National Park Service v. National Trust for Historic Preservation in the United States · ¶18

Nor is that all. The government has also presented declarations from the Director of National Intelligence, the Director of the Central Intelligence Agency, the Director of the Federal Bureau of Investigation, the Director of the United States Secret Service, and the Secretary of State, the Secretary of Homeland Security, and the Secretary of the Army, among others, attesting to national security and other harms that would likely arise from enjoining a “single, coherent” project that cannot be readily cleaved into distinct below- and above-ground pieces. See, e.g., App. to Application 229a, 246a–247a, 397a–398a, 426a–429a, 431a–433a, 437a–439a. The Secretary of the Army, for example, represents that “[t]he height and mass” of the planned above-ground ballroom are “crucial” to shield the planned underground military installation “from kinetic impacts,” and that, without such height and…

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