Freesteel Blog » 2012 » February
Monday, February 27th, 2012 at 12:42 am - Whipping
Too tired to do any blogging and stuff, esp after this nicar event. I’m going to try and upload some processed pictures and get going.
Here’s from outside Union Station (they’re all called “Union Station”) in Kansas City (which is not in Kansas). It is a very fine station, except the access to the half dozen trains a day is along a concrete catwalk bolted on the side of the building between it and the multistory carpark. Clearly not the way it was envisaged originally.
As it was a train change I had an hour to cross the road to the very large and odd WW1 war memorial with these winged sphinxes covering their faces.
At the end of one of the presentations the speaker told us that we absolutely must go to the City Museum because it was the sort of place you would not believe could exist.
It was perfect for cavers. And, being quite dark in the cave area with the Gormenghast-like 10 storey slide and interlocking spiral staircases, none of my photos could show it. I remain utterly astonished that I did not thwack my head once, so there must be some magical method in their madness.
Pretty much the whole of the city seemed to be in the Museum. At least all the children in city. The place was utterly heaving. There are these hamster tubes leading right up into the sky onto the wings of a suspended aircraft. It was beautifully crazy.
All day I was wondering how could enough people in one town ever think it was a good idea to build something like this out of welded metal for people to crawl around in? Then in the afternoon three of us went to the Gateway Arch and rode the washing-machine-drum-on-a-wire tram to the top, which at that point is a triangular tube rammed full of people experiencing a perceptible swaying motion in the wind.
Train ride to San Francisco tomorrow. Actually one train, a bus and then the California Zephir all the way to the end. Here we go again.
Dropped back my 24 bike hire before noon today (cost $38), now packing my things and food for journey to Missourri.
Ho hum. Only 2 days since last explosion, I mean email cockup.
Trying to orient myself with some St Louis news. Expecting to make it back here in March for more of a holiday, and not so much work — though I have promised that some machinining algorithms will get done for HSMWorks, and I don’t deserve a holiday until I can demonstrate some progress.
Meanwhile, back at the other programming project, a new fad of Behavoir Driven Development has swept the table. This of course looks like it’s modelled on the same idea as Behavoirism, which was an early 20th century theory in psychology which said that brains were nothing more than stimulus-response devices with no internal cognition or conscious thoughts or beliefs, for example. Evidently cannot be entirely true, like so many all-encompassing theories. But the appropriate domain of application is not going to be discovered when the doubters are condemned as “uncomfortable”.
In the brief time I have before lunch and catching the Number 10 bus I am hereby proposing the next revolution: Cognitive Driven Development. With CDD we imagine that people a mental model of what is going on in the IT system, which guides them in their expectations of what to do to achieve the outcomes. Then we codify this mental model as closely as we can in a high-level programming language (or simulate it if there is a more appropriate internal model in the computer).
Hey, maybe we can also test code by verifying the computations of the model using assert statements, like we did in the old days — and more importantly expand and communicate and explore alternative models in terms of their structure, rather than in the form of cognitively-cleansed behaviour tests that are like wordy exam questions that you have to sweat over to make sense of what exactly they are getting at.
It would have really been cool if those BDD systems like lettuce and tomatoe were written using BDD throughout because then it would have taken until 2015 for them to be completed.
Popped into the Santa Monica library yesterday and thumbed through a copy of the March 2012 issue of Technical Analysis of Stocks & Commodities
Got a question about options?
Question: Being relatively new to options, I’m paper trading various strategies… One position that’s stumped me is a long butterfly using two contracts…
Answer: …In regards to your dilemma, the modification is often called a “broken wing butterfly.” The profit center of the butterfly, just like a regular fly, is the purchased spread minus the initial debit. But the bear call spread of bull put spread sold is designed using a wider strike distance. The result is the associated risk with that vertical will siphon the long vertical’s profits by the extra difference of the larger spread if the shares jump above or below that vertical’s purchased outer wing.
The other pages of this magazine contained large amounts of program code, the like of which I had not seen since the computer games magazines of 1983.
What are you supposed to do? Type it in? Some of it doesn’t even work, because it’s in pseudocode.
Wouldn’t it be cool if they used ScraperWiki?
Well, that was an interesting time with the HSMWorks crew at an expensive hotel in sunny San Diego, climbing into an apple pie bed every night and eating pancakes in the morning before attending SolidWorks World 2012.
Not sure entirely what SolidWorks World is; it’s part trade show, part product launch pad (like Apple used to famously do), and part training boot camp for users of the base software.
The law waits for no man, once it gets going. This is Part 3 where Part 1 was the first response. I forgot to drop Part 2 in the blog, but no one is probably interested.
