Challenging Bill Proenza's QuikSCAT numbers

By: Dr. Jeff Masters , 5:04 PM GMT on July 04, 2007

A political storm engulfed the National Hurricane Center this week, with a majority of the senior hurricane forecasters calling for Bill Proenza's removal as director. The most visible issue revolved around the extraordinary focus on the aging QuikSCAT satellite. The public argument put forth by Mr. Proenza was that QuikSCAT data was so vital to hurricane track forecasting that without it, track forecast errors would increase significantly, leading to larger warning areas and increased costs for evacuation and emergency planning.

Focus on QuikSCAT--out of proportion?
On March 16th Proenza went public with the QuikSCAT concerns and associated statistics for the first time, stating that "two- and three-day forecasts of a storm's path would be affected. The two-day forecast could be 10 percent worse while the three-day one could be affected up to 16 percent," with the conclusion," that would mean longer stretches of coastline would have to be placed under warnings, and more people than necessary would have to evacuate." As a result of these comments, a perception arose in the public and among lawmakers that without QuikSCAT, NHC would not be able to provide accurate hurricane forecasts. Legislation was hastily introduced into both the House and Senate to provide an immediate replacement for the $375 million satellite.

Proenza's statements raised several questions: 1) Why the focus on track forecast errors in landfalling situations, when QuikSCAT was widely known to be used in intensity forecasting and for tropical cyclones too far at sea to be accessed by the Hurricane Hunters? 2) Could such specific and significant gains in track forecast error truly be attributed to QuikSCAT? Where did these numbers come from, and why was no uncertainty being attached to them?

Since QuikSCAT data became available, starting in 1999, average track errors for 48-hour and 72-hour forecasts have been reduced by 43 miles and 62 miles respectively. Fully one quarter of this improvement was being attributed by Proenza to QuikSCAT. This was an extraordinary performance increase to attribute to one satellite, and seemed doubtful.

We find out where the QuikSCAT numbers came from
In mid-June, Margie Kieper and I asked Proenza to comment on how he got his QuikSCAT numbers. He cited an unpublished study, "A Two Season Impact Study of Four Satellite Data Types and Rawinsonde Data in the NCEP Global Data Assimilation System", by Tom H. Zapotocny, James A. Jung, John F. LeMarshall and Russ E. Treadon. I contacted one of the authors, who informed me that the study was submitted for publication on January 26, 2007, and accepted for publication in the journal Weather and Forecasting on May 23, 2007. It will probably appear in the October-November time frame, according to the publisher. This raises an immediate problem, since only a privileged few are able to read unpublished research. This limits the possibilities for an informed debate on the issue, and basing important policy decisions on unpublished research is thus normally to be avoided. However, making accurate hurricane forecasts is important enough that such considerations can be excused. Proenza didn't give me any details on the study, other than the fact that QuikSCAT data improved 72-hour and 48-hour hurricane track forecasts by 16% and 10% respectively, for a select group of storms from the 2003 hurricane season. One of the authors graciously sent me a copy of the study, though, and after reading it, I had these observations:

1). The study looked at a very limited number of cases over a six-week period during 2003--only 19 cases were available for 72 hour forecasts. The 19 cases were not 19 storms, just 19 separate forecasts from the 4 hurricanes and 2 tropical storms that occurred during the 6-week study period. This sample is too small to draw definitive conclusions about the impact of the QuikSCAT on tropical cyclone forecasts. The two longest-lived storms during the test period were Fabian and Isabel, storms that spent the majority of their lifetimes far away from land. Since the quality of the observing network increases close to land, particulary when reconnaissance data from the Hurricane Hunters is available, it is reasonable to conclude that the impact of the QuikSCAT data for storms within 72 hours of landfall would be less than for the sample as a whole. The study was not primarily designed to study tropical cyclone track accuracy, so there was no separation out of the cases we really care about--storms 72 hours or less from landfall.

2). The study was done with only one model, the GFS. NHC official forecasts make use of several models, including the GFDL, UKMET, NOGAPS and ECMWF. Consequently, a change in the accuracy of a single model will have only a partial effect on NHC official forecast accuracy. As far as I know, there have not been studies done of the impact of QuikSCAT on tropical cyclone forecasts in the GFDL, UKMET or the ECMWF models. Past studies on the impact of dropsonde data from the Hurricane Hunters, however, show that the GFDL is less sensitive to these data than the GFS is.

