Comment on FR Doc # 2011-21337

Please see the attached comment by OMB Watch. The proposed rule runs counter to the spirit of President Obama's Executive Order 13556 on controlled unclassified information and would imperil the usefulness of the entire CUI program currently under development. OMB Watch recommends that DOD withdraw the rule entirely. Barring a full withdrawal, OMB Watch urges DOD to significantly revise the proposed rule. DOD should address the following concerns in any revised or future proposed rule: The proposed regulation would establish secrecy as the presumptive status of unclassified DOD information, contrary to the president's directives; The proposed regulation does not clearly specify which information requires safeguarding or dissemination controls, which could result in inappropriate withholding of information; and The proposed regulation could be construed to circumvent the CUI executive order or to prematurely establish a new CUI category.