Satu Hassi, MEP
Shadow Rapporteur, INSPIRE
European Parliament
Strasbourg, France

Dear Ms. Hassi,

PRIMET Comments re. Proposed INSPIRE Directive

In addition to fully endorsing the excellent comments and proposals for amendments (see attachment) to the INSPIRE Directive made by Chris Corbin, Director of Info-Dynamics Research Associates Ltd of the United Kingdom, the Association of Private Meteorological Services representing 32 private meteorological services in Europe would like to make the following remarks for your attention and consideration:

• to focus only on the public sector and to virtually exclude the private sector is ill-advised and short sighted since the number of private weather companies operating observational networks and numerical models producing gridded analyses and forecasts is steadily increasing as a consequence of technological developments;

• furthermore NGOs and voluntary groupings with similar activities are increasingly emerging in Europe and it would be unwise to ignore this new strategic component in the overall balance of spatial data;

• the catastrophic tsunami in Southeast Asia has been an excellent example of why any data infrastructure must enable the sharing of data in an interoperable way and be open to all data providers down to the grassroot level. The impact of the tsunami could be readily ascertained from remote imagery and the pollution was assessed and monitored using remote imagery combined with actual data on the ground. This activity used oceanic data, weather data and a whole raft of spatial data and technologies. During environmental catastrophes such as this there is a tremendous amount of good will from people (not Governments and their civil servants) across the world that are willing to assist by helping to do things remotely - this is also why we need freedom of access to data.

In spite of the implementation of the PSI and Environmental Data Directives, the overall situation as regards availability of weather information has not improved significantly in Europe. Weather data is available only through a complicated structure governed by ECOMET, an E.E.I.G. established by the European Meteorological Services, maintaining excessive price levels in order to hinder competition from private sector, whilst the public players are dividing the EU market by operating mainly in their respective countries.

The request from EUMET/EUMETNET/EuroGOOS (see footnote with URLs) to remove meteorological and atmospheric data altogether from the INSPIRE Directive should not be supported. The INSPIRE Directive should work in favour of an open and unrestricted flow of weather information which is vital for most human activities, and also provides better support for decision makers outside the weather community suffering today from poor availability of weather data due to pricing practices.

It should also be kept in mind that the EU heads of state and government at their March 2000 meeting in Lisbon agreed to make the European Union "the most competitive and knowledge-driven economy by 2010". However, although some progress has been made in boosting innovation and reforming the EU's economies, there is growing concern that the reform process is not going fast enough and that the ambitious targets will not be reached, as recently confirmed by a high-level expert group chaired by Wim Kok.

In the field of meteorology, an area with an enormous production of space- and surface-based data in real-time, two major steps have been taken since 1995 towards an environment which is less rather than more competitive:

• the approval by the World Meteorological Organization in 1995 of WMO Resolution 40, which distinguishes between "essential" data and products which are necessary for the provision of services for the protection of life and property and the well-being of nations, and "additional" data and products on which conditions for their re-export for commercial purposes may be placed (comment: virtually any experienced meteorologist would agree that such a distinction is unrealistic because of the chaotic behaviour of the atmosphere);

• the establishment of ECOMET, an Economic Interest Grouping of National Meteorological Services, and the associated issuing by the European Commission on 21 October 1999 of a protective "Comfort Letter" on ECOMET;

The environment created by the above two actions spearheaded by the National Meteorological Services (NMSs) in Europe has substantially reduced the capability of European actors to compete both within Europe and in the global meteorological market place.

Finally, rather than further strengthening the dominance of the public agencies that control environmental data whilst also involved in commercial activities utilising these data, steps should be taken towards more open and fair environmental data practices in conformity with competition law. In particular, public authorities should not be allowed to be involved in the formulation, implementation, monitoring and evaluation of policies whilst also engaging in the commercial utilisation of the information they hold.

In fact Article 23, para. 3 of the INSPIRE Directive under consideration clearly states that this kind of competition distortion by the European public weather sector should be prevented - in practice first and foremost by fully separating governmental public and commercial activities, it should be noted that the situation today is fully satisfactory in only one EU country, The Netherlands.

Yours sincerely,

Antonio Verga PRIMET Secretary General

Daniel Soderman Strategic Advisor to the PRIMET Secretary General

www.eurogoos.org/documents/EG04_45InspireEUMET_EUMETNET.pdf
www.eurogoos.org/documents/EG04_49LetterInspire.pdf