Tuesday, September 23, 2014

Consulting Services for FCHLPM: Sunshiny or Convoluted?

The state of modern science is such that one can legitimately piece it together in a myriad of ways to develop one's own unique perspective on a given issue.

This provides risk model vendors with with opportunity to develop their own secret sauce.  It  provides the vendor with their slice of the market and is therefore, fiercely protected.

Florida has "sunshine laws" which mandates that much of the government's going-ons, particularly meetings, becomes public record.   Florida's Sunshine Laws are in accordance with the Government in the Sunshine Act (1976) signed into law by President Ford.  It was introduced to the Senate- just after Nixon left office- by Florida's very own Lawton Chiles.  Presumably due to Nixon's legendary meeting secretiveness, the bill passed fairly quickly.

The Sunshine Act compliments the 10 years senior Freedom of Information Act (1966) which makes a bunch of government information public with some exceptions.  One exception is company trade secrets.  

So, there is a difficulty: Company's want to keep their information secret, FOIA allows them to, but once they have a "meeting" with public officials it becomes public information.  In order to resolve this difficulty in regards to catastrophe model vendors' secret science, the FCHLPM (those responsible for reviewing catastrophe model science) hold their meetings off public property at the vendors' office.

(Later today: It was brought to my attention that I may not be entirely clear on how FOIA and the Sunshine Law actually work.  However, I am still under the impression that the reason for site meetings [at the vendors' offices] is to avoid public disclosure of trade secrets.  As to how this legally works out, I'm not sure.  Some particulars on how and when FCHLPM things are exempt from public disclosure is here under section g.)   

However, models are becoming increasingly complex.  They have many more moving parts today then when first adopted by the industry in the early 1990s.   For example, under FCHLPM 2000 Standards, AIR submitted a report of 306 pages and under 2011 Standards the report was 404 pages.  

It takes a long time to review this amount of information perhaps longer than a site visit allows.  Besides, FCHLPM members have full time day jobs in addition to Commission responsibilities.  

To resolve this time consuming complexity problem (or so the story goes), the SBA has recently announced a request for consulting services
The SBA is seeking approximately fourteen (14) to sixteen (16) different vendors in seven areas of discipline (Meteorology, Structural Engineering, Coastal Engineering, Hydrology, Actuarial Science, Statistics, and Computer Science) to provide consulting services to the Commission. Respondents should be prepared to provide, at a minimum, the services described in the Report of Activities
The SBA financially administers the FCHLPM and the members of the commission are appointed by a mixture of statutory requirements and selection by the governor and state CFO.  The SBA is, ultimately, overseen by the Governor, the Chief Financial Officer and the Attorney General- all elected positions.  

Though the consulting services hired will provide their scientific evaluation to the FCHLPM who remain the decision makers, the consulting services, it seems, could be answering to the SBA.  

This adds a layer of non-transparency to the expert advising system.  In addition, it is unclear how much freedom of evaluation and access to information will be maintained by the FCHLPM.  Will the FCHLPM still be able to evaluate as they see fit or will their responsibilities be limited to decision making based only on the consulting services information? 

It is certainly not uncommon for a government agency to contract private expertise, demonstrated by by the colloquially termed Beltway Bandits.  But it is also not uncommon is for governmentally hired private expertise to produce information selectively favorable for their client.  

Clarification of who is the client helps improve transparency of potential incentives- particularly in situations of modeling science which is easily pieced together in different ways and really more theory than accepted knowledge, anyway.   

Improved transparency about how this new expert advice system will work is important for democracy and the continued integrity of the FCHLPM.  

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