“Why PRA does not apply - “Agency records are not presidential records.”
All agencies operate under the president...or do they? Ask the question, where does the national intelligence agencies lie in the three tier government system.
National Archive Statement:
What are “personal records” under the Presidential Records Act (PRA)?
Under the PRA, “’personal records’ means all documentary materials of a purely private or nonpublic character which do not relate to or have an effect upon the carrying out of the constitutional, statutory, or other official or ceremonial duties of the President.” This includes
(A) diaries, journals, or other personal notes serving as the functional equivalent of a diary or journal which are not prepared or utilized for, or circulated or communicated in the course of, transacting Government business;
(B) materials relating to private political associations, and having no relation to or direct effect upon the carrying out of constitutional, statutory, or other official or ceremonial duties of the President; and
(C) materials relating exclusively to the President’s own election to the office of the Presidency; and materials directly relating to the election of a particular individual or individuals to Federal, State, or local office, which have no relation to or direct effect upon the carrying out of constitutional, statutory, or other official or ceremonial duties of the President.
What are “Presidential records” under the Presidential Records Act (PRA)?
“’Presidential records’ means documentary materials created or received by the President, the President’s immediate staff, or a unit or individual of the Executive Office of the President whose function is to advise or assist the President, in the course of conducting activities which relate to or have an effect upon the carrying out of the constitutional, statutory, or other official or ceremonial duties of the President.”
https://www.archives.gov/press/press-releases/2022/nr22-001#June-9-2023-statement