3). When I attended the AMS hurricane conference in May 2006 in Monterey, I came across a poster presentation by Dr. Jim Goerss that evaluated the impact of QuikSCAT on the NOGAPS model. His study was far more comprehensive, and included 12 hurricanes, 5 typhoons, and 7 tropical storms from a 6-week period in 2004. The number of cases was 212 at 72 hours, eleven times as many as the study Proenza cites. Dr. Goerss found that QuikSCAT probably improved 24-hour track forecasts by 2.5% (90% confidence of this), but at all other forecast times (48, 72, 96, and 120 hours), QuikSCAT had no statistically significant effect (i.e., zero effect).

It is hard to compare the results from these two studies, since they used two different data assimilation systems. We do not know if they used all the data, or how they treated the vertical impact of the data. The uncertainties are high, and Proenza's simple statement that QuikSCAT data improves hurricane tracks forecasts by 10% and 16% is unreasonable, without at least making mention that these numbers are highly uncertain.

I believe that NHC official forecasts for landfalling storms in the Atlantic would not be significantly affected by the loss of the QuikSCAT satellite. I can't think of a hurricane scientist out there who would defend using a study with only 19 cases that didn't focus on landfalling storms, to make the case Proenza is making--particularly in light of the data from the unpublished Goerss study showing no effect of QuikSCAT data on NOGAPS model tropical cyclone track errors. Proenza should have at least attached some measure of uncertainty to his numbers, which he did not.

One could argue that the study cited by Proenza has undergone peer review, and is thus the only scientific study one can use to make arguments on QuikSCAT's effectiveness. The Goerss study has not been published in a journal, and has not undergone peer review. However, Proenza was making his QuikSCAT accuracy arguments in March, two months before the Zapotocny study he cited had been accepted for publication.

QuikSCAT misconceptions
The numbers pushed by Proenza have led to some potentially serious misconceptions about QuikSCAT. The Congressional Record has this to say about QuikSCAT:

"A single plane gathering data is like a tiny fishing line collecting data only along the single strand of the line. The satellite, on the other hand, provides rich, detailed data horizontally from one side of the storm to the other side, and vertically, from the ocean surface to the top of the storms swirling winds. The QuikSCAT is like a detailed MRI."

Well, QuikSCAT is not like an MRI, it just measures the ocean surface winds. In a letter written by Representatives Melancon and Klein in support of H.R. 2531, there are comments that data from the reconnaissance aircraft are inferior to the data from the QuikSCAT:

"Short-term options for replacing QuikSCAT include hurricane hunter aircraft, buoys, and foreign satellites--all of which will collectively produce inferior data."

There is not a hurricane forecaster anywhere that would trade hurricane hunter data for QuikSCAT. Lawmakers may start cutting aircraft reconnaissance with misconceptions like this. That would be a disaster.

I would hate to lose the QuikSCAT satellite, and have been calling for a replacement since before Mr. Proenza came on the job. QuickSCAT data is invaluable in identifying weak systems and in defining storm structure, particularly of outer wind radii of 34 knots and 50 knots. This is particularly true outside of the Atlantic, where there are no Hurricane Hunter flights, and in the Atlantic beyond where the Hurricane Hunters can reach. Track forecasts for tropical cyclones in the Pacific and Indian Oceans may benefit from QuikSCAT data, since Hurricane Hunter information is not available. QuikSCAT also helps identify when a tropical depression or tropical storm is intensifying.

Besides hurricanes, the QuickSCAT data is invaluable to the Ocean Prediction Center, which now issues hurricane force wind warnings for extratropical storms in the Atlantic and Pacific. Search and rescue missions, and the U.S. Navy also greatly benefit from QuikSCAT. QuikSCAT should be replaced, but not due to a rush knee-jerk reaction that will get us a replacement with old technology. NHC needs a "next-generation" scatterometer, one that has greatly improved capabilities to help tackle the structure and intensity problem. We should take our time, and deal with a gap in coverage, if it gets us an instrument that has higher resolution, higher saturation speed, and is not adversely affected by rain. Such a gap would not put the public at risk.

