Appendix D
Private Sector Comments

Note: At its meetings and through its web site the committee invited all sectors to provide examples of documented conflicts that had occurred within the last five years. Only private weather companies responded and their comments (with identifiers of companies and individuals removed) were forwarded to the relevant NOAA officials for response. Private sector comments are given in italics and NOAA responses are given in indented plain text.

COMMENTS ABOUT NWS

1. As you may know, our company entered into an agreement with Bauch and Lomb in 1994 to create an Ultraviolet Index that could be used in conjunction with weather forecasts to predict the impact of ultraviolet radiation on skin and eyes. At the time, the government did not have any such index. Through research and development, our company created a UV index. In an independent initiative, another company, in conjunction with another interested partner, also developed a UV index. Daily production of hourly forecasted values began and were published in the media.

As the public became aware, through press releases and other means, of these developments in the commercial weather industry, the U.S. National Weather Service, under the direction of Dr. Elbert W. (Joe) Friday, Jr., began a rushed program to develop their own UV index.

Meetings were held between the commercial weather industry and the National Weather Service over this concern. The ultimate result was that while taxpayer money was spent to recreate what had already been developed in private industry, the National Weather Service limited itself to ongoing daily preparation of its index for approximately 50 cities, valid, for noon only, at each location.

Through the commercial weather industry, both in the newspapers, and on television, radio, and web sites, access by the public to these privately created UV indexes became widespread.

Many in the National Weather Service did not seem pleased by the



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Appendix D Private Sector Comments Note: At its meetings and through its web site the committee invited all sectors to provide examples of documented conflicts that had occurred within the last five years. Only private weather companies responded and their comments (with identifiers of companies and individuals removed) were forwarded to the relevant NOAA officials for response. Private sector comments are given in italics and NOAA responses are given in indented plain text. COMMENTS ABOUT NWS 1. As you may know, our company entered into an agreement with Bauch and Lomb in 1994 to create an Ultraviolet Index that could be used in conjunction with weather forecasts to predict the impact of ultraviolet radiation on skin and eyes. At the time, the government did not have any such index. Through research and development, our company created a UV index. In an independent initiative, another company, in conjunction with another interested partner, also developed a UV index. Daily production of hourly forecasted values began and were published in the media. As the public became aware, through press releases and other means, of these developments in the commercial weather industry, the U.S. National Weather Service, under the direction of Dr. Elbert W. (Joe) Friday, Jr., began a rushed program to develop their own UV index. Meetings were held between the commercial weather industry and the National Weather Service over this concern. The ultimate result was that while taxpayer money was spent to recreate what had already been developed in private industry, the National Weather Service limited itself to ongoing daily preparation of its index for approximately 50 cities, valid, for noon only, at each location. Through the commercial weather industry, both in the newspapers, and on television, radio, and web sites, access by the public to these privately created UV indexes became widespread. Many in the National Weather Service did not seem pleased by the

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situation when the commercial weather industry questioned why it was that the National Weather Service would expend public funds to create a product and produce a service when one was already developed and available from the commercial weather industry in response to what was perceived to be a business and market need. The governments of Australia and New Zealand began public awareness programs of the dangers of overexposure to the sun in the late 1980s, and Canada started an awareness program in 1992. Alarmed by increasing trends in skin cancers and cataract surgeries, the U.S. Environmental Protection Agency (EPA) and the Centers for Disease Control and Prevention (CDC) launched a similar health awareness program in 1993. The Canadian government first devised a UV forecast index based upon the incident rate of UV-B radiation reaching the Earth’s surface around noontime to help the public plan to appropriately protect themselves from overexposure. The EPA used the Canadian program as a model. Not having the necessary expertise, the EPA approached the National Weather Service early in 1993 about developing a U.S. Ultraviolet Index similar to the Canadian index. At the same time, several federal agencies (NOAA, USDA and the EPA) were deploying ground based observation networks to measure UV radiation reaching the Earth’s surface. These networks would provide long-term data for purposes of trend detection as well as the necessary validation for any UV index forecast. In November of 1993, the EPA invited atmospheric scientists, medical specialists and the private meteorological sector to discuss the possibility of a broad coalition. A major concern at that time was that none of the UV-B indices developed by any country included the effects of clouds. In response, the NWS examined the possibility of including existing NWS cloud forecast data in a UV index. After appropriate peer review, validation, and testing, the NWS concluded that including cloud cover in a UV index was feasible. The EPA as well as television broadcast companies, including The Weather Channel, promoted the NWS development of a baseline UV index available to the broad public in a non-exclusive manner as a public health service. Following further consultations with the commercial meteorology sector and other interested parties, an experimental UV index was made available in May 1994 as a plain text bulletin for 58 cities. The NWS also made its data and the methods used to calculate the index broadly available to the private sector in order that these companies could create value-added products, such as hourly UV forecasts for ski resorts or the many locations for which NWS did not issue a UV forecast. In cooperation with the American Meteorological Society, the NWS held several meetings during 1995-1996 to work in partnership with the pri-

