Okay, I finally got a response from the FOIA Office at the Department of Commerce regarding the processing of cases.
In their letter, they wrote that they use the regulations from the US Public Health Service (found
here).
"Since the NOAA Corps does not have an internal mechanism to process these cases, they are
outsourced to the US Public Health Service." (italics mine).
Outsourced? I am not done getting to the bottom of this. I have my doubts about the legality of "outsourcing" this function. My next request if going to be for the memorandums of agreement, and grants of authority to do this. Since NOAA falls under Commerce and
PHS under Department of Health and Human Services, I have serious questions about the processing of NOAA cases.