It greatly troubles me that the most visible and admired member of my profession has failed to use good science in his arguments for funding a replacement of the QuikSCAT satellite. The Director of the National Hurricane Center needs to be an able politician and good communicator, but being truthful with the science is a fundamental requirement of the job as well. Mr. Proenza has misrepresented the science on the QuikSCAT issue, and no longer has my support as director of the National Hurricane Center.

Other critical concerns--lost in the hubbub?
We strongly support many of the valid concerns Proenza has raised. Of particular concern are the slashing of critical research funding for the Joint Hurricane Testbed (JHT) from $1.7 million to $1 million, and the lack of adequate yearly increases to the National Hurricane Center budget. Both of these important concerns still remain to be addressed; they were quickly overshadowed by a frantic campaign by lawmakers to fund a new QuikSCAT satellite. The JHT provides the means for promising research to be tested in the NHC operational environment, usually resulting in a successful transition to an operational product at NHC. This program has been extremely successful, and its budget should have been increased, not slashed. As hurricane activity has increased dramatically over the last twelve years, NHC's budget should have increased accordingly, but it did not.

Proenza also raised legitimate concerns about NOAA's effort to promote their "Corporate Identity" by renaming the National Hurricane Center and National Weather Service. The new organizations would be called the "NOAA Hurricane Center" and the "NOAA Weather Service". He also justly complained about NOAA's plan to spend between $1.5 million and $4 million on a "bogus" 200-year NOAA anniversary celebration.

While wanting to take a neutral stand as to whether to call for Proenza's dismissal, Senior NHC Hurricane Specialist Lixion Avila clearly shares the concerns that have been put forth by the other senior forecasters Richard Pasch, James Franklin, and Richard Knabb, and former director Max Mayfield. Avila noted, "If I [was] the director of the hurricane center, I would not spend my time fighting for QuikSCAT--I would be fighting to make sure that the reconnaissance planes are always there." That leaves a vacationing Jack Beven as the only senior hurricane forecaster to not comment publicly on the issue. Max Mayfield has refrained from making public comments on the deteriorating situation these past months, but all of his comments in the Miami Herald article lend support for the hurricane forecast staff. Given his previous experience in the position of NHC Director and his successful tenure, his feedback counts tremendously.

With the busiest part of hurricane season just a few weeks away, expect a decision on Bill Proenza's tenure to be made soon.

Jeff Masters and Margie Kieper

Having lost the support of most of his senior forecasters, and having misrepresented the science on the importance of the QuikSCAT satellite on hurricane forecasts, it would be best for Mr. Proenza to step down as director of the National Hurricane Center.

--Jeff Masters

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1114. Drakoen
2:44 PM GMT on July 05, 2007
Seems 96L did do something though. The sal was further South before 96L came though. Now waves coming of Africa won't be directly affected by SAL (in the short term)
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1112. Melagoo
2:44 PM GMT on July 05, 2007
....is there a slight chance this could reorganize ... just a question

Link
Member Since: July 31, 2006 Posts: 19 Comments: 1655
1111. IKE
9:40 AM CDT on July 05, 2007
But the NAM flip-flops badly. Makes it hard to believe what it says on tropical systems.
Member Since: June 9, 2005 Posts: 23 Comments: 37938
1110. MisterPerfect
2:38 PM GMT on July 05, 2007
Posted By: franck at 2:33 PM GMT on July 05, 2007.

Most science bureaus, like every other entity in a pure capitalist state such as ours, are comprised of political hacks and technicians who actually do the work. When computer systems take over, the technician is surplanted, leaving figureheads to interpret information. The bureau eventually fails.


Can you name me a few science bureaus that have collapsed in the past because of technical upgrades and employee downsizing?
Member Since: November 1, 2006 Posts: 72 Comments: 20205
1109. Drakoen
2:39 PM GMT on July 05, 2007
Posted By: jphurricane2006 at 2:37 PM GMT on July 05, 2007.

the NAM should not be used as a tropical model, well because it isnt one


true but it can pick up on low pressure areas or developing low pressure.
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1108. weathersp
2:35 PM GMT on July 05, 2007
I don't care (not to be critical) what is going to happen off the coast of Florida. first it will bring rain, which is good for that area, then it will just move out to sea and dissipate. Its not something worth watching
Member Since: January 14, 2007 Posts: 17 Comments: 4140
1106. IKE
9:34 AM CDT on July 05, 2007
Posted By: MrNiceville at 9:34 AM CDT on July 05, 2007.
Isn't what's developing off the FL east coast what NAM picked up yesterday (or Tuesday)?