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vate sector to help them expand to specific markets, cover the diurnal cycle, and provide information to cities not covered by the NWS. While some private sector companies did not agree that the NWS should issue any UV index, all parties did agree to work towards a standardized UV index scale. After providing the UV index for several years with a consistently high degree of validation, (Long et al., Bulletin of the American Meteorological Society, 1996), in the summer of 1999, the EPA, the CDC, the American Academy of Dermatologists, the American Cancer Society, and members of Congress asked the NWS to expand its coverage beyond the original 58 cities to 160 cities. The EPA, NWS, private sector and medical community representatives met to consider ways to improve coverage. NWS rejected the EPA’s suggestion that NWS provide UV indices for 160 cities. The NWS decided: To continue to produce the daily UV index at the original 58 cities; To deliver over the Internet in gridded format the data necessary for the private sector to create UV indices over the entire U.S., and; Not to produce a contoured map graphic of UV on NWS Web pages. The NWS has and continues to have good working relationships with most companies within the commercial weather industry and television broadcasters concerning the UV index product. All generally understand the limitations of any one sector’s service, as well as the expanded possibilities for the private broadcasting and commercial meteorology sectors to communicate the UV index and attendant health messages to the public. By continuing to improve the UV index forecast, and by making the numerical output available to the private sector in gridded format for creation of graphical products, the NWS satisfies both its public health and its economic enhancement missions. 2. For many decades, the National Weather Service has utilized an index called Wind Chill to attempt to describe the effect of temperature on humans during windy conditions. It has been known the Wind Chill formula is flawed and significantly overstates cold, yet the NWS has continued to use it for these many decades and publish and distribute charts to the media, emergency managers and the public, which allow one to plot temperature and wind speed and calculate Wind Chill. Based on this formula, the NWS also issues wind chill advisories. As a result, it can be argued that schools, businesses and other routine daily operations have, on many occasions, been prematurely curtailed while the NWS knew that the overstatement of values was costing the economy millions.

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Our company began a research and development project a number of years ago to develop its own index that would better state the weather’s effect on people. A patent is pending on this before the United States Patent Office. The National Weather Service recently began, what appears to be an urgent drive to create a new Wind Chill index for use in the United States. How these actions related to our company’s pending patent is not yet understood, but the National Weather Service and the consortium it established on the new Wind Chill index, are aware of the fact that a patent is pending. The National Weather Service has announced that it will put into use the new Wind Chill index this winter of 2001-2002. They have also announced that they are only making certain adjustments to the old Wind Chill index that was used last year and that next year, in the winter of 2002-2003, they will make further changes to the new Wind Chill index they will use this year. As a result, three different winters will have three different wind chill indices, which are not comparable to one another, all issued by the National Weather Service. In the span of a year and two days, three different NWS wind chill numbers will be valid. Our company believes this will be an issue of confusion for the public. Media outlets may still use the old charts and inconsistency may develop. Whether the rush to bring out a new, revised Wind Chill index in this problematic fashion, is a response to our company’s initiative is not known. But it does appear to fit the pattern that occurred with regard to the UV index in the 1990s. The National Weather Service, as part of its mission to help protect lives and property, has issued wind chill warnings and advisories since 1973, as one of its public safety products and services available to the American public. These products and services are regularly upgraded and improved to ensure public safety. The original version of the wind chill index was based on the 1945 scientific experiments of Antarctic explorers Siple and Passel. This research established an important relationship by recognizing that the combination of the two different elements—temperature and wind speed—could produce an effect greater than either element. However, they were working with the science available in the 1940s, and did not take into account other factors that impact wind chill. There has been general agreement in the scientific community for the past eight years that new and better science could produce a more accurate and useful wind chill index. Because of the National Weather Service’s responsibility to protect lives, it was necessary to identify and thoroughly re-

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search the factors influencing wind chill before making any changes. The final product must provide accurate data which would warn the public of danger to health and life. It was also necessary to create a standardized index that would be the most effective in promoting public safety and coordination between the U.S. and Canada. The Office of the Federal Coordinator for Meteorological Services and Supporting Research (OFCM) and the National Weather Service created a Joint Action Group for Temperature Indices (JAG/TI) to bring together the best scientists from the academic community and the federal government to carry out the necessary research and testing processes. JAG/TI consists of representatives of the OFCM, several federal agencies (U.S. Air Force, Department of Energy, National Weather Service (National Oceanic and Atmospheric Administration), Federal Aviation Administration, Federal Highway Administration, and U.S. Department of Agriculture), as well as the Meteorological Service of Canada (Environment Canada), the academic research community (Indiana University, Purdue University), and the International Society of Biometeorology (ISB). Using the advances in science, technology, and computer modeling which have occurred in the past decade, JAG/TI identified the factors other than temperature and wind speed that can impact human safety in severe winter weather conditions, and determined the most accurate way to measure them. These factors were identified, researched, and developed into the new wind chill formula using advanced computer modeling technology. This formula was then clinically tested using human volunteers at the wind tunnel and climatic chamber of the Defense and Civil Institute of Environmental Medicine in Toronto, Canada. The results of these tests enabled JAG/TI to further improve the wind chill formula, which has been integrated into the computer models that produce NWS weather forecast products. All the work done by the Weather Service to upgrade the index was carried out as part of the normal work of the NWS Office of Climate, Water and Weather Services. The timing of NWS implementation of a new wind chill index was driven by gradual improvements in the science and technology, and a methodical research, development and testing process which led up to initial implementation in 2001. The U.S. Department of Defense and the OFCM contributed funding, and Environment Canada provided facilities for the testing process. This new wind chill index provides, for the first time, a specific danger level for frostbite, including warnings of the length of time until frostbite occurs at varying levels of wind chill. It is also the first time that a standardized index has been used for the U.S. and Canada.

