had no adverse consequences at all, GAO endorsed the claim that the document was “sensitive” and recommended that rigorous new procedures be adopted to prevent public disclosure of such information in the future.

See “Managing Sensitive Information: Actions Needed to Prevent Unintended Public Disclosures of U.S. Nuclear Sites and Activities,” Government Accountability Office report GAO-10-251, December 2009.

The inadvertently disclosed document, a draft U.S. government declaration to the International Atomic Energy Agency (IAEA), was transmitted from the White House to Congress in May 2009.  Though it was identified in a cover letter as “sensitive but unclassified,” it was forwarded to the Government Printing Office for publication and was incorporated in an online GPO document database.  Secrecy News identified the document and republished it on June 1.  The New York Times, the Washington Post and other publications reported on it on June 3.  Concluding that a mistake had been made, the GPO removed the document from its public database and recalled the hardcopy editions.  But by that time, tens of thousands of copies had been downloaded around the world.  Speaker of the House Nancy Pelosi asked the GAO to investigate who was at fault, and what damage had been done.

Almost everyone involved was at fault, the GAO concluded.  But what is more remarkable is that the disclosure of the ostensibly “sensitive” document was found to have caused no damage to security at all.

GAO said that the agencies that prepared the unclassified compilation had carefully reviewed it prior to transmitting to Congress “to ensure that information of direct national security significance was not included.”  In cases where site-specific details were described in the draft declaration, such information “was publicly available on agency Web sites or other publicly available documents.”  Department of Energy officials told GAO that “no information detrimental to national security was included in the document.”

After the unintended disclosure of the draft declaration occurred, agencies once again reviewed facility security in light of the document’s public availability.  “Based on these assessments, DOE officials told us they did not increase security at any site,” the GAO said.  Operators of an NRC facility likewise “determined the procedures they had in place were sufficient, even with the release of the draft declaration.”

Unfortunately, instead of critically questioning the “sensitivity” of such a demonstrably innocuous document, the GAO report took for granted that it should never have been published.  Worse, GAO proposed strict new procedures to limit any future disclosures of this kind.

But if a document produces no detrimental effects when disclosed, then it is not sensitive in any meaningful sense of the word.  More rigorous procedures are needed to prevent the unnecessary protection of such material, not to enforce it.  Having missed that central point, the GAO report represents a lost opportunity to advance a more sensible information security policy.

*     *     *

The public disclosure of the draft declaration generated an unusual volume of confusion and misinformation.

“It is probably not that dangerous,” said David Albright of the Institute for Science and International Security in the Washington Post (6/3/09), “but it is a violation of the law.”  But that is not correct.  There is no law prohibiting disclosure of the information in the draft declaration, and so there was no violation of the law.

The document is “a one-stop shop for information on U.S. nuclear programs,” I found myself saying in the New York Times (6/3/09).  Besides being glib, that wasn’t correct either.  The draft declaration dealt only with civilian research programs and excluded U.S. military nuclear programs.

Sen. Christopher Bond (R-MO) said it was all FAS’s fault.  “There’s a group called the Federation of American Scientists – a far Left-wing fringe group that wants to disclose all our vulnerabilities,” he explained to reporters.  “I don’t know what their motives are but I think they are very dangerous to our security.” (“Senator Bond concerned by online posting of civilian nuke sites” by Steve Walsh, Missouri News, June 3, 2009.)

In fact, it is now clear from the GAO investigation that no vulnerabilities were disclosed, no damage to security resulted, and no corrective security measures were required.

*     *     *

Although the International Atomic Energy Agency said in response to an inquiry from FAS that it had no objection to publication of the draft declaration (a fact not noted by the GAO), officials from several U.S. agencies months later remained adamantly opposed to continued public access to the document.

At an August meeting at the State Department, an NRC official told FAS’s Ivan Oelrich and me that the document contained information on the uranium enrichment capacity of certain U.S. companies, the disclosure of which could somehow put them at a commercial disadvantage with foreign uranium producers.  But there are no known indications that anything like that has come to pass.

Another official with the rank of Ambassador made the astonishing claim that if other countries saw just how cursory the U.S.’s reporting of its nuclear activities was, they would soon reduce their own cooperation with the IAEA to a similar, minimal level.

A senior State Department official therefore urged FAS to remove the draft declaration from our website.  The official acknowledged that the document had already been widely disseminated internationally, that it was still posted on several other websites, and that removing it from the FAS website would not make any practical difference of any kind.  But the official courteously requested that we do so, as a “favor.”  We agreed.

Some day, and that day may never come, we will call upon the State Department to do a favor for us.

