To the U.S. Navy
via online comment to Naval Base Kitsap Bangor
April 25, 2012These comments are submitted on behalf of the Federation of American Scientists, which generally favors robust public disclosure of government information to support sound policy decisions.
We wish to express our concern that Appendices A-C of the Final Environmental Impact Statement (EIS) for the Second Explosives Handling Wharf (EHW-2) at Naval Base Kitsap at Bangor have been withheld in their entirety as DoD UCNI (Unclassified Controlled Nuclear Information). We urge that the decision to withhold this information be reviewed and reconsidered.
The Navy has considerable discretion as to how much information to withhold, but as a rule public disclosure is to be preferred, in accordance with the DoD Directive on DoD UCNI, directive 5210.83, section 4.3 which states:
"It is DoD policy... that Government information shall be made publicly available to the fullest extent possible by applying the minimum restrictions consistent with the requirements of 10 U.S.C. 128 (reference (a)) necessary to protect the health and safety of the public or the common defense and security."
It is also true that explosive safety issues are well within the scope of public knowledge and concern. So, for example, we note that DoD makes its explosive safety criteria and standards publicly available as a matter of course.In light of these factors, we urge the Navy to reconsider its position and to release Appendices A-C of the EIS in whole or in part.
Thank you for your consideration.
Steven Aftergood
Project Director
Federation of American Scientists
1725 DeSales Street NW, Suite 600
Washington, DC 20036email: saftergood@fas.org