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Some private meteorological companies have developed their own wind chill formulas. The Weather Service has no problem with that. Indeed, these private efforts may well advance the state of the underlying science if they are subject to peer review and documentation in accordance with the principles set forth in Resolving Conflicts Arising from the Privatization of Environmental Data (National Academy Press, 2001). 3. For a number of years, we actively marketed our services to IDAHO POWER (IP), in Boise, Idaho. As the local utility in southwestern Idaho, IP’s primary service concern was the city of Boise. IP personnel informed me they elected not to subscribe to our custom forecast services, because one of the meteorologists in the Boise NWS office would provide them a “tailored” forecast each morning at no cost. The NWS continued to supply a custom forecast for a number of years, until the Fall, 2000, when energy deregulation issues forced IP to change operational strategy. At that time, IP elected to subscribe to our services, as the NWS office could not provide the data in the required format. Clearly, this is an example of the NWS exceeding mandated policy. The Boise weather office staff have not provided tailored forecasts to Idaho Power. Idaho Power did receive and use weather information from the NWS. They used the standard NWS Coded Cities Forecast (CCF) and computer generated temperature forecasts in their energy demand model. We believe they also use daily temperature and precipitation observations. All of these products are available to anyone, not made for a specific customer, and are part of the national suite of products. 4. This program from the National Weather Service (http://www.crh.noaa.gov/ict/gfe/temps.htm) duplicates what the private sector has done for years. Our company, literally since Day One of its founding 20 years ago, has produced point-specific hourly forecasts. Currently, there are two private sector companies that produce animated mesoscale temperature images and both sell them to clients and distribute them through the media. Their products are FutureCast and MyCast. This new NWS program looks almost identical to these existing programs. The general public simply does not need or use mesoscale hourly forecasts…but energy companies and certain industrial users do. I believe this is both a duplication and violation of the Public-Private Partnership Policy. NWS forecasters have been formulating point-specific hourly forecasts for many years. For example, surface temperature is one of the primary factors affecting the onset of convection and hazardous freezing conditions associated with winter weather. In order to produce a core set of watch/ warning/advisory/statements one must be able to forecast individual weather elements, such as temperatures, on an hour-by-hour basis. Our forecast grids are on a scale consistent with the state of the art/science in

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our forecast models. Increases in time and spatial resolution of NWS forecasts, now and in the past, have been enabled by advancements in the science and technology. The example cited is a display of information produced by NWS forecasters using the Interactive Forecast Preparation System (IFPS). IFPS, long-planned as part of the NWS modernization and currently being implemented across NWS, allows forecasters to produce forecasts in digital form with higher resolution in space and time. Forecasters produce, manipulate, and publish forecasts in digital form with the resulting digital forecasts driving production of traditional NWS information products. This capability will also allow them to prepare products in multiple formats (e.g., graphics). The product in question is a straightforward graphical presentation of the underlying digital information from one NWS forecast office (Wichita). The NWS is anticipating distribution of this type of data in various forms including digital data formats. It can then be used by the private sector to reformat and repackage to meet their customers’ diverse needs. IFPS has been broadly publicized, including presentations at meetings of the American Meteorology Society and elsewhere. 5. Why does the NWS feel it needs to make 7 and 14 day public forecasts? Seehttp://weather.noaa.gov/cgi-bin/iwszone?Sites=:ksz083. On Wichita’s NOAA Weather Radio, a listener can obtain 14 day forecasts (not available on the Web). As Joel Myers says, “Are they going to do 28 day forecasts and expect us to sell the 29th day?” While we were using NWS model guidance as a source of input, the private sector has made 7 day forecasts for 5+ years. This is duplication by the NWS and not required for public safety or consistent with the Weather Service’s core mission. Weather and climate phenomena are ongoing and dynamic. Historically, forecasters were only able to predict conditions at best a very few days in advance. Advances in science as well as in information and observational technologies now permit predictions in the one to two week time range with some skill, and are beginning to permit forecasting extreme climate events. For the NWS to achieve its core mission of protection of life and property and the enhancement of the economy, it must provide predictions for all time scales up to the limit of scientifically demonstrated skill. Hence, NWS forecast products can be categorized into three broad categories. The first are short term warnings and forecasts of weather conditions, be they hazardous or benign. Typically, these products have valid time ranges from a matter of minutes for short-duration warnings (e.g., Tornado Warning), to up to 60 hours for Winter Storm Outlooks. In the medium range, there is a need to monitor weather conditions and to

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provide emergency managers, planners, forecasters and the public advance notice of potential threats through seven day forecasts, 6-10 day and “Week Two Threats Assessments.” NWS also predicts extreme climate events, such as drought, excessive rain, and temperature extremes as far in advance as possible. Water, energy, transportation and other economic sectors use these forecasts to plan and avoid or mitigate risk. For example, the NWS seasonal climate forecast for 1997-1998 saved Californians $500 million to $1 billion as they were able to take mitigation measures six months in advance of heavy rains. All of these are part of the national information database that the NWS provides for the protection of life and property and the enhancement of the national economy. We are unaware of any policy principle authorizing NWS to withhold this taxpayer-funded information from the public. 6. This is the form of a National Weather Service AIRMET (hazardous weather for small aircraft) report: FOS WA 301912 AMD AIRMET SIERRA UPDT 4 FOR IFR AND MTN OBSCN VALID UNTIL 302100 AIRMET IFR…WA OR CA…UPDT FROM BLI TO 40SSW FMG TO MOD TO OAK TO FOT TO TOU TO BLI OCNL CIGS/VIS BLW OVC010/3SM IN CLDS..PCPN AND BR. CONDS CONTG BYD 21Z THRU 03Z. AIRMET IFR…WA OR ID MT FROM YDC TO 50NNE FCA TO HLN TO LKT TO BKE TO PDT TO YDC OCNL CIGS/VIS BLW OVC010/3SM IN CLDS..PCPN AND BR. CONDS CONTG BYD 21Z THRU 03Z OVR NRN ID/NWRN MT PTNS AREA…ELSW…CONDS ENDG BY 21Z. AIRMET IFR…CA…UPDT FROM EHF TO HEC TO LAX TO 40W RZS TO EHF OCNL CIGS BLW OVC010 OCNL VIS BLW 3SM IN CLDS AND PCPN. CONDS CONTG BYD 21Z…ENDG BY 03Z. AIRMET MTN OBSCN…WA OR CA ID MT WY NV UT