New Executive Order Awaits Presidential Decision

A new draft executive order on national security classification and declassification policy is expected to be presented to President Obama this week for his personal resolution of issues which remain in dispute among policymakers and affected agencies, especially intelligence agencies.

This marks the first time since the first Bush Administration, nearly two decades ago, that a President has needed to make a final determination on the contents of an executive order because staffers and agencies were unable to reach a consensus view. (Correction: There is a more recent precedent for such presidential involvement. According to Morton Halperin, President Clinton was presented with a “split memo” in 1995 on the question of whether to include a public interest balancing test for declassification in executive order 12958. President Clinton decided against it.)

The currently disputed issues are believed to include the composition of the Interagency Security Classification Appeals Panel, including whether it should include representatives of ODNI or CIA or both, and whether the intelligence agencies should continue to have the veto over Panel declassification decisions that was granted by the George W. Bush Administration.

The final order, which is likely to be issued before the end of December, is expected among other things to direct agencies to conduct a Fundamental Classification Guidance Review in order to eliminate obsolete classification requirements, and to establish a National Declassification Center to coordinate and expedite declassification of historical records, as described in a previous draft dated August 4, 2009.

See “Obama Plan Could Limit Records Hidden From Public” by Pete Yost, Associated Press, December 20, 2009.

State Dept Series Falls Farther Behind Schedule

The U.S. State Department’s official Foreign Relations of the United States (FRUS) series had another disappointing year in 2009 with only two softcopy volumes published to date, including one released last week on “Global Issues, 1973-1976.”

The FRUS series is supposed to provide “comprehensive documentation of the major foreign policy decisions and actions of the United States Government” and it must must be “thorough, accurate, and reliable.”  As such, it is a potentially vital tool for advancing declassification of significant historical records and assuring government accountability, at least over the long run.

Publication of FRUS is not optional.  By statute, “The Secretary of State shall ensure that the FRUS series shall be published not more than 30 years after the events recorded.”  But that 30 year goal, which has rarely if ever been met, is now receding further and further from realization, leaving the Secretary of State in violation of the law.

State Department spokesman Ian C. Kelly did not respond to a request for comment on the Department’s continuing violation of the law on FRUS publication.

But William B. McAllister, the Acting General Editor of FRUS, expressed a hopeful view of the future despite recent turmoil, which included the last-minute withdrawal of person who was to become the new FRUS General Editor.  He said that a third FRUS volume on “Foreign Economic Policy, 1973-1976” would appear before the end of the year, and at least one other in January 2010.

Likewise, Dr. Robert McMahon, who chairs the State Department’s Historical Advisory Committee, said “We continue to be optimistic about publication prospects for FRUS volumes in the near future despite the disappointing number of volumes that came out this year.  There are four Vietnam volumes alone that should be published in 2010.”

“We anticipate being able to fill all [employment] vacancies in 2010, many of them rather early in the year,” Dr. McAllister wrote in an email message. “The Office of the Historian is … well on its way to resolving the multiple infrastructure, document handling, and archival access issues that impact FRUS production…. The Office of the Historian has launched several initiatives to address systemic impediments that slow the declassification process.”  And over time, “we anticipate returning to a more typical production cycle.”  But a typical production cycle has never yet meant regular compliance with the mandatory 30 year FRUS publication requirement.

The latest FRUS volume on “Global Issues, 1973-1976” has a number of interesting features and a few peculiarities. Oddly, all of the documents were marked as declassified in December 2008, so this collection was apparently ready for publication online a year ago.  And unlike other contemporaneous FRUS volumes, audio tapes are not listed as a source and were apparently not used in the collection.  No explanation for this omission was offered.

Among the noteworthy records in the collection is a 1976 intelligence assessment (pdf) of the likelihood of terrorist acquisition of nuclear weapons, which is deemed “unlikely” in the following year or two.  In most respects, the assessment is no longer current or relevant, but it still includes some remarkable observations.  Thus, it notes that “The locations of most U.S. [nuclear weapons] storage sites abroad are locally known and could be ascertained by any terrorist group with a moderately good intelligence potential.  Detailed intelligence about the site could be fairly readily acquired in many cases….”  Despite this apparent fact, which is even more likely to be true today, the Department of Defense still insists that such information is classified.  By doing so, it disrupts routine declassification activities, forcing reviewers to search for and remove non-sensitive but technically classified information.

See “The Likelihood of the Acquisition of Nuclear Weapons by Foreign Terrorist Groups for Use Against the United States,” United States Intelligence Board, Interagency Intelligence Memorandum, 8 January 1976.

