STEVEN AFTERGOOD                   )
     Plaintiff,     		   )
                                   )	Case No. 02-1146 (RMU)
v.                                 )
Washington, DC 20505               )
     Defendant.                    )


I, John Pike, hereby declare:

1. I am Director of, a nonprofit national security policy research organization. Prior to founding in 2000, I was a senior staff member and project director at the Federation of American Scientists for 17 years. For over two decades I have studied intelligence spending practices. I am conversant with essentially all of the unclassified official and unofficial literature on intelligence community organization, structure and function. In fact, the relevant literature on the subject often cites my analyses, as did the Director of Central Intelligence in this case.

2. I am the author of the hypothetical budget for the Central Intelligence Agency that was cited as Attachment 1 by Director of Central Intelligence George J. Tenet in his March 19 Declaration (para. 23, note 2) to illustrate "the kind of conclusions, right or wrong, about the intelligence budget that a sophisticated analyst can derive using available information."

3. My hypothetical CIA budget was last updated on September 23, 1996, as indicated at the bottom of the document. (Mr. Aftergood informs me that the bottom of the document, including most of the source notes, was not included by Mr. Tenet in the service copy of his declaration.) In other words, this document was prepared more than a year prior to the official declassification of the Fiscal Year 1997 budget total in 1997 by Mr. Tenet. My analysis obviously did not present any kind of impediment to that declassification, or to the subsequent declassification of the Fiscal Year 1998 budget total in 1998.

4. Having spent years observing intelligence budget practices from the outside, I perceive these matters differently than they are described in Mr. Tenet's declaration.

5. The total intelligence budget is not like a "jigsaw puzzle," as Mr. Tenet would have it. That is to say, it is not a coherent, integrated totality. Rather, it is the sum of three independently generated budget aggregations: the National Foreign Intelligence Program (NFIP), the Joint Military Intelligence Program (JMIP) -- which are themselves composed of numerous sub-programs -- and Tactical Intelligence and Related Activities (TIARA), which is a very loose amalgam of miscellaneous intelligence-related programs. These aggregations are devised by different officials, and are authorized and appropriated in significantly distinct ways. For that reason, they are more like three jigsaw puzzles than one. But they are not even the same three "puzzles" from year to year. In particular, the TIARA designation may or may not encompass the very same military program from one year to the next.

6. As a result, what we call "the intelligence budget total" is an arbitrary construct that cannot be meaningfully correlated with any particular intelligence program or set of programs.

7. It is not possible to "reverse engineer" the budget total in order to derive information about its specific component parts. There is no way to reproduce the numerous administrative decisions that result in the budget total so as to deduce more detailed spending data.

8. Likewise, I have found that it is not possible -- even for a "sophisticated analyst" -- to take the official budget total as disclosed by Director Tenet in 1997 and to retrospectively identify in the published budget where this spending was located. The intelligence budget total does not "map" onto the published budget in any straightforward way. The location of intelligence spending in the published budget remained equally obscure when Director Tenet declassified the 1998 budget total. There is no reason to believe that future disclosures of the budget total would alter this situation.

9. It is entirely plausible that a foreign adversary may be engaged in assembling a "mosaic" of many pieces of information about U.S. intelligence. But such an adversary would not be aided by disclosure of the total intelligence budget appropriation. This single budget figure is not the missing piece of any puzzle that would assist in discovering new information about U.S. intelligence programs. It would, however, assist in informing the American public about the magnitude of expenditures in this vital arena of national security policy.

10. In summary, disclosing the total intelligence budget would not reveal meaningful new information about the content or conduct of U.S. intelligence programs. Nor would it reveal any information about the mechanisms of clandestine funding transfers from the Department of Defense to the CIA.

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

Executed this 22nd day of April 2003.