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FROM YXC TO GTF TO BPI TO DTA TO BTY TO HEC TO 40W RZS TO FOT TO TOU TO YDC TO YXC MTNS OCNLY OBSCD IN CLDS AND PCPN. CONDS DVLPG/ SPRDG EWD DURG PD…CONTG BYD 21Z THRU 03Z. This coded report (dating from the days of low speed communications requiring “broken language” communications as a form of data compression) can be easily read by any pilot in the world. While the private sector was first to provide this data in plotted form, I have no problem with the NWS taking its basic aviation text data and plotting it on a simple map. See, for examplehttp://www.awc-kc.noaa.gov/awc/airmets/wsairmet.gif. While some contend it is “adding value” to plot this data, if that’s the case it is such a low level of added value it is acceptable to me because it is a simple plot and the potential for enhanced aviation safety overwhelms the concern in this case. Now viewhttp://adds.awc-kc.noaa.gov/projects/adds/flight_path/. This is an entirely different matter. This is not simply aviation weather, it is flight planning. There are a number of commercial weather companies (Jeppessen, Universal, Lockheed, etc.) that do flight planning services. The NWS should not be competing with flight planning companies at even this level, but, it gets worse. Seehttp://www.awc-kc.noaa.gov/awc/iff/iffdp-menu.html. The NWS will create a custom flight package for international flights. For example, Continental Airlines can call and request a menu of products for a flight from Houston to London. The NWS will deliver it to the fax machine of Continental’s choice, immediately before scheduled take-off and will provide a meteorologist to answer questions, elaborate, etc. (see phone number for that purpose on the Web page). This service did not exist five years ago (how did the airlines ever manage without this service from the NWS?). The NWS decided to duplicate what in-house airline meteorologists and companies like Kavouras, Universal and Jeppessen were already doing. Aviation Digital Data Service. The Federal Aviation Administration (FAA) has asked NWS to participate in its effort to help the aviation community improve the safety and efficiency of flight planning through the development of an Aviation Digital Data Service (ADDS). The Federal Aviation Act, 49 USC 44720, requires NWS to furnish “reports, forecasts, warnings and other advice to the Secretary of Transportation and other persons” in order to promote safety and efficiency in air navigation. The FAA has tasked a product development team to develop methods to better gather, display, and utilize official National Weather Service aviation weather information. The FAA also created a team composed of govern-

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ment, industry, and association representatives, which has endorsed ADDS as a means by which both the FAA weather briefer and the pilot can “view the same weather graphics during weather briefings” (p. 39, FAA Safer Skies: Focused Safety Agenda, March 2000). The ADDS web site, http://adds.aviationweather.noaa.gov/, prominently states: “The Federal Aviation Administration funds and directs the Aviation Digital Data Service and the experimental weather products that it displays. These products have not been developed by and are not endorsed by the National Weather Service.” International Flight Folder Documentation Program. The International Civil Aviation Organization (ICAO) requires all countries to provide international flights with a minimum level of weather services. This requirement ensures flight safety and a consistent minimum level of services worldwide. The U.S. is a signatory to the 1947 ICAO Convention, and the Federal Aviation Act, 49 USC 44720, requires NWS to “establish and coordinate international exchanges of meteorological information required for the safety and efficiency of air navigation.” The services in question— flight documentation—provide departing international flights with ICAO mandated information. The NWS has been providing this service for 50 years. In 1998, NWS moved to a web-based production and delivery system and consolidated management at the Aviation Weather Center. Previously, the necessary documentation was manually assembled at numerous forecast offices. The Flight Documentation system is operated by the private sector under a NWS contract. The service only provides the minimum information required by ICAO. Most international carriers receive additional information and services from their own in-house meteorological staff or commercial weather firms. 7. Until 1999, the Storm Prediction Center (formerly the National Severe Storms Forecast Center) transmitted a daily list of all reports of tornadoes, large hail and damaging winds occurring during the previous 24 hours. Our company took this list, added reports from local National Weather Service offices that did not make the list and also added reports from the Associated Press’ National Disaster Wire to which we were subscribers. Our company (and other commercial weather companies) then compiled this data into a new list, quality controlled it (i.e., checked the position of severe storm reports relative to the position of radar echoes to eliminate false reports), plotted the reports and (in our case) added radar storm tracks so clients (such as insurance companies, insurance adjusters, shingle companies, etc.) could view the location of storms in between reports so they could interpolate the location of potential losses. In 1999, the Storm Prediction Center began plotting these reports on colorized maps and making them available on the web in real time. As a

