
You may recall and entry about a week ago titled: NOAA/NCDC Throws a roadblack my way.
Good news! NCDC has decided to restore the access. I think this is a wise move on NCDC's part not only because their initial argument was unsupportable as I demonstrated dozens of pages in various NOAA websites showing not only observer names, but also photos of the observers, but more importantly the timing made them look like they were actively hampering a science activity. Data sharing is a hallmark of science so that independent study and confirmation of observations and theories can occur.
I'm pleased that NCDC has changed their position. Its the right thing to do. I agree with their current position that provides the name of the observers, but keeps addresses and telephone numbers private.
For the purposes of the photographic investigation being done at www.surfacestations.org I point out that anyone in the project must agree to and follow rules of conduct, and respect the clearly spelled out privacy issues.
Here is the communication:
Dear Mr. Watts,
You made several inquiries recently regarding the availability of Cooperative observer names in the MMS system. I have received the clarification I needed in order to respond, and wanted to inform you of the results as well as to provide some background detail.
The names of observers participating the the National Weather Service's (NWS) Cooperative (Coop) Observation Program have for many years been published state by state in both the Climatological Data (CD) and Hourly Precipitation Data (HPD) publications. Individual Coop observer names have also appeared from time to time on various NWS web sites, often in the context of award presentations. However, as a practice, NCDC has not intentionally made the names public as part of its station metadata systems.
While the Multi-network Metadata System (MMS) has always included security restrictions to prevent guest users from accessing observer details, including name, an oversight permitted observer names to be viewed on the Station Identity form along with managing party identifiers. Based on our accepted practice, NCDC immediately corrected the condition that permitted such visibility, but soon received user comments indicating that people were indeed accessing the names and requesting that the field be restored.
Those inquiries and requests prompted NCDC to revisit their practices for handling Cooperative observer names, and to formally address the issue of privacy as it relates to those names. NCDC began with a review of the Freedom of Information Act and Privacy Act statutes, a related court decision, NCDC practices and existing documents, systems and sites at NCDC and other sources. With this background, NCDC requested that the Department of Commerce's Office of General Counsel (OGC) provide a legal opinion on the issue. That opinion follows:
"As you know, personal information can be withheld under FOIA Exemption (b)(6), which permits withholding of personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. A balancing test is employed to apply this exemption. Under this test, the privacy interest held by those identified in the records is weighed against the public interest in the information. In all cases, the public interest in disclosure of information about private individuals under the FOIA is limited to information that sheds light on an agency’s performance of its statutory duties.
For the names of weather observers that have been released, there can be no privacy interest because the information is already public. However, weather observers do have privacy interests in their home addresses. Release of this information could lead to unsolicited mail or even visitation by strangers. There is no public interest in this type of information because it does not shed light on NCDC's performance of its statutory duties. Accordingly, I would conclude that the addresses of weather observers is withholdable under b(6)."
The OGC's opinion is also the basis for a more concise NCDC policy regarding observer details, which is now posted on NCDC's web site.
Based on the revised policy, Coop observer names will be displayed in the MMS station metadata system, but address, phone numbers and any other details will not. Should requests be made for paper copies of previously submitted paper station history forms, all observer details except for name must be manually obliterated from each form copy prior to delivery, with the requester responsible for the cost of that manual work.
Access to the station managing party field in the MMS Identity tab's form view should be restored within one business day. In the long term, that information will probably be removed to a separate tab, but will continue to be available.
I hope this adequately addresses your concerns regarding NCDC's Coop observer name policy and availability of that information.
Sincerely,
Jeff Arnfield
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Jeff Arnfield
Station Metadata Project Manager