Saturday, March 23, 2013

A Paroxysm of Political Paranoia Paralyzes NOAA/NWS Participation in Science

A long-time friend brought to my attention the following statement of "ethics" for NOAA/NWS employees (copied here verbatim, in its entirety):

The following is a summary of Ethics guidelines which pertain to NWS employees attending professional conferences.  This includes conferences sponsored by organizations such as The National Weather Association (NWA), American Meteorological Society (AMS) and American Society of Engineers (ASE).  Everyone should be aware of these to avoid inadvertently violating government ethics rules and inappropriately using government resources for personal use.

Professional organizations hold conferences which NWS employees frequently attend as part of their official government responsibilities.  The NWS pays for travel to the event and the employees are on official time.  Employees frequently present research or papers which they have developed as part of their NWS responsibilities, or interact as a participant with others.  Here are the general guidelines applicable to all employees.

1.      Employees attending a professional conference at Government expense in their official capacity as an NWS employee must be on approved travel orders.   Authorized costs for the conference are to be paid by the government or approved gifted travel.  Employees may not pay all or part  of these costs from their private funds.

2.     NWS may pay conference registration fees for employees attending a professional conference in their official capacity as an NWS employee.  Employees may not pay these costs if they are attending on official time in their official capacity.

3.     Supervisors must certify that costs paid by the government to send the employee to the conference are in connection with the NWS mission and the employee’s responsibilities.

4.     Approval for groups of twenty (20) or more employees on domestic travel and ten (10) or more employees on foreign travel, including invitational travelers, regardless of whether or not NOAA is funding the travel must be submitted to the Deputy Under Secretary for Operations prior to travel to the conference.  NWS Deputy Administrator approval for meetings, conferences, symposiums involving less than these thresholds may still be required.  Please check with the Chief, ASD prior to coordination of travel and/or conference planning.

5.     Employees attending a professional conference who are not on approved travel orders must be on a day off or on approved annual leave.  No expenses will be paid by the government, including registration and/or abstract fees.  The employee will be in a private capacity and cannot present research or papers developed as part of their NWS responsibilities, nor represent NOAA/NWS.

In addition to the above, we’ve received additional guidance from NOAA Office of General Counsel regarding Ethics Issues for NWS personnel that serve on the boards of other organizations.  These restrictions are as follow:

1.     Persons serving on the boards of an organization are required to disqualify themselves from any NWS matter that could have an effect on the financial interests of that organization.

2.     You may not use any Government resources in connection with your personal activities with the organization.   This means that you may not use any duty hours or your NWS email account for any NWA, AMS or similar organization activities.  You may not use your NWS title for such activities either.  (For example, you may not list your NWS title or email address on an AMS or NWA website.)  You may not disclose any nonpublic Government information and you may not take any action to imply NWS endorsement of NWA, AMS or similar organization activities.  See 5 C.F.R. § 2635.701-705.

3.     Criminal statutes bar you from contacting NWS, or any other Federal agency or Federal court, on behalf of a professional organization, to influence Government action.  See 18 U.S.C. § 205(a).  For example, if NWA plans to recommend a policy position to NWS, you may not sign a letter to NWS and your name may not appear on the NWA letterhead, even if a different NWA officer sends the letter.

4.     You may only travel to an organizations conference on official time and at government expense  if your supervisor assigns you to attend, without your input, as part of your official responsibilities.  If you are assigned to attend a conference, you may only be a passive participant, meaning that you may attend all conference activities but may not be listed on the agenda as a speaker, nor may you present materials at the conference. 

5.     If you wish to conduct activities relating to your position within an organization while at that organizations conference in your Government capacity, you may only do so while off duty.  This means, for example, that you may meet with other officers of the organization in the evening, as long as you are technically off duty at that time.

6.     In the alternative, you may take leave and attend a conference in your personal capacity.  In that scenario, the Government cannot pay for your travel to the conference and you cannot use any Government resources (such as your NWS title) while at the conference.  While you would be permitted to present remarks or materials at the conference in your personal capacity, you would not be able to present scientific papers that you developed as part of your NWS duties.  Generally, you may accept travel payments from the organization (i.e., NWA)  if you travel in your personal capacity, but you may not receive any other form of payment (such as an honorarium from NWA) if any remarks that you deliver at a conference contain references to your Government duties or NWS programs or operations.  See 5 C.F.R. § 2635.807(a).  If you are offered payment of any sort, you should contact NOAA General Counsel to confirm that such payments are acceptable in advance.

This represents a dramatic break with previous ethical boundaries and will eviscerate any opportunities for NWS employees to participate in conferences, thereby representing a policy that threatens the very existence of the NWA and, ultimately, the AMS.  Once again, it seems that NOAA, acting through the advice of its General Counsel, is responding to political pressure in a way that is destructive to the NWS.

I have long considered NOAA to be a bloated bureaucracy of incompetent parasites.  But this attack on the scientific activities of NWS employees is both inexplicable and unconscionable.  What possible reason could there be for these ridiculous new policies?  What political pressure is creating this response from NOAA General Counsel?  What ethical abuses will this prevent?  Has it ever been shown that any abuses resulting from NWS employee participation in conferences have been detrimental to NWS forecasts or to the science?   Can anyone show there is any real need for this massive change in NWS policies regarding the participation of their employees in conferences?

Of late, attendance at scientific conferences by NWS employees has been on the wane.  Presumably, this reflects a short-sighted policy in response to budget pressures associated with federal budget deficits.  The recent tendency has been to reduce the presence of NWS forecasters at scientific conferences, where a good deal of the business of science takes place.  Some NWS forecasters have been participating at their own expense and on their own time - the new policies apparently will prevent even that!  This not only inhibits the dissemination of NWS research findings, but it limits the opportunity for scientific peers to provide direct feedback to the authors of that research.

The dramatic reductions in participation in science by NWS employees we have seen will pale to insignificance when these new policies are implemented.  The impact on the NWA, which is dominated by operational weather forecasters, could be devastating.  Even the AMS will suffer as a result of the non-participation of so many operational weather forecasters.

There can be no good reason for this unnecessary change in policy.  If NWS managers buckle under the pressure of NOAA management, this will constitute a huge blow to the entire science of meteorology, which has long struggled with the operations-research interface.  An "iron curtain" will have descended on that interface, to the detriment of all.  For shame, NOAA!