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result our company and other commercial weather companies have lost many of their clients for this service. While our product was superior to the National Weather Service’s, many clients cancelled because of a “free” alternative. I estimate the annual loss of revenue to our company in the $15,000 to $20,000 range. As always, I support making the data available as part of the national infrastructure. However, the general public does not need colorized, real time maps of severe storm reports. This product is of interest to industry and is best served by the private sector. The National Weather Service, as part of its mission to protect lives and property, issues warnings for severe thunderstorms and tornadoes. The Storm Prediction Center (SPC) automatically collects and compiles reports of these events and sends them out as a table and in graphic format. The purpose of the report is to allow local NWS Weather Forecast Officers and emergency managers downstream from the storms to see the kind of severe weather approaching them. In order to effectively plan for pending events, emergency managers need to know what the approaching storms are capable of producing, e.g., 3/4" hail and tree damage, or F-5 tornadoes, or 3" hail and 100 kt winds. These products were developed in the late 1970s. Initially, the product was compiled manually and issued on an as time allows basis. Due to staffing reconfiguration with the establishment of the SPC, manual collection was no longer possible and in 1996 production of these products was automated. The data was collected and the products issued hourly. Presently the product is disseminated externally via NOAA Port and internally via AWIPS. Before 1999, computer limitations precluded putting anything but the report list on the Internet. Now, the only difference between the NOAA Port and AWIPS product and the Internet application is that tornado reports are colored red, hail reports green, and wind reports cyan. The colors help the product serve as a quick guide to forecasters and emergency managers who use this page as a quick reference for severe weather that has occurred upstream of their location. The underlying data on which the severe storm reports are based are likewise publicly available via NOAA Port. 8. The NWS wants to extend its hydrologic modeling activities to small ungauged urban watersheds. This is in conflict with commercial weather services: custom flood warning systems contracted by businesses or other entities. River forecast centers forecast long duration slow rise river response. These events are rarely life threatening and therefore not within the core mission of the NWS. Forecast offices do not have access to cutting edge technology available in the private sector for forecasting small basins

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such automated use of information in the headers has increased, and the information content of NWS headers has been increased to support these services better. As a result, discrepancies between the header and the body of NWS warnings have become both more likely and more important to avoid. NWS forecasters use a variety of automated systems to support rapid production of short duration warnings. The examples of data quality problems with these warnings have uncovered three general shortcomings in this complex man/machine system, and NWS is taking action to correct each of them. First, a careful review of NWS policies and procedures which provide instructions for NWS forecasters regarding exactly how NWS warning products must be produced and formatted uncovered areas where greater precision is needed to ensure NWS produces consistent, machine-readable warnings. NWS Directives System Instructions 10-511 (Weather Forecast Office Severe Weather Products Specification) and 10-922 (Weather Forecast Office Hydrologic Products Specification) update the policy for short duration warnings and provide NWS managers and forecasters with clear and concise instructions regarding short duration warning procedures and formats (see http://www.nws.noaa.gov/directives/). NWS has worked with our private sector partners, including the individual providing the examples of data quality problems, to ensure these instructions reflect appropriate standards and are complete, clear, and accurate. Efforts have also been undertaken to ensure that NWS software systems are consistent with these instructions. Second, discrepancies between the header and body of NWS warnings most typically happens when NWS forecasters manually edit the body of warnings created by automated formatting software but fail to accurately edit the header as well. These manual editing steps can be important to warning accuracy, but NWS needs to ensure the resulting product is consistent with all product format standards. To provide this assurance, NWS will implement a software based Quality Control program for short duration warnings in mid-2003. This program will check warnings for proper coding and format prior to dissemination. NWS partners and customers made significant contributions to the coding and format requirements for this Quality Control program. Finally, NWS leadership continues to stress quality control to the forecasters at our Weather Forecast Offices. Greater management and forecaster diligence to avoid quality control problems with NWS warnings is already showing results. The NWS values the quality control feedback our private sector partners and customers provide. We have a common goal to provide the best possi-

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ble warning services, and we are working together to address the detailed concerns raised in this item. 25. At the committee’s request, our company has tracked errors in NWS data. Attached are nine representative examples involving inaccurate reports, various adjustments, contemporaneous reports that are of questionable accuracy, and inaccuracies creeping into the climate record.2While we do not normally track these kinds of errors we see them virtually every day. In fact we have a team devoted to reviewing weather statistics to try and create the greatest accuracy for newspaper clients where we face the daily challenge of putting into print accurate information, even though the daily record and climate record as reported by the NWS often contains discrepancies. Case 1. In element A, the National Weather Service Summary reports low temperature for January 9, 2002, to be 22 degrees at 10:49am. This report was issued as of 4:42 pm January 9, 2002, as per element C. Attached are decoded hourly reports from the official surface observations (element B) which shows that the temperature, on the hour, had not dropped below 40 degrees. Case 2. In the National Weather Service Max/Min Temperature and Precipitation table (element A), Doylestown reported 0.26 inches of precipitation in the 24 hour period ending at 7am. Our company’s decoded observations (element B) indicated no precipitation had fallen during that 24 hour period of time although precipitation amounts were reported and decoded (element C). The previous day, snow fell at this location (element D). A typical, known error with ASOS equipment is a melting of snow long after the storm has ended and the equipment reporting it as new precipitation when none actually occurred. These should be caught, but the records from the National Climatic Data Center show the 6XXXX code indicating precipitation (elements E and F). The summary for the data from NCDC that goes into the official records indicates hourly precipitation (element G) and a 24-hour total of 0.26 inches of precipitation (element H). Even though this is a preliminary summary, it is unlikely to be caught and is inaccurate. Case 3. Incorrect data is entering the climatic data stream due to erroneous reports from ASOS equipment. This hourly report from Mt. Pocono, PA, on December 15, 2000, shows 0.09 inches of precipitation being re- 2   The logs themselves, which exceed 50 pages, are not included in this report.

