30 July 1997
Mr. Samuel R. Berger
The White House
Washington, DC 20500
The Security Policy Advisory Board was chartered by Presidential Decision Directive 29 of 16 September 1994. The Board provides a non-government, public interest perspective on actions required to streamline and improve Federal security policies and procedures.
Our frame of reference is the report of the Joint Security Commission (JSC), "Redefining Security," dated February 28, 1994. Part of our charter is to provide to the President, through the National Security Advisor, an annual report of our findings on implementing recommendations contained in the JSC report. Our emphasis is on the four key principles enumerated in PDD 29 that Security Policy (1) match the threat; (2) be consistent and enable us to allocate scarce resources efficiently; (3) result in fair and equitable treatment; and (4) provide the security we need at a price we can afford.
In the course of our first year of activity, we focused on personnel security issues, which (as the Joint Security Commission pointed out) make up the centerpiece of the Federal security system.
We held a series of four public meetings over the last year to discuss specific security issues and to solicit input from the public at large, and industry in particular. To encourage public participation, our meetings were advertised in the Federal Register and held in locations where there is a significant concentration of government contractors.
Additionally, we have monitored the activities of the Security Policy Board, the Security Policy Forum subset of that Board, and the attendant staff.
We have keyed our resulting observations and recommendations to specific observations and recommendations of the JSC report.
We are persuaded of the overall wisdom, viability, and necessity of many of the Joint Security Commission recommendations. There is important progress in achieving common investigative standards, reciprocal recognition of investigations, and common adjudicative standards. Further, we believe that the Security Policy Board concept is viable and that the Board members and staff are dedicated to improving security processes.
We find, however, that progress in several key areas has been slow and the personnel security process is still unduly arbitrary, bureaucratic, and cumbersome. In the course of our public meetings, we have found a consistent theme of frustration with the process, the delays and expense it imposes on industry (and thus on government programs), and the apparently unnecessary burdens it imposes on individuals and their employers. The end of the cold war and the introduction of some of the recommendations of the JSC do no appear to have greatly eased the burden on the public. Instead, in some ways the process is more intrusive than ever.
Of equal importance, the personnel security process can and should be far more efficient and cost-effective. We believe that priority attention to several areas could, in a fairly short period, provide not only significant cost savings, but also an improved, more responsive security system.
Specific Comments and Recommendations (keyed to JSC comments and Recommendations)
In our opinion, the following are five areas that, if given added priority attention, could produce rapid improvement and increased efficiency in the Federal Security process:
1. Strengthen common standards and reciprocity, both in investigations and adjudication.
JSC Report: "Our goal is to establish a security clearance standard, the application of which will be tracked in a Community-wide data base and will be fully transferable and valid among all government agencies."
2. Give priority to creating a central data base where investigatory history and clearance status can be readily accessed.
JSC Report: "The Commission recommends that a central Clearance Verification data base be developed and made available to industry and government. The data base should contain all collateral and SCI clearances. Sensitive clearance information should be encrypted or otherwise protected within the data base."
3. Force efficiencies upon the demand for investigations.
JSC Report: "The Commission recommends that security clearances be requested only for personnel who require actual access to classified information or technology. For most of those who merely require facilities access, a position suitability determination based on the results of a National Agency Check with Inquiries (NACI) should be the maximum allowed."
"The Commission recommends that fee-for-service mechanisms be instituted to fund clearance requests within DOD and the Intelligence Community."
4. Establish standards for access to compartmented programs.
JSC Report: "The Commission recommends that: a) a single, consolidated policy and set of security standards be established for Secret Compartmented Access information, including all current SAPs, SCI, covert action, and the various bigot list programs; b) Standards contain some flexibility, but waivers down from compartmented access security measures be permitted only when there is no impact on reciprocity."
JSC Report: "The Commission recommends the establishment of a national level Security Policy Committee to provide structure and coherence to US Government security policy, practices, and procedures.... As a first step, the Commission recommends that the Secretary of Defense and the Director of Central Intelligence immediately establish a committee to fulfill these functions for the Defense and Intelligence communities."
Larry D. Welch
President's Security Policy Advisory Board