Another 1976 document on Naming the Space Shuttle sought President Ford’s approval of a request from hundreds of thousands of “Star Trek” fans that the first NASA space shuttle be named “Enterprise.”  Most of the White House staff, including Brent Scowcroft and others, concurred.  But presidential counselor Robert T. Hartmann contended that Enterprise is “an especially hallowed Naval name… I think the Navy should keep it.”  Presidential counselor John O. Marsh approved the choice of the name, but said he was “not enthusiastic about the [Star Trek] rationale for the selection,” which he disdained as “appealing to a TV fad.”  President Ford initialed his approval of the proposal.

As it turns out, it seems that the Star Trek “fad” is going to outlast the space shuttle itself.

FBI Linguist Leaked Classified Docs to Blogger

An Israeli-American attorney who worked for the FBI as a translator pled guilty yesterday to unlawfully disclosing five classified FBI documents to an unidentified blogger last April, who then published information from the documents on his blog, the Justice Department announced.

In a signed plea agreement, Shamai Leibowitz stipulated that he had “knowingly and willfully caused five documents, which were classified at the Secret level and contained classified information concerning the communication intelligence activities of the United States, to be communicated… to a person not entitled to receive classified information (‘Recipient A’).  Recipient A was the host of a public web log (‘blog’) available to anyone with access to the Internet.”

“Recipient A then published on the blog information derived from the classified documents provided to Recipient A by Leibowitz.  As a result of these disclosures, intelligence sources and methods related to these documents were compromised,” the plea agreement said.

Recipient A was not named, and has evidently not been charged with any misconduct.  Leibowitz was charged under 18 U.S.C. 798, which prohibits unauthorized disclosure of communications intelligence information.

“The willful disclosure of classified information to those not entitled to receive it is a serious crime,” said David Kris, Assistant Attorney General for National Security. “Today’s guilty plea should serve as a warning to anyone in government who would consider compromising our nation’s secrets.”

Prosecutors credited Mr. Leibowitz for his “apparent prompt recognition and affirmative acceptance of personal responsibility for his criminal conduct” as well as his “timely notification of his intention to plead guilty.” Based on those and other factors, they proposed a sentence of 20 months imprisonment.

Though it has no bearing on the case, Mr. Leibowitz happens to be the grandson of Yeshayahu Leibowitz (1903-1994), a renowned Israeli scientist, orthodox Jewish philosopher, polemicist and political activist.

The case was first reported in “Israeli lawyer & peacenik guilty of leaking FBI secrets” by Josh Gerstein in Politico, December 17.  Laura Rozen, also writing in Politico, provided additional background and proposed speculatively that Leibowitz’s disclosures were behind an April 16, 2009 story in the New York Times on NSA’s “overcollection” of domestic intelligence.

TSA Cannot Order Sites to Take Down Sensitive Manual

After a Transportation Security Administration (TSA) manual containing “sensitive security information” was inadvertently disclosed on a government website, it was reposted on several non-governmental websites where it remains freely available.  Asked what TSA intends to do about that, Acting TSA Administrator Gale D. Rossides told Congress that her agency does not have the legal authority to compel members of the public to remove sensitive TSA documents from their websites, though she wished that they would do so.

“Do the current regulations provide you a mechanism to keep individuals from reposting this information on other web sites?” asked Rep. Charles W. Dent (R-PA), at a December 16 hearing of the House Homeland Security Subcommittee on Transportation Security.

“No, sir, they do not,” Ms. Rossides replied.  “We do not have any authority to ask non-government or non-DHS sites to take it down.”

“What action does TSA intend to take against those who are reposting this sensitive document that should not be in the public domain?” Rep. Dent persisted.

“Well, right now, there really isn’t any authoritative action we can take,” Ms. Rossides said.  “Honestly, persons that have posted it, I would, you know, hope that out of their patriotic sense of duty to, you know, their fellow countrymen, they would take it down.  But honestly, I have no authority to direct them and order them to take it down.”

But Rep. Dent expressed his own indignation at the web sites that ignored the official control markings on the TSA manual.  “To those who reposted this security information on the internet, you should share in the blame should security be breached as a result of this disclosure,” he said.

But the urgency of the need to restrict continued access to the leaked TSA manual seemed diminished by Ms. Rossides’ declared view that aviation security has not “been compromised or weakened because of this incident.”  Furthermore, she said, that manual was now obsolete because “very significant changes” have been made to airline security policy since the manual was issued.

Ms. Rossides added that in order to prevent further inadvertent disclosures of the newest security measures, she was refusing to provide a hardcopy of the latest edition of the TSA security manual to Congress.  “I just wanted to take the absolute measures to protect that information, and that’s why a hardcopy wouldn’t be presented,” she said.

Rep. Dent objected to this.  “By refusing to give a document to this committee because of concern about a public disclosure, that’s implying that this subcommittee would disclose the document.  And that’s what, I guess, troubles me the most.” He said he would press the issue.