It had a low developing off of the west coast of Florida. Now it has it developing off of the east coast of Florida and heading NE.

The NAM model is as reliable as throwing darts at a dartboard. It has it going here...here....there....back here...back there...out to sea.
Member Since: June 9, 2005 Posts: 23 Comments: 37938
1105. Drakoen
2:35 PM GMT on July 05, 2007
here the NAM. The Low has moved to the east nover central/northern Florida
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1104. Thundercloud01221991
2:32 PM GMT on July 05, 2007
Posted By: stoormfury at 2:25 PM GMT on July 05, 2007.
latest quickscat shows 98L slowly limping on. but for how much longer.

Here is a picture of the tranquil atlantic this morning.Link


it is 96L
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1103. MrNiceville
2:32 PM GMT on July 05, 2007
Isn't what's developing off the FL east coast what NAM picked up yesterday (or Tuesday)?
1102. franck
2:23 PM GMT on July 05, 2007
Most science bureaus, like every other entity in a pure capitalist state such as ours, are comprised of political hacks and technicians who actually do the work. When computer systems take over, the technician is surplanted, leaving figureheads to interpret information. The bureau eventually fails.
Member Since: Posts: Comments:
1101. Drakoen
2:33 PM GMT on July 05, 2007
Posted By: weathersp at 2:32 PM GMT on July 05, 2007.

Hey drako what universe are you in? In mine it's July.

;)



mistake lol.
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1100. IKE
2:32 PM GMT on July 05, 2007
Posted By: WPBHurricane05 at 9:29 AM CDT on July 05, 2007.
Thanks for the update doctor. Seems like we will have another break from the tropics this week. Unfortunately this normally leads to debating.


Debating about...whether it's going to be another slow season vs.....it's early in the season. Give it time...August, Sept, Oct.

So far...*a yawner*
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1099. Drakoen
2:32 PM GMT on July 05, 2007
you can see the low open and borad now on the visible SAT imagery of 96L.
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1098. weathersp
2:32 PM GMT on July 05, 2007
Hey drako what universe are you in? In mine it's July.

;)
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1097. AndrewC75
2:32 PM GMT on July 05, 2007
Has no one noticed that this blog got Slashdotted?

Slashdot Article
1095. pottery2
2:30 PM GMT on July 05, 2007
Thank you, Dr. Masters.
1094. Drakoen
2:30 PM GMT on July 05, 2007
Posted By: WPBHurricane05 at 2:29 PM GMT on July 05, 2007.

Thanks for the update doctor. Seems like we will have another break from the tropics this week. Unfortunately this normally leads to debating.


lol.
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1093. WPBHurricane05
2:29 PM GMT on July 05, 2007
Thanks for the update doctor. Seems like we will have another break from the tropics this week. Unfortunately this normally leads to debating.
Member Since: July 31, 2006 Posts: 56 Comments: 8112
1092. Drakoen
2:28 PM GMT on July 05, 2007
Climatologically speaking the areas favored for development in the first 10 days of July are in the GOM and the Bahamas.
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1091. EdMahmoud
2:28 PM GMT on July 05, 2007
Mutiny at the Hurricane Center!


Despite the fact that my degree is in engineering, and everything I know about weather I read in library books and on the internet, or maybe because I am completely free from the NOAA bureaucracy, not having worked for the Federal government in 19 years, and because of my honest looks, and slight weight problem, my TV image would be of a honest, trusted, slightly gruff, but loveable guy who tells it like it is, I think I should be appointed to head the TPC.

I would add my Armed Forces Expeditionary Medal is worth points on the Civil Service exam, and I do well on standardized tests anyway, with a 1440 on my SATs in college.


I lived in Orlando back when I was at NNPS in 1984, and I liked it. I'm sure I could talk my wife into the move.
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1090. stoormfury
2:25 PM GMT on July 05, 2007
latest quickscat shows 98L slowly limping on. but for how much longer.