According to the Directions ordered by the tribunal judge, I have to get this essay in by the 14th of February. Being as I am in California right now there is a good chance I would miss it by 8 hours. As you know, it’s unprofessional to hand anything in like this late. If you do, you have to send a begging letter to the Tribunal asking for an extension.
What’s even more unprofessional is handing in your Statement early, as I am doing, because that gives the other parties time to read it and rewrite their rebuttals to take account of it. I’d like to see them do that. I would have got this in three days ago if I hadn’t been stuck on the train or otherwise engaged in eating fancy steaks. I have had to reserve some slumber time to get this turned in.
FIRST TIER TRIBUNAL (INFORMATION RIGHTS) APPEAL UNDER SECTION 57 FREEDOM OF INFORMATION ACT EA/2011/0227
JULIAN TODD Appellant
– v –
THE INFORMATION COMMISSIONER Respondent
SECRETARY OF STATE FOR COMMUNITIES AND LOCAL GOVERNMENT Additional Party
WRITTEN SUBMITTION BY JULIAN TODD
1. This is my Written Submission in accordance with Section 9 of the 6 December 2011 Directions.
2. Since my 12 November 2011 reply to the Information Commissioner’s response and my 20 December 2011 reply to the Additional Party’s response I have received only the 1 February 2012 Open Witness Statement.
3. As neither the responses (which pre-dated the replies) nor the Open Witness Statement directly challenged or disputed the statements in my replies, there is no need to repeat their contents here. This Written Submission is therefore primarily a reply to the Open Witness Statement.
The Witness Statement
4. Following its introductory sections, paragraphs 11 to 15 of the Witness Statement set out the current regulations regarding the disclosure of EPCs. It is important to note that the regulations come as a consequence of a decision to enforce the determination to treat EPCs as personal data. In other words, the legal advice was procured for the dominant purpose of forming and amending the public regulations governing the register of EPCs. Whilst the public is legally bound to follow these regulations irrespective of what the legal advice contains, I would expect to have a right to know the basis and properness of the arguments developed by the legal professionals to justify the regulations, as would normally be the case had the regulations been debated in Parliament.
5. Paragraph 15 of the Witness Statement has been redacted, presumably to preserve the secrecy of the legal advice.
6. Paragraphs 16 to 20 of the Witness Statement explain that there have been two revisions of an original 2007 legal advice, in 2009 and 2010, due to inadequacies in each version. The Privacy Impact Assessment of 28 January 2011, included in the Open Bundle and also referenced in paragraph 30 of the Witness Statement, points to a further more complete over-haul of the legal advice.
7. The multiple times this advice has been sought provides the first possible explanation for the discrepancies relating to the authorship of the advice.
8. Paragraphs 21 to 26 of the Witness Statement provide an account of the 2010 consultation based on the 2010 version of the advice, which appeared to have determined that the EPCs constituted personal data.
9. Owing to the change in government, change in policy and evident change in legal advice, the January 2011 Privacy Impact Assessment reviewed the responses to the 2010 consultation even though the responses had been to a different set of questions (drafted on the basis of the more restrictive 2010 version of the advice that the EPCs were personal data for which there could be no option of disclosure).
10. Paragraphs 27 to 30 outline the liberalizing process that has been applied to the legal position which lead up to the 2011 Privacy Impact Assessment. However it does not clarify whether it was based on the 2010 version of the advice, or if that advice had been considered obsolete.
11. Paragraphs 31 to 32 outlined the handling of my FOI request without reference to the issues as to satisfying Section 1(a) of the Act wherein I would have expected to have been informed of the existence of information of the description specified – in particular the identity of the separate documents.
12. Paragraph 33 of the Witness Statement comes close to challenging my assertion in paragraph 11 of my 12 November 2011 reply to the Commissioner that LPP is waived due to a substantial disclosure of the advice. In particular, the witness disputes that the PIA I quoted from made any reference to the existence of legal advice. However, the tone of its language, citations of the EHCR and the Data Protection Act, the listing of the Data protection principles in Annex D of the consultation, and standard operating procedure were sufficient to lead me to believe that there must be a legal opinion underpinning the policy outlined. This supposition was confirmed in the response to my FOI request. Without access to the original legal advice documents I cannot be certain of the overlap. However, given the number of revisions that have been undertaken as result of predictable circumstances, the different versions of the advice are probably not very robust and complete.
