December 13, 2007

 

Re. Opposition to the FISA Amendments Act reported by the Senate Select Committee on Intelligence.

 

Dear Senator,

 

We, the undersigned organizations who care deeply about both civil liberties and effective intelligence-gathering, strongly urge you to oppose the FISA Amendments Act of 2007 as reported out by the Senate Select Committee on Intelligence (S. 2248).   The Intelligence Committee bill unreasonably and unnecessarily authorizes broad surveillance of Americans’ international communications without meaningful Fourth Amendment protections:  no individualized warrant issued by a court, no determination of probable cause of wrongdoing, and no specification of the location or means of the surveillance.   

 

The Judiciary Committee approach, in contrast, provides some crucial protections for Americans’ international communications that are sorely lacking in the Intelligence Committee’s bill.  We urge you to support the Judiciary Committee changes as well as other improvements that are also needed to protect Americans’ privacy and constitutional rights. 

 

Below are some of the most important reasons to oppose the Intelligence Committee’s bill and support the Judiciary Committee’s mitigation of some of its failings, as well as additional protections.  

 

*  “Bulk Collection.”  The Intelligence Committee bill fails to include provisions that would clearly prevent the bulk collection of international communications, which would inevitably sweep in millions of communications by Americans so long as one party to a phone call or e-mail is believed to be located abroad and the purpose is to gather foreign intelligence.  The Judiciary Committee approach would affirmatively prevent such bulk collection.   Rather than permitting broad streams of Americans' communications to be seized, the Judiciary Committee approach requires that the surveillance target a particular individual or phone number abroad, although that person abroad could be virtually anyone. The administration has assured the Congress that it does not engage in such bulk collection of international communications and that doing so is not necessary for national security.   

 

*  No Individualized Warrant Even When Government is Interested in American’s Communications.  The Intelligence Committee bill allows the government to intentionally and knowingly acquire millions of Americans’ international communications with no individualized warrant or determination of probable cause.  Such protections are required only if and when the government decides to “target” a particular American, meaning use their phone number or e-mail address to select their communications for acquisition. 

 

While the Judiciary Committee approach does not restore the protections that existed in FISA before the enactment of the Protect America Act, it improves the bill by requiring that individualized review by the FISA court is sought once acquiring the communications of a person in the United States becomes a “significant purpose” of the surveillance. 

 

* Government Accountability.  The Intelligence Committee bill does not include a key provision necessary for Congress to fulfill its responsibility to investigate and oversee the activities of the intelligence agencies that threaten the civil liberties of Americans.  The Intelligence Committee bill omits a one-time retroactive audit of all illegal NSA surveillance conducted prior to January 2007.  That provision is contained in the Judiciary bill.  It is essential to ensure that key documents are preserved, that there is accountability for illegal activities, and that Congress only legislate on key privacy protections in the FISA with full knowledge and public debate on what changes are warranted.   

 

*  Sunset.  The Intelligence Committee bill would authorize the government to conduct this massive surveillance for six years.  The Judiciary Committee approach would more prudently shorten the period to four years, which is still too long in our view.    

 

* Exclusivity.  The Judiciary amendment reiterates that FISA is the exclusive means for foreign intelligence wiretapping of Americans on American soil, and will prevent any future argument that a subsequent statute like the 2001 Authorization to Use Military Force implicitly amended FISA intended to allow warrantless wiretapping of Americans.  It does this by tightening FISA’s exclusivity language both directly and by maintaining FISA’s long-standing definition of “electronic surveillance.”  The Intelligence Committee bill eviscerates that definition.

 

*  Retroactive Immunity for Wrongdoing.  The Judiciary version of S. 2248 does not grant blanket immunity to the telecommunication companies that facilitated the President's warrantless wiretapping program in violation of the clear terms of the statute.  It leaves that major policy decision for later, and allows Congress to thoroughly vet all the options before it acts, if it chooses to act at all.  The Intelligence Committee version would give blanket immunity from the statutory damages FISA has long permitted for companies that aid in warrantless electronic surveillance of Americans. 

 

The Protect America Act granted unnecessary and unconstitutional powers to the Executive Branch.  The Intelligence Committee bill does little to rectify this.  We ask that you vote now to rein in that unwise expansion of power by opposing the Intelligence Committee bill and supporting the improvements made by the Senate Judiciary as well as additional amendments needed to protect the rights of Americans. 

 

Thank you for considering our views.

 

American-Arab Anti-Discrimination Committee

American Civil Liberties Union

American Library Association

Association of Research Libraries

Bill of Rights Defense Committee

Bill of Rights Defense Foundation

Center for American Progress Action Fund

Center for Democracy and Technology

Center for National Security Studies

Council on American-Islamic Relations

Defending Dissent Foundation

Electronic Frontier Foundation

Federation of American Scientists

National Association of Criminal Defense Lawyers
OMB Watch

Open Society Policy Center

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