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5 BUILDING AN AGENCY
Pages 87-98

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From page 87...
... Paramount in maintaining trust are credible pledges that the identity of individual reporting units will be held in confidence. We discuss the problems for BTS that are posed by data programs, such as those in the Office of Airline Information, which were developed for regulatory purposes and operate under provisions that mandate the release of data for individual businesses.
From page 88...
... For example, a direct reporting line from the head of the statistical agency to the secretary of the department fosters both independence and policy relevance, so long as that reporting line carries no requirement or expectation that the statistical agency will submit its data releases for prior approval regarding content or date of release. (The secretary of transportation has been scrupulous about respecting BTS's independence in this regard.)
From page 89...
... In addition, the department has helped to ensure BTS's professional independence by establishing practices whereby BTS has the authority to select and promote its professional staff and to release statistical information without prior clearance. BTS seeks wide review inside the department of such publications as the Transportation Statistics Annual Report.
From page 90...
... (BTS press releases should also include information about the quality of the data being released.) Further, when BTS begins to develop regularly published indicators of the transportation system, it will be important to establish predetermined schedules of public release in order to prevent the manipulation or the appearance of manipulation of release dates for political or policy purposes.
From page 91...
... The critical nature of confidentiality protection for the mission of a statistical agency and the implications for the kinds of data programs the agency should operate is particularly important to address in a department like USDOT that has many data systems that serve administrative and regulatory functions in which identification of reporting units is an operational necessity. Confidentiality Protection The release of data that identify individual reporting units is incompatible with the mission of a statistical agency.2 A statistical agency provides data, not for administrative, regulatory, or enforcement purposes, which would require the identification of individual respondents, but for description, evaluation, and analysis on the basis of patterns and trends from groups of respondents (National Re 2The exception is when the reporting units, such as state and local governments, are public entities, in which case statistical agencies commonly report data for individual units (e.g., highway expenditures of each state)
From page 92...
... However, statistical microdata files, although they provide data for individual reporting units, do so in a manner that guards against disclosure of the identity of a unit for example, such files carry no name or address, have limited geographic identification, and alter sensitive variables that might otherwise possibly permit disclosure (e.g., reported income above a specified amount may be assigned to a single broad category)
From page 93...
... Identifiable Data from Regulatory Systems Many data systems in USDOT are operated for administrative, regulatory, and enforcement purposes in which it is necessary to identify individual reporting units. Such data may not be publicly available on a routine basis, but the data are potentially available in identifiable form through such means as documentation for regulatory hearings and judicial proceedings.
From page 95...
... , which operates data programs that were developed by the Civil Aeronautics Board when that agency regulated the airline industry with respect to entry, pricing, and related matters. The airlines were deregulated in 1978, but the data programs continued under provisions in the Code of Federal Regulations that specify reporting requirements for the airlines and the availability of data series.
From page 96...
... Implications for BTS Given that a statistical agency is not an administrative, regulatory, or enforcement agency and that central to its mission is a commitment not to release individually identifiable data, we are concerned about the placement of the Office of Airline Information and the Motor Carrier Statistics Program within BTS. The continued operation of data programs within BTS that require release of data in identifiable form poses a risk to the evolution of BTS as a statistical agency that can credibly pledge confidentiality to survey respondents.
From page 97...
... It should also incorporate statistics derived from the data in its electronic and printed products and use the data as appropriate to develop indicators, but it should not operate the programs so long as there are provisions to release the data for individual reporting units. ATTAINING LEADERSHIP As the statistical agency in USDOT with a broad mandate to improve transportation data, BTS should have leadership responsibilities in such areas as developing department-wide data quality standards and coordinating the collection of transportation data with agencies inside and outside USDOT.
From page 98...
... (11) BTS should review the Office of Airline Information and Motor Carrier Statistics programs, which provide for the release of individually identifiable data, for their compatibility with the BTS mission as a statistical agency that is committed to confidentiality protection.


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