Subcommittee chair Rep. Sheila Jackson-Lee (D-TX) said she would introduce legislation to bar contractors from access to “sensitive security information,” since contractors apparently were at fault in the inadvertent disclosure of the security manual.  “It’ll be my legislative initiative to insist that contract employees not be used to handle sensitive security information, period,” she said.

Rep. James Himes (D-CT) asked whether TSA was examining who had downloaded the security manual.

“I believe that is part of what [the TSA Inspector General] is looking at,” Ms. Rossides said.  “We do know — our CIO shop has done an initial review of who did download it and has it on their website — non-government, non-DHS websites.  We do know that.”

OSC Views Taliban Propaganda Video

A Taliban video distributed last month documented the purported seizure of an abandoned U.S. military base by Taliban forces in a remote province of Afghanistan.  The 7-minute video was analyzed in a recent report (pdf) from the DNI Open Source Center.

The video “glorifies the Taliban victory by highlighting the group’s triumphant entry into the ‘captured base,’ the symbolic burning of an American flag, and the [local Taliban governor] touring the area.”  A copy of the Taliban video (.wmv) and the OSC report, obtained by Secrecy News, may be found here.

The OSC report was discussed by Bill Gertz of the Washington Times in his Inside the Ring column today (the second item).  Other aspects of the video were previously reported in Wired’s Danger Room and Al-Jazeera.