Here is a picture of the tranquil atlantic this morning.Link
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1088. Drakoen
2:24 PM GMT on July 05, 2007
Thanks for the update Jeff.
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1087. weathermanwannabe
2:24 PM GMT on July 05, 2007
Thanks Dr. M; you called this one right several days ago......
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1086. weathersp
2:24 PM GMT on July 05, 2007
Thanks for the update Dr.M!
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1085. Drakoen
2:23 PM GMT on July 05, 2007
that convection of the coast of Florida is part of a surface trough attached to a low pressure center over Florida. Upper level winds are 10-20kts over the area.
Member Since: October 28, 2006 Posts: 57 Comments: 32501
1084. Dr. Jeff Masters , Director of Meteorology
2:21 PM GMT on July 05, 2007
I added today's outlook on 96L to the bottom of my Bill Proenza post:

A low pressure system with a well-defined spin, near 11N 48W, has lost all of its heavy thunderstorm activity and no longer appears to be a threat to develop into a tropical depression. As seen on water vapor satellite loops, this system (labeled "96L" by the NHC) is surrounded by such a large area of dry air that it will be very difficult for it to mount a comeback. Wind shear is about 10 knots, and is forecast to increase to a hostile 20-30 knots by Saturday, further lessening the chances for 96L to develop. None of the reliable computer models develop the system into a tropical depression, and climatologically, formation of a tropical depression in this region of the Atlantic this time of year is unusual. NHC is no longer running their suite of computer model tracks on the system.

Jeff Masters
Member Since: May 7, 2001 Posts: 3242 Comments: 650
1083. weathermanwannabe
2:19 PM GMT on July 05, 2007
Good Morning Folks....Yes, 96L is just about gone and I'm back to blob watching.....
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1082. texascanecaster1
2:19 PM GMT on July 05, 2007
convective active and possible disturbance forming off florida coast. wind shear is actually low in that area. also 96l needs to keep moving ahead or even the low level swirl will die. Shear is going to increase there if it keeps moving west it should tecnichally start making convection.

1081. weathersp
2:16 PM GMT on July 05, 2007
The first one is a short term model and the 2nd one is the % of the deviation from average in the 8-14 day range?
Member Since: January 14, 2007 Posts: 17 Comments: 4140
1080. wederwatcher555
2:14 PM GMT on July 05, 2007
i know this is sort of off the whole cyclone topic. but can anyone tell me the difference between these forecasts

http://www.cdc.noaa.gov/map/images/ens/t850anom_us_alltimes.html

http://www.cpc.noaa.gov/products/predictions/814day/814temp.new.gif
1079. MissBennet
2:12 PM GMT on July 05, 2007
Yes. But you both said "a human". Can a more sofisticated tool ultimately bring an agency with 200+ workers down to a mere handful?

Ooo yes I see what you're saying. I thought you meant 'all computer generated' with no people involved, my missunderstanding.

I can't help but think that this is how the NHC operates right now, lots of computers with just a few people (maybe 20?) I can't imagine what they'd need so many for. (besides coffee and doughnut runners of course, even my office is guilty of that) Besides their funding wouldn't cover 200+ people and all that equipment



1078. weathersp
2:12 PM GMT on July 05, 2007
QuickSCAT

96L (or what's left of it)
Member Since: January 14, 2007 Posts: 17 Comments: 4140
1076. texascanecaster1
2:10 PM GMT on July 05, 2007
a it woulod not appear that 96 is finished just yet. B. look of the east coast of florida where the collapsing tip end of a front lies. It would appear something is trying to spin up there.
1075. texascanecaster1
2:05 PM GMT on July 05, 2007
morning all. I am unhappy that the models are showing that thing becoming chantal anbd moving near cuba as that could screw me in one of two ways. A it goes over the keys near the end of my vacation and completley screw that. or b it ethier does that or doesn't go that far north, goes into the gulf, and then hits southeast texas while i am gone like allison did. But this can only happen if it develops and i am still skeptic on that.
1074. MisterPerfect
2:05 PM GMT on July 05, 2007
Also, if a satellite is 99.9% accurate in predicting exact landfall of a hurricane, who shall we blame if a .1% error in accuracy kills hundreds of people?
Member Since: November 1, 2006 Posts: 72 Comments: 20205
1073. EdMahmoud
2:03 PM GMT on July 05, 2007
Earlier this morning, satellite derived winds were still near 30 knots for Tropical Disturbance 96L.

