Delinquent Interim Change Letters

[SarDragon]

Regulations mostly just state policy. Manuals are more detailed, and explain methodology for implementing the policies contained therein.

[JoeTomasone]

Regulations mostly just state policy. Manuals are more detailed, and explain methodology for implementing the policies contained therein.

Right - and so sayeth CAPR 5-4 -- mostly.   It only mentions policies in conjunction with regulations. 

"Regulations" announce policies, direct actions and prescribe standards.

"Manuals" announce procedures and guidance for performing standard tasks and usually contain examples.

..You can't equate the two from a mandatory compliance perspective unless you are trying to fit the language therein to a predetermined conclusion.

[RiverAux]

We've got 6 ICLs from 2007 and 12 from 2008 that haven't yet been turned into regulations.  Just a reminder, CAPR 5-4 requires that ICLs be turned into regulations within 3-6 months depending on the type of change being made. 

I had occasion to visit the ICL site today http://members.gocivilairpatrol.com/forms_publications__regulations/interim_change_letters.cfm and happily noted that the problem I identified back in 2009 seems to have been solved.  At that point we had 18 ICLs that had been around for longer than allowed by CAPR5-4, with 6 more than 2 years old. 

Now, we really only have 4 regulations with ICLs to them at this point, 3 of which were only issued in 2011.  So, thank you NHQ/BOG/NEC for more or less eliminating this issue. 

Unfortunately, we have 4 ICLs to 39-1 that are still current, some of which go back almost 4 years at this point.  But, if we assume/hope/fear/dread that a new 39-1 will be issued sometime in the next year we can probably consider the problem solved.