Response to Critiques Against Fordow Analysis

Our article “A Technical Evaluation of the Fordow Fuel Enrichment Plant” published in the Bulletin of the Atomic Scientists on November 23 and its technical appendix, an Issue Brief, “Calculating the Capacity of Fordow”, published on the FAS website, have sparked quite a discussion among the small community that follows the technical details of Iran’s program, most prominently by Joshua Pollack and friends on and by David Albright and Paul Brannan at ISIS, who have dedicated two online reports (from November 30 and December 4) to critiquing our work.
Before addressing the arguments and exposing the fallacies in ISIS’s critique directly, we strongly encourage interested parties to read our Issue Brief, in which we have presented our reasoning, calculations, and assumptions in a clear and straight-forward way that we believe anyone with some arithmetic skills and a pocket calculator can follow and reproduce. We published a quick first version of our Issue Brief on 1 December. The 4 December ISIS rebuttal was based on the first Issue Brief. We published an expanded version of the Issue Brief on 7 December.  The second version adds to the first version, but everything in the first brief is also in the second version.  The second version includes additional examples and further details on how we carried out our calculations (as well as cleaning up some formatting, for example, all the tables in the first version were in different formats, the revision at least looks much prettier).  References to equations and page numbers below pertain to the second revision.
In our Bulletin piece, we concluded that Fordow is ill-suited for either a commercial or military program and we speculated that it would make most sense if it were one of several facilities planned. The latter conclusion has been de facto supported by Iran’s recent declaration of 10 additional planned enrichment sites. Although ISIS explicitly states that our assessment of Fordow is unrealistic, the authors are not clear what their broader argument is. They seem to imply that Fordow alone is sufficient for a viable breakout option, which in the context of our Bulletin article would make Iranian intentions clear-cut but would, however, undermine the need for additional facilities.
Albright and Brannan state that we “appear to assume” that Fordow would perform worse than Natanz.  Quite the contrary, we state clearly in our Issue Brief that “We use well- documented, publicly available data from official IAEA reports and one assertion: The best estimate of the near term capacity of the Fordow facility is the most recent capacity of the Nantanz facility, scaled by size.”    In the December 4 ISIS report, this statement is corrected to say we “significantly underestimate the performance of the Natanz facility.”  The basis of their argument is that our calculation of the effective IR-1’s separative capacity of about 0.44 kg-SWU/yr, lower by a factor of three, four, or more than previously published estimates (see Table 1 of the Issue Brief), is not characteristic of and seriously underestimates Iran’s capabilities.  We argue that previous speculations on the separative capacity of the IR-1 simply cannot explain IAEA data on the actual performance of IR-1 cascades at Natanz, which we consider to be the only credible open-source information available.
Argument #1:  Adopting Ad Hoc Values
Expert guesses on the IR-1 separative capacity vary greatly, as illustrated in Table 1 of our Brief.  For example, since 2006 Albright continuously sites values in the 2 to 3 kg-SWU/yr range, which are either not referenced or are attributed to untraceable sources (e.g. “senior IAEA officials”, “former Urenco official”). The lowest value that Albright has cited was in a footnote on his prepared statement for the Foreign Relations Committee in 2006, which is 1.4 kg-SWU/yr, based on calculations of a 164-machine cascade described in an Iranian official’s interview (this number is consistent with Garwin’s estimate using the same data).  Albright characterizes the 1.4 value as “relatively low output” and this number is never used in breakout scenario estimates.  In the same footnote, he calculates a higher capacity of 2.3 kg SWU/yr based on Aqazadeh’s ballpark figures on the performance of the total planned 48,000 centrifuges.  Since then, the most recent and most widely referenced value for the separative power of an IR-1 that ISIS uses in breakout assessments is 2 kg-SWU/yr.  When given the choice between a higher value attributed to unnamed sources and values he calculates himself, Albright consistently chooses the higher values. This is especially misleading when dealing with weapon production scenarios, which evaluate what Iran can currently achieve.
However, in their critique of our Bulletin article, Albright and Brannan adopt significantly lower values for the separative power: 0.6-0.7 kg SWU/yr (which they say is “undoubtedly too low”) and 1.0-1.5 kg-SWU/yr (which they say is “reasonable for new IR-1 centrifuge cascades”).  They do not explain their reasoning for the latter value, except that the upper boundary is close to “Iran’s stated goal.”  Perhaps, the authors are referring to Albright’s 2006 estimate based on the Aqazadeh statement, but now pick the lower value of 1.4 kg-SWU/yr that Albright had calculated but dismissed.  Although Albright and Brannan do not reveal the data or go through the calculations for their former value, they do allude to their method, which we will discuss below.
The authors arrive at the 0.6-0.7 kg-SWU/yr based on “the average output over nine months in 2009.”  We believe that even this “undoubtedly too low” value has been miscalculated. There are two major sources of difference with the FAS 0.44 kg-SWU/yr value: (1) ISIS uses Iranian logbook data, which does not account for the hold up of material while FAS uses independently calibrated data in the IAEA reports, (2) ISIS does not account for the change in the number of machines in the 9 month period cited (we believe ISIS was referring to 31 January to 30 October 2009).  On the other hand, FAS uses the values of independently recorded data (unfortunately, you have to look for them in the footnotes of the IAEA reports) and accounts for the holdup as described in our Issue Brief.  In addition, we look at data since the last IAEA physical inventory in 2008, from 18 November 2008 to 30 October 2009 (the entire period for which calibrated date is available).
Iranian logbook data have been shown to slightly underestimate the amount of feed and more significantly overestimate the product.  Essentially, Iran is putting more uranium in their machines and less enriched product is coming out than their material accounting algorithm shows, which effectively means that separative power calculated with Iranian logbook data is expected to overestimate the actual effective separative power per machine. This is why indendently calibrated data, if IAEA physical inventory data is not available, provides a more realistic estimate.
