Critical Mass Energy Project v. Nuclear Regulatory Commission, and Institute for Nuclear Power Operations

RANDOLPH, Circuit Judge,

concurring, in which Circuit Judge STEPHEN F. WILLIAMS joins:

Section 552(b)(4) of the Freedom of Information Act exempts from disclosure “commercial ... information obtained from a person and ... confidential.” This is rather straightforward language. The information must be commercial and the government must have received it from another. There is no doubt that the reports INPO voluntarily provided to the Nuclear Regulatory Commission fit that description. Are they “confidential”? If ordinary usage controlled, there would also be no doubt that they were. The reports are “conveyed [and] acted on ... in confidence” and they are “not publicly disseminated.” Webster’s Third International Dictionary 476 (1981).

In light of our decision in National Parks & Conservation Ass’n v. Morton, 498 F.2d 765 (D.C.Cir.1974), however, it is not enough to satisfy the language of exemption four. National Parks added — or, as has been said, “fabricated, out of whole cloth” — an additional requirement that must be met before confidential information is exempt from disclosure. Note, Trade Secrets and the Fifth Amendment, 54 U.ChiL.Rev. 334, 364 (1987). The fol*948lowing “objective” test must be satisfied: information qualifies for exemption as “confidential” if its disclosure would impair the government’s ability to obtain necessary information in the future, or if its disclosure would place the source of information at a.competitive disadvantage. National Parks, 498 F.2d at 770.

If this were a question of first impression, I would apply the common meaning of “confidential” and reject this test, which has spawned a good deal of litigation including this case, now about to make its third trip to the district court. I see no legitimate basis for a court’s adding some two-pronged “objective” test relating to the government’s need for the data and the consequences of destroying its confidential nature. Information not customarily revealed to the public is no less confidential when disclosing it would cause only discomfort rather than objectively measurable harm. In business affairs, as in personal affairs, there are many things people simply prefer to keep to themselves or to reveal to others only on a confidential basis. In applying exemption four, some courts have asked whether “disclosure will harm a specific interest that Congress sought to protect by enacting the exemption.” 9 to 5 Org. for Women Office Workers v. Board of Governors, 721 F.2d 1, 9 (1st Cir.1983). The “interests” are then defined, as in National Parks, as agency efficiency or competitive injury. But the “specific interest,” indeed the only interest, apparent in the statutory language is confidentiality and that interest is necessarily harmed by disclosure. The argument against this is that parties, by designating the information they provide as confidential, would wind up controlling whether it is publicly revealed. One may reasonably ask what is wrong with such a system. Patten & Weinstein, Disclosure of Business Secrets Under the Freedom of Information Act: Suggested Limitations, 29 Admin.L.Rev. 193, 195-202 (1977). At any rate, the argument is one of legislative policy. It is not based on any ambiguity in the language of the statute. See West Virginia Univ. Hosps., Inc. v. Casey, — U.S. -, -, 111 S.Ct. 1138, 1146-49, 113 L.Ed.2d 68 (1991); United States v. Ron Pair Enters., 489 U.S. 235, 241, 109 S.Ct. 1026, 1030, 103 L.Ed.2d 290 (1989).

I am, however, not at liberty to follow the common sense meaning of exemption four. This court has endorsed the National Parks definition many times, and it was applied by the first panel in this case. Critical Mass Energy Project v. NRC, 830 F.2d 278, 282 (D.C.Cir.1987). I am thus bound not only by the law of the circuit, but also by the law of the case, which also prevents me from following Judge Buckley’s persuasive dissent in Critical Mass I arguing that the National Parks test should not be further extended to force disclosure if the government’s “future ability to obtain necessary information on a voluntary basis” would be impaired, as it surely will be in this case. 830 F.2d at 288 (emphasis in original). In view of these constraints, and the fact that the decision here does not expand upon National Parks, I concur.