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corded (element A) from a clear sky (element E). The summary of the unedited surface weather observations also shows the 0.09 of an inch (element B). The Local Climatological Data summary from NCDC for December 2000, indicates that the water equivalent of 0.09 fell on the 15th (element C) without any significant weather being reported that day (element D). The frozen precipitation from the day before melted on the 15th giving the false reading, and 18 months later, the error still exists in the records kept by the official agency charged with keeping climatological data. Case 4. Precipitation in areas that do not normally receive substantial rain draws a high level of focus. In the newspaper industry, the deadlines are tight between when the information is collected and when papers must be published, especially along the West Coast. This leaves little time to sort through conflicting reports. The 4:27pm PST report from the National Weather Service office in San Joaquin Valley indicated that 0.18 of an inch of rain fell in Fresno on January 27, 2002, as of 4pm local time (element B). The hourly reports clearly indicated that 0.01 of an inch fell before mid-night local time and that the total should really be 0.17 of an inch (element C). When the midnight report—issued at 12:27am local time—was released, 0.15 of an inch was the official measurement for the day. This amount does not show up anywhere unless any precipitation before 4am local time is thrown out (element D). Case 5. The next day’s reports from the same NWS office revealed additional problems. Rain totals for the 4:27pm local time report for January 28, 2002, in Fresno indicated that 0.01 of an inch was observed (element A), yet the month to date total was increased by 0.02 of an inch. It was later (4:54pm) corrected to reflect the proper month to date total (element C) based on the actual precipitation for the day (element E). However, the total precipitation for Bakersfield on the 4:27pm report was listed as a trace (element B), which was confirmed by hourly reports (element F). The 4:54pm report changed the precipitation total to 0.16 of an inch increasing the month to date and season to date totals by 0.01 of an inch and increasing the year to date totals by 0.11 of an inch (element D). Case 6. The 4:26pm local time climate report for Eureka, CA, issued by the National Weather Service on January 8, 2002, indicated that 0.23 of an inch of precipitation fell that day bringing the month and year to date totals to 4.05 inches (element C). The report issued 8 hours later for the entire day January 8, 2002, showed a decrease to 0.04 of an inch of precipitation and a month and year to date total of 3.86 inches (element B). The season to date also was lowered by a similar amount. The report issued by the NWS

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at 4:23pm local time the next afternoon (element A) kept the totals at the same level as shown in element B. Case 7. The hourly observations showed a high temperature on January 28, 2002, in Akron, OH, of at least 59 degrees tying the record for the day set in 1914 (element C). This was a rather noteworthy event and prompted many calls for interviews. By 5pm, the temperature has already begun to drop and the National Weather Service sent out the climate report at 5:25pm local time. This report indicated that the record had been tied at 4:09pm (element B). This is a non-standard reporting time and, more than likely, represented the official high for the day. However, an update was issued at 9:11pm, about 2 hours after the hourly observations indicated that the temperature had actually gotten to 60 degrees, setting a new record for the date. This update (element A) listed the new high as 60 degrees, but it occurred at exactly the same time reported 4 hours earlier (4:09pm). Case 8. Equipment in the field can break down on occasion. However, that does not explain all of the unusual reports received from ASOS stations. At Harrisburg, PA, the ASOS at MDT showed 7 mile visibility and a clear sky below 12,000 feet (element A) and then suddenly the visibility dropped to 1.5 miles and rain was reported from the clear below 12,000 foot sky (element B). This same type of event has happened before at MDT (element D) and at many other stations for which we cite the example of Houston, TX, which went from 10 miles to 1.5 miles back to 10 miles in a 50 minute period of time during the middle of the day (element C). In that observation, varying visibility between 0.25 of a mile and 5 miles produced the 1.5-mile visibility. Fayetteville, NC, has also visibility errors more frequently than other stations (element E). Case 9. South Bend, IN, appeared to receive 0.07 of an inch of precipitation on February 16, 2002, with another 0.01 of an inch on February 17, 2002, as reported by ASOS (element A and B). The National Weather Service climate summary through 4pm local time February 16 corresponded with the hourly observations indicating that 0.06 of an inch had fallen (element C). The NWS midnight summary, however, changed the value to 0.09 of an inch of precipitation (element D) and kept it the next morning. The February 17 summary as of 4pm local time showed that 0.07 of an inch fell (element E) when the hourly reports indicated that 0.01 of an inch fell. Snowfall was also a problem. The 4pm NWS summary February 16 (element F) listed 0.6 of an inch of snow fell (a 10-to-1 ratio standard estimate). The midnight report kept the 10-to-1 ratio and changed the snowfall to 0.9 (element G). The 7:40am local time report the next morning listed a total