13. Paragraph 33 also repeats the crucial statement from the PIA by stating “that whether or not address level data was personal data was ‘not clear cut’, but that a choice had been taken to treat it as such…” The reason this statement is crucial is that it is central to the purpose of my FOI request. Every single consultation document and policy proposal until now has pretty much assumed that the privacy status of EPCs could not be questioned because it was a matter of law. The government is perfectly entitled to receive legal advice and take what it believes is “by far the safest course of action” when it chooses its policies and writes regulations. However, there should always be as much clarity as possible in distinguishing what it chooses to do and what it is legally required to do, in order for the public to participate in a discussion about the policy within the appropriate framework.
14. Paragraph 34 goes on to outline the justification for the FOI Section 43 (Legal professional privilege) in general terms (including needlessly providing an argument against routine disclosure of all legal advice) — without dwelling on the specific aspects of the requested information, such as the fact that it relates to the interpretation of a public Act of Parliament and has nothing to do with litigation.
15. There is, however, evidence in the numerous reviews of the advice and radical shifts in policy that the requested advice has never been been particularly full and complete. All along I have pointed out its likely shortcomings in terms of the unexplained incompatibility between the handling of the EPC data and of other building related data held by the Land Registry. I have repeatedly requested completely not-sensitive evidence to prove the contrary (eg a section from the preamble of the advice stating that the lawyer has taken into consideration the practice of handling this other Land Registry-held data). These communications were routinely ignored.
16. If the purpose of confidentiality is to promote and assure the quality and robustness of the legal advice, then in this case it appears to have failed. In fact, with regards to advice of this nature, which is concerned only with the interpretation of the Data Protection Act for the purpose of forming regulations in the handling of a government database, and which was never intended to be used for any kind of litigation, publication would more likely lead to better quality advice because it could be subject to independent scrutiny and would not require a change of government to provide a fresh set of eyes.
17. Paragraph 37 of the Witness Statement confirms that in any event the requested advice is no longer relevant.
18. In my three replies (including this statement) I have provided several strong independent arguments favouring disclosure in relation to the public interest test. To read statements that I have not done so, without reference to them, is dissatisfying. I look forward to reading the other Written Statements.
13 February 2012
After this wings its way through we move on to Section 10 of the Directions:
Any submissions in reply may be lodged with the Tribunal and exchanged between the parties by 21 February 2012.
Let’s hope it’s something interesting, and not the usual boring “The Appellant has not, to my mind, provided any such argument so as to favour the release of the disputed material.”
Well, that was easy. Two days on the train from Chicago. Unfortunately I had the worst seat in the carriage, opposite the stairs with the exit light bright as daylight that never turned off, sharing the double seat with a large guy and people tripping over my toes at night when I stretched them out into the aisle. It felt like I didn’t grab a wink, and I tended to give up at five in the morning and be first in at breakfast. The coffee seemed to get rid of my headache.
Wednesday, February 8th, 2012 at 7:11 pm - Machining
Just spending my very few hours between trains wandering around Chicago and dropping in on the amazing extraordinary public library here. All cities should be rated on the basis of their public libraries — more than just their public artworks (which are pretty interesting here too).
Onwards to California now. I better go get a good seat on the train as I will be in it for some time.
Saturday, February 4th, 2012 at 4:56 am - Whipping
In about 2 seconds — zip! — a 3 day long train ticket from New York to Los Angeles was purchased for $208. I went with Aidan to a noisy sports bar in Penn Station where his brother was having a beer with a golfing buddy. “Wot de fok’s wrong wid’ you?” he said.
On this train I am going to get some work done. I hope it doesn’t have WiFi.
Meanwhile, back at the hackathon, I spent the day doing PDF parsing. I got lucky. There were 120 documents all identically formatted with lots of numbers in them.
There’s another day of this tomorrow, so off to bed.
I got out on Saturday before my nasty travel-induced cold really took hold and laid me low. I was not surprised to find that most of the Underwater Rugby players round here are Columbian. One of them gave me a lift up to East Haven, Connecticut, which was a 3 hour drive north and then east. In spite of the huge population and development around New York, there are very few pools that they can play the game in. This pool was on a back street behind a school. It was a turn-out-the-lights-when-you-leave affair. The team coach was funny. Before the game he was like “It doesn’t matter how many points the other side scores, as long as you’re learning to play.” After the other team began to score, then the real strong critical coaching began. If it’s just you up against the goalee there is no excuse not to score. There’s a technique to levering them off the basket which inevitably caused me to bang my head against the pool wall. Quality entertainment. More like this please.
Have been working night and day (when not trying to rest) finishing off various webscraping duties. Must get moving on. A three day transcontinental train ride beckons. I have it in my tiny mind to move on to SolidWorksWorld. Why, I don’t know. Plans can always change.