Albright and Brannan take an average of enriched product as reported by Iranian logbook estimates from February to October 2009 (an overestimated value), then they simply divide by the number of months to obtain a monthly average, also ignoring the fact that the number of machines varies from month to month. ISIS does not consider the amount of feed that has been reported to enter the cascades under the same set of data, but simply adopt 0.4 percent as the concentration of the waste stream. Although that number is indeed present in a footnote in IAEA reports (GOV/2009/35), it is not the overall concentration of the waste, but shows that particles of depleted uranium “down to 0.4% U-235 enrichment” have been measured. The difference between the ISIS lowest estimate and the FAS estimate is not as significant as the fact that Albright and Brannan dismiss the effective capacity of the IR-1 altogether.
Argument #2: Iran operates fewer machines when the IAEA is not looking
The number of centrifuges in the period is not only a difference between ISIS and FAS’s calculations but is also Albright and Brannan’s basis for dismissal of a smaller number altogether.  The “number of centrifuges used in the derivation is from IAEA safeguards reports and exceeds the quantity of those centrifuges that are actually enriching.”  In personal communication with Scott Kemp (as posted on Pollack’s blog), Albright has also speculated that cascades are not being operated continuously.  This makes little sense.  Do the Iranians wait until inspectors arrive to turn on their machines?  (If this is so, then our problem with Iranian enrichment can be solved quite easily:  just stop inspections and Iran will stop enriching altogether.)  Additional reasons given in a recent Albright and Shire analysis published in Arms Control Today include: Iran is keeping cascades in reserve in case of cascade failures or if it decides to “produce higher enriched uranium” or Iranian experts are focusing on getting Fordow running. All of these arguments seem weak. In the November 30 report, ISIS make yet another conjecture –“a significant fraction of these 4,000 machines are likely also not enriching or are broken.”  As far as we can tell, the ultimate basis for this claim is that otherwise ISIS’ higher per machine capacity does not make sense. However, we discuss the one bit of numerical evidence Albright and Brannan provide for their speculations below.
Based on IAEA reports, changes in the number of machines from 7 November 2008 to 2 November 2009 increases by only 10 percent or so; thus, even if we assume the minimum number of machines for each reporting period, instead of taking averages, the SWUs per machine will increase from 0.44 to 0.47, which of course, has a negligible effect on breakout scenarios.  For the ISIS argument to become important, we have to believe that half or more of the machines reported by the IAEA to be operational in fact are not.
Moreover, remember that the basis of our argument is that recent performance at Natanz is the best predictor of near-term performance at Fordow.  ISIS not only rejects our calculation of Natanz performance but rejects our assertion about it being the best predictor of Fordow.  The implication of the ISIS critique is that, while there might be severe problems at Natanz, these will not be repeated at Fordow.  This may or may not be true.  Perhaps the centrifuges at Natanz perform poorly and are very unreliable and Iran has figured out all those problems and will only install 2.0 kg-SWU machines at Fordow (although we have no hard evidence that IR-1s of that capacity exist).  Alternatively, perhaps there are systematic problems with centrifuge production and cascade operation and this is the best the Iranians can do in the near-term.  Our assertion hinges on Iranian improvements being incremental and evolutionary and on not seeing dramatic, revolutionary improvements at Fordow.  If this is not true, then our assertion for Fordow is wrong, but our estimates of Natanz’s capacity would still be correct.
The ISIS paper presents an additional argument to show that per machine capacity was increasing:  daily average enrichment stayed constant at 2.75 kg of low enriched UF6, while the number of centrifuges dropped from 4920 to 3936.  (There is the problem that we will set aside for the moment:  Either the IAEA data are suspect or they are not, but one should not dismiss them in one case and base arguments on them in another.)  We are back to estimating average number of machines per given period. We have three data points: 31 May – 4920 machines operating, 12 August – 4592, and 2 November – 3936.  We agree with ISIS here: From 31 May to 12 August the average daily enrichment is about 2.8 kg UF6 (according to Iranian logbook data, not calibrated measurements) and similarly about 2.8 kg UF6 from August to November.
However, there are several problems with this argument.  First and foremost, it depends on Iranian logbook data, which has been demonstrated to be inaccurate (plus, of course, IAEA inspection data that ISIS tells us is unreliable).  Taking averages for the number of machines operating in each period and a concentration for the product of 3.49% (as the 2008 PIV), we get a slight decrease from 0.51 kg-SWU/yr (18 November 2008 to 31 May 2009) to 0.46 kg-SWU/yr (31 May to 31 July), followed by a jump to 1.0 kg SWU/yr per machine (31 July to 30 October), that is, a sudden doubling, according to Iranian logbook data. However, if we look at the independently calibrated measurements, the increase is only from 0.43 (18 November 2008 to 2 August 2009) to 0.49 kg SWU/yr (2 August to 30 October 2009).  Also, note a negative holdup for August-November 2009; this could mean that the Iranians have started feeding the leaked material back into the cascades and are salvaging some of the lost separative work.  Interestingly, if you look at the feed data, the feed went up slightly (from 30.4 kg UF6 per day to 31.05 kg UF6 per day, based on Iranian logbooks) as the number of machines went down, suggesting that the limiting factor is the amount of feed material.  Finally, we do not know the enrichment concentrations definitively for those short periods.  For example, a shift in enrichment from 3.5% to just 3.8 % would, by itself, account for all of the difference in separative work. Therefore, the ISIS numerical example is not indicative an increased per machine capacity.
We believe the lesson here is that short term logbook data are not reliable.  Over time, an overestimate during one period will balance an underestimate in another and we will get closer to actual values but on short time scales we need to be wary of Iranian self-reporting.  We concede, whenever we are given the choice, we rely on measurements conducted by IAEA on-site inspectors rather than Iranian logbook entries.
Argument #3: Misrepresenting the FAS Calculation
Albright and Brannan have succinctly expressed the basis of their critique: “We were unable to understand the problems in the FAS calculation.”  On this point, we agree wholeheartedly.