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snowfall for February 16 of 0.3 of an inch (element H). The month and season totals were adjusted downward as well. That total was maintained on the report through 4pm February 17 when another 0.7 of an inch was added to the reduced totals (element I). This example presents nine representative cases of seeming problems in various National Weather Service observational summaries and in the climate data records maintained by the National Climatic Data Center (NCDC) based on these summaries. A brief discussion of the procedures used to create these summaries is needed to provide a framework to address these cases: All of the representative cases begin with the Automated Surface Observing System (ASOS) as the initial provider of the information. ASOS continuously monitors the environment and feeds data to NWS Weather Forecast Offices (WFOs). Some WFOs issue an interim climate summary in the late afternoon, derived from an automated ASOS product, to provide an early look at temperature and precipitation information for that day. Each WFO creates and transmits a daily climate summary in the early morning which will include data from the interim climate summaries (if any) for the previous day, updated as necessary given additional information such as Cooperative Observer Program reports (see below). NWS transmits the daily climate summaries to NCDC where they are collected to form preliminary climate data. NCDC performs further checks and eventual certification of the climate data (with several months lag time), using all available observational data, to create an official climate record. In the ideal, the ASOS observations would be error-free and representative of actual conditions. Therefore the interim climate summary, daily climate summary, preliminary climate data, and final official climate record would all agree with each other and all reflect the best possible estimate of conditions. As the nine representative cases make clear, this ideal situation is not always met. There are a variety of reasons for this, beginning with the ASOS instrumentation. Errors in ASOS data are generated in one of two ways: The ASOS fails to perform as designed, experiences known shortcomings in certain instrumented observations, or is out of service; or The ASOS is affected by non-meteorological environmental conditions. When NWS staff are able to identify these errors, they manually correct data in the daily climate summary (but typically not in any interim summaries) to provide the highest quality information available. Thus, discrepancies and differences in reports occur due to either human interven-

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tion to correct ASOS errors or human errors made while correcting ASOS errors. With the above as background, the representative cases can be addressed: Representative cases 2 and 3 are directly related to the shortcoming of the ASOS heated tipping bucket instrument. As is noted by the questioner, this instrument has known shortcomings in measuring snow. In some cases, snow can accumulate and not be measured until it is melted by warming temperatures. These measurements (“late tips”) are then disseminated in the observation. When NCDC performs full quality control processing, checks for these specific situations are made, and when they occur, the data are flagged for further manual review and verification. NCDC can either make a precipitation estimate or mark the observation as missing. NWS recognizes the problems in this area. For some ASOSs, backup observations are available from COOP observers, contract observers, etc. When available, these backup observations are used to correct a faulty precipitation measurement, but for the sites noted in cases 2 and 3 (Doylestown and Mt. Pocono, PA), backup observations are not available. Plans to modernize the NWS COOP network will increase the availability of suitable backup observations. Plans to replace the ASOS instrument itself are also under way (see below). Representative case 8 has several observations where the ASOS appears to be affected by non-meteorological environmental conditions: The decrease in visibility at observation site MDT (Harrisburg International Airport) appears to be associated with a smoke cloud from Canadian forest fires. There is not enough data to fully explain the situation at Fayetteville, NC, but it appears to be caused by either a condition local to the ASOS instruments or another environmental cause. NWS will investigate the location of this ASOS to determine if the location is adversely affecting the accuracy of observations. The observations from Houston, TX appear to be affected by construction at the airport which created dust interpreted by the ASOS as variations in visibility. In each of these cases, a human observer monitoring the ASOS during the time of the reports attests to the accuracy of the observation, whether the data are automated or edited by the observer. Most of the representative cases (1, 4, 5, 6, and 9) are the result of inconsistencies due to multiple reports. The data for the interim climate summary uses temperature and precipitation information from ASOS. However, at many NWS offices, including the offices serving Madison (case 1), Fresno (cases 4, 5), Bakersfield (cases 4, 5), Eureka (case 6), and South Bend (case 9), there are alternative sources of reports, primarily COOP sites on or near the airports. If the ASOS is not operating properly or if the data are judged to be incorrect, NWS staff use information from these alternative sources to correct readings or to fill in gaps from the ASOS. The data from the interim (late afternoon) climate summary report is

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updated with the latest information and finalized in the daily climate summary issued early the next morning. Thus, when data in ASOS reports are compared to updated data in the early morning issuances, discrepancies are apparent. Finally, the discrepancy noted in representative case 7 is simply due to a corrected report issued by NWS. The temperature value in the interim climate summary was reported incorrectly and was changed via a corrected climate summary report issued 4 hours later. NWS standard format for climatological reports is defined in NWS Directives System Instruction 10-501 (Weather Forecast Office Statements, Summaries, Tables Products Specification, see http://www.nws.noaa.gov/directives/). Planned Improvements. NWS is dedicated to providing observational products which are as accurate as possible using current technology and available resources. At the same time, work is under way to improve NWS observational data and services. The ASOS heated tipping bucket will be replaced with an improved All-Weather Precipitation Accumulation Gage (AWPAG) at selected ASOSs starting in 2003, with the planned upgrade completed before winter of 2004-2005. (AWPAG installation plans do not include every ASOS location; in particular the sites noted in cases 2 and 3 (Doylestown and Mt. Pocono, PA) are not planned for AWPAG installation as of this writing.) Many missing temperature readings, which then require gathering information from other sources, are due to limitations in the current technology of the ASOS dewpoint sensor. A new dewpoint sensor which eliminates these problems is being fielded now. Other ASOS improvements are in various stages of investigation and development. COMMENTS ABOUT NOAA AND ACADEMIA 26. Over the past 10 to 15 years certain U.S. government weather agencies have become more and more active relative to direct competition with U.S. private industry. This competition is especially noticeable from NCAR/UCAR, FSL and the various labs. It is common for these agencies to directly offer products and services to foreign governments in direct competition to U.S. industry or to exclusively join with a single contractor in the U.S. to market one of their “products.” I believe that these practices either are, or should be, prevented by law. U.S. industry pays the taxes that enable these organizations to develop software and equipment for the common good, not for use against the organizations that enable them to exist. Exclusive links with one contractor are just that—exclusive. If a U.S. government agency has code or hardware that can be marketed in some form, then why

