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STEVEN AFTERGOOD                   )
on behalf of the                   )
     Plaintiff,     		   )
v.                                 )		Case No. 1:98CV02107(TFH)
Washington, DC 20505               )
     Defendant.                    )


I, John Pike, hereby declare:

1. I am a project director at the Federation of American Scientists, a national organization devoted to research and advocacy in national security policy. In the course of my professional duties over more than 15 years, I have made a close study of the defense and intelligence budget process. I am conversant with essentially all of the unclassified official and unofficial literature on intelligence community organization, structure and function. Among my other responsibilities, I maintain the FAS Intelligence Resource Program, an on-line library of unclassified information and analysis concerning U.S. intelligence.

2. I am the author of the hypothetical budget for the Central Intelligence Agency that was cited as Exhibit 1 by Director of Central Intelligence George J. Tenet in his April 6 Declaration (para. 26), and attached to Defendant's motion of the same date. I am also the author of comparable budget estimates for the National Security Agency, the National Reconnaissance Office, and other intelligence agencies.

3. These estimates were developed in response to recurring public inquiries as to the magnitude and character of U.S. intelligence spending. Journalists, students of intelligence, and ordinary citizens routinely contact me for such information. For reporters, this is a subject of continuing news interest. Others are drawn by simple curiosity or the mystique of forbidden knowledge. Still others believe that as U.S. citizens they are entitled under the Constitution to a regular statement and account of the expenditure of all public money, including the expenditure of public money for intelligence purposes. I attempt to satisfy such inquiries to the best of my ability, based on unclassified sources of information. To the extent that it fulfills constitutional requirements and facilitates public participation, I believe that disclosure of intelligence budget information strengthens American democracy and thereby enhances national security.

4. It is an error to suppose that official disclosure of the total intelligence budget would imply or could inevitably lead to the disclosure of sensitive details of intelligence spending. Methodologically, that is a practical impossibility.

5. The total intelligence budget is an aggregate of a very large number of agency and program budgets which are for the most part individually very small relative to the total. While this aggregation is apparently useful for the annual intelligence budget cycle, it is arrived at by a process that is not apparent to external observers and that reportedly changes from year to year. For example, the numerous individually small projects that constitute the Tactical Intelligence and Related Activities [TIARA] account are aggregated into various larger programs, but there are changes from year to year as to which projects are included in TIARA, and how they are aggregated.

6. In other words, what we call "the intelligence budget" is a substantially arbitrary construct. It is an artifact of the budgeting process. R. James Woolsey, then Director of Central Intelligence, testified in 1994 that "it is extremely difficult to identify a reliable and stable number than can capture what we spend on intelligence." In particular, he explained, "the Tactical Intelligence and Related Activities (TIARA) component [of the intelligence budget] is neither a separate nor a clearly defined program, but a loose amalgamation of activities that may vary from year to year, depending on how the various military services decide what constitutes tactical intelligence."

7. As a result of this inherent arbitrariness, there is simply no means to independently reproduce the numerous administrative decisions that result in the official intelligence budget total in order to deduce more detailed spending information.

8. Thus, I have found that it is not possible to take the official budget totals as disclosed in 1997 and 1998 and to retrospectively identify in the published budget where all of this spending was located.

9. For similar reasons, a foreign adversary that was engaged in assembling a "mosaic" of many pieces of information about U.S. intelligence so as to deduce further information about a particular intelligence program would not be aided by disclosure of the total intelligence budget appropriation or request. This information is not the missing piece of any puzzle that would assist such an adversary. It would, however, materially assist the American public in participating in this vital arena of national security policy.

10. In summary, disclosing the total intelligence request or appropriation would not reveal meaningful new information about the budgets of individual agencies, let alone more detailed information.

I hereby certify under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief.

Executed this 17th day of May 1999.

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