Here is their argument according to the second paragraph of their 4 December posting: (1) They use our separative work number of 0.44 kg-SWU/yr to calculate what we would predict to be the output of Natanz;  (2) This number turns out to be about half of what Natanz is actually producing; (3) QED, our separative work number must be wrong.
But part of their input data is that “[t]he authors also assert that the tails assay at Fordow should be 0.25 percent” when we never say any such thing (we do show example calculations using low, that is to say, global industry standard, tails assay).  In fact, we calculate the tails assay at Natanz as 0.46%.  Indeed, in the very next paragraph, they say that “FAS appears to have forced a U-235 mass balance by adjusting the tails assay in Table 2 in their assessment to 0.46 percent as a way to get the masses to match.  But the situation at Natanz is quite complex.”  On this point, we admit we are guilty as charged.  When they say we “forced” the tails assay, what they mean is that we used the mass balance equation.  And if the laws of conservation of mass do not apply in Natanz, then we concede that the situation there is quite complex indeed.  (And, moreover, no calculation that anyone could make would be useful even in theory.)
Albright and Brannan are more specific:  “For example, calculating the mass balance on the uranium 235 (uranium 235 in the feed should equal the uranium 235 in the product and tails) is not possible based on the available information.  This requires assigning values in a formula that are impossible to substantiate.”  Going to equation 5 on p. 8 of the Issue Brief and following the references, the reader can see that all of the values on the right hand side of the equation appear in IAEA reports.  (And presumably as an alternative to “assigning values in a formula that are impossible to substantiate,” we would do better to accept values credited to “senior IAEA officials.”) If one uses our actual tails assay rather than the incorrectly asserted tails assay and the proper number of centrifuges and the difference between Iranian logbook data and actual IAEA measurements, all of the differences disappear.  (As they have to, since we calculated the 0.44 kg-SWU/yr value in the first place based on these same numbers.)
In the end, an important scientific principle has been demonstrated here:  if one takes several variables from one of our examples and several more variables from a separate example and combines them randomly, nonsense results.
Argument #4: ISIS Is Right Because the White House Says So
The most compelling support for the ISIS estimate that “using 3,000 IR-1 centrifuges, and starting with natural uranium, Iran could produce enough weapons-grade uranium for one bomb in roughly one year” that the authors give is that it is similar to the White House September 25 briefing statement that Fordow is capable of producing HEU for one to two bombs a year.  First, this is a classic example of argumentum ad verecundiam – we are not about to accept White House numbers without checking their math.  Moreover, it must be clarified that the US government’s statement is fairly vague and does not give details on this assumed breakout scenario (whether HEU is enriched from LEU or natural uranium and whether a crude or sophisticated weapon is assumed).  What the government said was:
“[..] if you want to use the facility in order to produce a small amount of weapons-grade uranium, enough for a bomb or two a year, it’s the right size.  And our information is that the Iranians began this facility with the intent that it be secret, and therefore giving them an option of producing weapons-grade uranium without the international community knowing about it.”
Let’s focus on paragraphs 6 and 7 from the November 30 ISIS report. In paragraph 8, the authors state that the White House scenario is unlikely to assume a breakout scenario using low-enriched uranium, since such a diversion would be likely discovered because LEU would have to be sneaked out of Natanz, which is under IAEA safeguards. They interpret the White House statement that weapons grade uranium would be enriched “without the international community knowing” means that this scenario would necessarily involve enrichment of natural uranium to HEU levels. But it must be noted that such a scenario would require a secret conversion facility as well, since the conversion plant at Esfahan is also under safeguards.
In paragraph 7, Albright and Brannan critique our assessment for “appearing to assume” that breakout scenarios considered depend on “activities not being discovered”, in apparent contradiction to their assumption in paragraph 6, that emphasized the importance of the clandestine function of Fordow.  ISIS further argue that if Iran was “breaking out,” Fordow would likely sustain military attack better than Natanz.  Our Bulletin argument was this: if Iran’s HEU production was likely to be discovered (such as if a diversion from Natanz were detected), speed is of the essence. They may be better off kicking out inspectors and going full-speed ahead at a facility such as Natanz with a large capacity, rather than proceeding with an option would take a year or more at Fordow.  If Fordow’s capacity was significantly increased or if there were other similar facilities, this judgment may change.
As we have shown ISIS’ critiques of our Bulletin analysis and its underlying technical assessment are completely unsubstantiated. First, their track record of using higher vaguely referenced values and dismissing values based on physical data and their own calculations, just because they are inconsistent with their previous assessments, is troubling. Second, they greatly misportray FAS’ technical argument, which is clearly described in our Issue Brief. Third, Albright and Brannan seem to pick and chose assumptions to suit their argument at hand: on one hand they assert that IAEA data do not provide a good account of what is going on at Natanz to advance one point, but at the same time site these data to support other points.
Overall, it is hard to see the bigger argument that ISIS is making by attacking our premise regarding Natanz’s capacity (and consequently Fordow’s), but not specifically our conclusions on Iranian intentions vis-à-vis Fordow. It seems Albright and Brannan are interested only in defending their use of a higher separative capacity by attempting to undermine our argument. They do not discuss how our Bulletin conclusions would change if their shorter time estimates were correct, but simply dismiss our analysis altogether.
Ultimately, the reason we engage in discussions over these numbers is because we believe that overestimating Iran’s enrichment potential will provide us with a skewed perception of Tehran’s intent and strategic planning. It is indeed important to be able to make a realistic assessment of Iran’s current capacity and future potential. However, this is best done using neither Poisson statistics nor arguments of authority, but a good look at readily available hard data.