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should only one U.S. company be allowed to market it? That certainly is a disadvantage to the other contractors. Finally, while the UK MET and other national weather services are attempting to become “commercial,” it was my understanding that the U.S. government was not on the same path. Why then do the U.S. weather agencies charge for software that can be exploited commercially? One would think, if the software is releasable, that it should be released freely to U.S. industry for use by U.S. business and to help U.S. private industry compete on a more even footing with UK MET (and others) who are trying hard to eliminate the private weather sector in the U.S. [This comment could not be directed to a specific individual, thus no response is given.] 27. As recently as October 24, 2001, the National Oceanic and Atmospheric Administration (parent agency of the National Weather Service) announced its new “Environmetrics” program. See http://lwf.ncdc.noaa.gov/oa/climate/research/environomics/environomics.html. In this program, NOAA and the National Weather Service tie various meteorological parameters to agricultural output and to residential heating demand. For many years, commercial weather companies as well as meteorologists employed by private sector companies (such as Smith Barney, E.F. Hutton and others), have created various systems for relating meteorological parameters to economic output. The policy clearly defines this as a private sector activity: c. The private weather industry is ideally suited to put the basic data and common hydrometeorological information base from the NWS into a form and detail that can be utilized by specific weather and water resources-sensitive users. The private weather industry provides general and tailored hydrometeorological forecasts, and value-added products and services to segments of the population with specialized needs. The National Climatic Data Center has a long history of collecting, quality controlling and analyzing climate information. This history includes an active Climate Monitoring program focused on providing information to the U.S. Administration and the general public on national and regional trends of climate events that impact the nation’s economy and society. Indices have always been a vital part of this program. Drought indices such as the Palmer Drought Severity Index, Growing and Heating Degree Day indices, and the Climate Extremes Index and Greenhouse Response Index are just some examples of indices that provide information on weather and climate conditions that affect the nation’s economy and society. Indices developed as part of NCDC’s National Climate Impact Indi-

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cators Program (formerly known as Environomics), such as the Residential Energy Demand Temperature Index (REDTI) and the Moisture Stress Index (MSI) for corn and soybean crops, provide additional quantitative measures of climate’s influence at the national level. The information conveyed with these indices assists the Department of Commerce in its role of providing information that strengthens the understanding of the U.S. economy and is essential to ensuring that political and business leaders have access to pertinent information that is part of any well-informed decision-making process. In addition, the sensitive nature of some indices such as the MSI, which provides indications of overall crop performance prior to the end of the harvest season, dictates that the data be calculated and coordinated with other government agencies, e.g., USDA. 28. FSL is bidding against our company right now in Vietnam to do the NWP. FSL pushed their modeling capability as well as their meteorological workstation. FSL wants to do the flash flood warning system in central Vietnam? No experience here; FSL is really selling against U.S. industry. To the first comment—FSL has never submitted a proposal or a bid to anyone in VHMS (Vietnam Hydrometeorological Service) for any activity. To the second comment—FSL presented to VHMS in Hanoi in September 2001, an overview of FSL’s organizational structure, information on projects FSL is working on in other Southeast Asian countries and an overview of the WorldWide Weather Workstation (W4) development. This presentation was part of the meeting sponsored by NWS under the bilateral U.S./Vietnam agreement signed in 1/01. To the third comment—this comment is significantly off base. FSL is not responsible for any interaction with Vietnam with respect to flash flood mitigation, hydrological studies or hydrological forecasting. This is the responsibility of the NWS, and there has been considerable interaction between NWS and VHMS on these topics. I believe the company that submitted these comments knows this. With regard to the second part of the comment—“…FSL is really selling against U.S. industry”—the purpose of FSL’s visit to Vietnam was to gain an understanding of the current level of expertise in Vietnam, make them aware of some of the things FSL is doing and promote the potential for future interaction regarding training, which we are doing in other countries and for which I presented our just-completed Thailand training activities. It is quite difficult to be “selling” anything when there is no proposal on the table, no bid to address and little or no communication between the parties. My only contact with any VHMS personnel after the September 2001 NWS sponsored meeting was at an NWS APEC (Asian-Pacific Economic Cooperation) sponsored meeting in Orlando at the AMS annual meeting in January 2002. There I discussed with two VHMS representatives their current situation and agreed with them that training of personnel should precede purchasing of large quantities of meteorological equipment so that the personnel would

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understand the purpose of the equipment and how to integrate these products to improve their overall weather forecasting abilities. This type of training, if done by U.S. personnel of course, can lead to the exposure of the trainees to U.S. products, which in turn leads to purchases of these products. We have seen this happen in several countries. Finally, regarding Vietnam, there have been no letters, e-mails or phone calls by me to further promote the general discussion that took place at the APEC meeting in January. FSL’s Position on Working in Other Countries. U.S. industry does not do application training and training on how software systems can be integrated into operational weather activities—FSL does. Through this training, the level of weather and forecast knowledge is enhanced so that the country’s operational weather organization can appreciate the value of U.S. services, computer products and meteorological equipment with respect to improving their regional, province and local forecasts. Our mission is technology transfer and we welcome industry partnerships through Federal Business Opportunity announcements or through different types of agreements which encourage U.S. industry to work with us. Through our international activities, we introduce technology to countries which can lead to sales for U.S. companies. For example, our interactions with CWB (Central Weather Bureau of Taiwan) influenced purchases of U.S. products of greater than $20 million for computers, network upgrades and mass storage and over $14 million for Doppler radars. Quite straight-forwardly, our foreign visitors work on specific workstations, with specific computer networks and applications and meteorological equipment. When they return to their home country, they want to purchase these products with which they are familiar.

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