December 10, 2002

J. William Leonard
Information Security Oversight Office
National Archives and Records Administration
700 Pennsylvania Avenue, NW, Room 500
Washington, DC 20408

Dear Mr. Leonard:

We, the undersigned historians and researchers, are writing to you to propose a change in classification policy.

We turn to you in your capacity as ISOO Director (per EO 12958, section 5.3(b)(6)) and also in view of your role on the NSC Policy Coordination Committee (PCC) on Records Access and Information Security.

The problem we are concerned with is that nuclear weapons storage locations from decades ago -- weapons depots that have long since ceased to be operational -- are still classified as Formerly Restricted Data under the Atomic Energy Act, with no prospect of ever being declassified.

We believe that in most cases this classification policy no longer makes sense, and is in fact counterproductive.

We therefore urge that the classification of historical nuclear weapons storage locations as Formerly Restricted Data be rescinded. Such a change could take a number of more or less expansive forms, including declassifying all historical locations worldwide, or only those that have been deactivated, or only the names of the countries where they are located, or all domestic U.S. sites, etc. We would be happy to comment on the benefits and disadvantages of each of these options with you, if you feel that that would be useful.

Although ISOO does not have jurisdiction over RD/FRD, we believe that this issue will be of interest to you because it directly affects the implementation of the declassification provisions of EO 12958. In particular, obsolete nuclear weapons storage locations comprise a significant fraction of the "inadvertent disclosures" of classified information that continue to be identified by reviewers surveying declassified records at NARA pursuant to the Kyl/Lott amendment.

Eliminating this anachronistic classification category, in whole or in part, would markedly improve the efficiency of the declassification process under EO 12958, and would make more historically valuable records available to the public. (It would also tend to enhance the credibility of the entire classification and declassification system.)

We understand that making this change in classification policy is complicated by the fact that the declassification of FRD requires interagency (DoD and DOE) concurrence.

For this reason, we urge that the PCC on Records Access initiate a review of the matter with a view towards reducing or eliminating the classification of historical nuclear weapons storage locations.