by Ivanka Barzashka and Ivan Oelrich

Our article “A Technical Evaluation of the Fordow Fuel Enrichment Plant” published in the Bulletin of the Atomic Scientists on November 23 and its technical appendix, an Issue Brief, “Calculating the Capacity of Fordow”, published on the FAS website, have sparked quite a discussion among the small community that follows the technical details of Iran’s program, most prominently by Joshua Pollack and friends on (on December 1 and December 6) and by David Albright and Paul Brannan at ISIS, who have dedicated two online reports (from November 30 and December 4) to critiquing our work. Continue reading

New Framework Proposed for “Sensitive” Govt Info

The government should replace the more than 100 different control markings that are now used to limit the distribution of sensitive but unclassified (SBU) information and should establish a single “controlled unclassified information” (CUI) policy for all such information in government, according to an interagency task force report (pdf) that was released by the Obama Administration today.

“The Task Force concluded that Executive Branch performance suffers immensely from interagency inconsistency in SBU policies, frequent uncertainty in interagency settings as to exactly what policies apply to given SBU information, and the inconsistent application of similar policies across agencies,” the report said.  “Additionally, the absence of effective training, oversight, and accountability at many agencies results in a tendency to over-protect information, greatly diminishing government transparency.”

The Task Force said that their proposal for a single “controlled unclassified information” (CUI) regime would not only facilitate information sharing among federal, state and local government agencies, it would also increase transparency and enhance public access to government information.

“Because of its uniformity, standardized training requirements, and the public availability of the registry [indicating what categories of information are controlled], the expanded scope of the CUI Framework can be expected to significantly increase the openness and transparency of government….”

Not only that, “It is foreseeable, based on the revised definition and scope of CUI recommended herein, that some information currently treated as ‘sensitive’ may be found not to warrant CUI designation.”

The Task Force presented 40 recommendations to the President on implementing the proposed CUI policy that could serve as the basis for an executive order on the subject.  It builds upon, and would expand the scope of, the CUI Framework that was established in a May 2008 memorandum issued by President Bush, which dealt with the control and sharing of terrorism-related information.  See the Report and Recommendations of the Presidential Task Force on Controlled Unclassified Information, transmitted August 25, 2009 and released December 15, 2009.

The Task Force proposal is an admirable effort to bring order to a chaotic information environment.  But it has some rough edges, and some unresolved internal contradictions.

The proposed definition of CUI seems disturbingly lax:  “All unclassified information for which, pursuant to statute, regulation, or departmental or agency policy, there is a compelling requirement for safeguarding and/or dissemination controls” (p.11).  Putting “departmental or agency policy” on a par with statutes or regulations could potentially open the door to all kinds of arbitrary or improvised controls on information.

More fundamentally, it is hard to see how the Task Force proposal could achieve its central goal of eliminating all non-CUI controls on unclassified information.  The Task Force report itself states (in Recommendation 20) that “decontrol of CUI” does not by itself authorize public disclosure; it only means removal from the CUI Framework.  But if information that has been removed from the CUI Framework does not necessarily have to be disclosed, this means that decontrolled information can still be controlled!

The report properly takes pains to distinguish information control under the CUI regime from the statutory disclosure requirements of the Freedom of Information Act, which cannot be altered by executive fiat.  “At no time, pre- or post-control, is a CUI marking itself determinative of whether it may be released,” the report stated (p. 21).  But this implies, oddly, that information marked as CUI may sometimes be released, while information that is no longer CUI may sometimes be withheld.  And if it is withheld, one must also expect it to be marked with a (non-CUI) control marking.

In short, the CUI concept still has some wrinkles that remain to be ironed out.

The Task Force recommended a ten-year life cycle for CUI that is not otherwise subject to defined disclosure deadlines.  It recommended a baseline assessment of the volume of current SBU activity, but this is probably unachievable or at least not worth the effort involved.  Staffing and resources for the “Executive Agent” that manages the whole enterprise are uncertain, but are likely to be crucial or even decisive in the success of the proposed policy.  An appendix to the Task Force report listed 117 different markings currently in use to protect SBU information (described as “a partial listing”).

The Task Force proposal is “a good foundation,” said one senior Administration official.  But before the subject is addressed in an executive order, the final policy “needs to be more forward-leaning,” he said.

Meanwhile, the Department of Defense, the intelligence agencies, and the Department of Homeland Security have already indicated that they plan to use the CUI Framework for all of their sensitive unclassified information, another official said.