But since then, all thunderstorms have fizzled, and I'm not even 100% sure there is even a closed circulation.

NHC didn't run 6Z models, a suggestion that 96L may be dropped as an Invest disturbance today.


Well, if any kind of wave can survive until the Western Caribbean in about a week, it might find reasonably light shear near the Yucatan channel.
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1072. MisterPerfect
2:02 PM GMT on July 05, 2007
... but don't you need people to stand around the water cooler and someone to make coffee? What about pencil sharpeners too!

Now go and try to find out how many people are employed in Congress that "make coffee". Probably thousands.
Member Since: November 1, 2006 Posts: 72 Comments: 20205
1071. MisterPerfect
2:00 PM GMT on July 05, 2007
I doubt that computers will take over operations. Who makes the computers?? We do. There is and will always be a human forecaster at the NHC as long as its around.

I agree with WPB we will always need a human or two to at least interpret the data.

WPB05 & MsBennet,

Yes. But you both said "a human". Can a more sofisticated tool ultimately bring an agency with 200+ workers down to a mere handful? I am not proposing that one data device calls the shots, but one data device that does the job 200 men and women can do....its not far fetched.
Member Since: November 1, 2006 Posts: 72 Comments: 20205
1070. Melagoo
1:59 PM GMT on July 05, 2007
QUESTION:

Do you think its possible that senior forecasters at the NHC possibly think a new and improved satellite might endanger their job security? Think about it. Imagine a space craft with 99.9% accuracy in predicting exact hurricane landfall within 72-48 hours. Why would you even need a whole agency? I think the root of this Proenza scrutiny has to do more with tenure for the rest of the NHC excluding Proenza. Will the NHC one day be one or two persons, behind a computer screen? Maybe.


... but don't you need people to stand around the water cooler and someone to make coffee? What about pencil sharpeners too!

... actually you make a good point Mister :c)
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1069. CJ5
1:53 PM GMT on July 05, 2007
The dry air won out last night and unless something incredible happens 96L should die before nightfall.
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1068. MissBennet
1:53 PM GMT on July 05, 2007
I agree with WPB we will always need a human or two to at least interpret the data.

Computers aren't everything. I remeber back in 2004 and a couple in 2005 when the storm discussion pretty much said "we don't have models to help us predict what the heck this thing is doing, so get ready we're in for a fun ride" This was especially true with the cat 3 and aboves.

We need humans, if only to let us know that the computers are also stumped. =)
1067. CJ5
1:51 PM GMT on July 05, 2007
The Director of NOAA is trumpeting up the charges that Proenza's comments have eroded the public confidence in forecasting. That is BS and is only being used to oust him. The reality is that Proenze is stating facts. The SAT is old and on backup systems already. It could fail today, and its failure would lead to less reliable forcasting. That is information the public needs to know and the public also needs to know what plan NOAA has to reslove it. The bottom line is NOAA got called out and instead of finding a way to fix the problem they are on a witch hunt. Typical government.
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1066. WPBHurricane05
1:40 PM GMT on July 05, 2007
I doubt that computers will take over operations. Who makes the computers?? We do. There is and will always be a human forecaster at the NHC as long as its around.
Member Since: July 31, 2006 Posts: 56 Comments: 8112
1065. MisterPerfect
1:37 PM GMT on July 05, 2007
QUESTION:

Do you think its possible that senior forecasters at the NHC possibly think a new and improved satellite might endanger their job security? Think about it. Imagine a space craft with 99.9% accuracy in predicting exact hurricane landfall within 72-48 hours. Why would you even need a whole agency? I think the root of this Proenza scrutiny has to do more with tenure for the rest of the NHC excluding Proenza. Will the NHC one day be one or two persons, behind a computer screen? Maybe.
Member Since: November 1, 2006 Posts: 72 Comments: 20205
1064. GainesvilleGator
1:34 PM GMT on July 05, 2007
96L is surrounded by dry air on three sides. Can you say "choke out"? 96L hung on for a long time because it was small & just below the mass of dry air. Now its time to say goodbye to 96L.
Member Since: September 11, 2005 Posts: 4 Comments: 747

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