Delinquent Interim Change Letters

[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. 

Now, of these 18 delinquent ICLs, it can be safely said that perhaps only 1 is critical (removing rear seats from 15pax vans) so it isn't terribly urgent that they be turned into regulations.

Just as an update and in case someone is thinking of topics to discuss at the upcoming NB meeting, in the last 6 months we haven't turned ANY of the 2007 ICLs into regulations but did manage to clear 5 of the 12 ICLs issued in 2008. 

As it stands now:
Outstanding 2007 ICLs: 8
Outstanding 2008 ICLs: 7
Outstanding 2009 ICLs: 4

So, in one sense you could say that CAP made some improvements in 2009 in reducing the number of ICLs on the books though of course there probably are some things voted on by our various leadership boards in 2009 that haven't yet been turned into ICLs, so this isn't a real measure of regulation change over the year.

[Eclipse]

They are, at least, adding the verbiage at the end of ICL's now that indicate "this is in effect until the reg is updated", etc.

[Cecil DP]

They are, at least, adding the verbiage at the end of ICL's now that indicate "this is in effect until the reg is updated", etc.

In other words the CAPR 5-4 limitation of 180 days maximum is in effect unless we don't update the document in which case it isn't.

[alamrcn]

I just don't have the bal... guts to fall back on the original regulation once an ICL is past 180 days. Technically expired or not, we need to allow for SOME assumption of the intent of the ICL. Even "black and white" isn't ALWAYS black and white.

[Spike]

Big corporations do not operate on "letters".  Sure they may publish orders or addendum in memo format, but they are quickly turned into policy in the corporate rule books. 

When there are three letters that are; ordering, counter-ordering, and rescinding the counter order, something needs to change.

Time for NHQ to get a "federally funded" work-study student to start knocking these new regulations out.  Come on!

[bosshawk]

Ever heard of the "Golden Rule"?  He who has the gold rules and National holds the gold.  The folks at National are too busy to worry about putting out new regs, when the NB and NEC continue to make changes at about the same pace that you and I change underwear.

[Spike]

.....at about the same pace that you and I change underwear.

Monthly??   

[Gunner C]

.....at about the same pace that you and I change underwear.

Monthly??   

Not have a lot of friends? 

[JoeTomasone]

I find it hard to believe that 99% of the ICLs cannot be reflected in a revised regulation within one hour - and I'll be generous and allow for 6 more hours to have the updated PDF put on the web site.

We're talking about editing a document - this is not rocket science.   Well, maybe the Model Rocketry one is...   

The only thing that would require more time are things that might require pictures, such as some items in 39-1.    But, for example, the NB votes (for example) to make the Wing Patch optional on BDUs and to remove it from all other uniforms.  How long can it possibly take to do the actual work of writing that verbiage into the 39-1 PDF??   There's a change of what, 10 words?   Lets ignore the fact that an ICL is not supposed to be used for such things...

Perhaps the NB should vote to change the reg concerning the legal lifetime of an ICL...  Then we can see how long that takes to revise.   

[Fuzzy]

Having worked on a upcoming regulation, changing a regulation is a little more then typing something up at midnight while consuming a gallon of coffee and blasting it out over the internet.

Replacing 67-1 with an updated regulation also revises or replaces either totally or partially CAPR 67-4; CAPR 77-1; CAPR 87-1; and CAPR 100-2.

The revision also incorporates a significant change in two asset databases that CAP has. The data bases have to be tested to make sure the database will enable the requirements of the regulation.


Because the revision affects CAP assets; the revisions have to be reviewed and approved by the CAP financial staff and CAP-USAF staff. Legal has to approve changes that comply with US laws complying with the DOD grants by which we recieve funding for various assets.

There are some policy changes regarding property that are subject to review and input by CAP Command, IG staff, financial staff, the BOG, NEC, The National Board and CAP-USAF. Changes from any of the above still require coordination with the other bodies.

Day to day oversight of CAP assets is provided by the CAP-USAF  Logisitcs Officer with support from 8 CAP-USAF Liason Region Logistics Officers.As a part of that oversight,they also review the proposed changes

Still, we have ICL's for 2007 still not turned into regs. I really doubt anyone is actively working on the problem. Besides so what if they think its hard? They signed up for the job and we sort of need the correct info. Just do it.

Also it looks like some of these things shoulden't ever have been an ICL in the first place. Whats up with that?

[RiverAux]

I find it hard to believe that 99% of the ICLs cannot be reflected in a revised regulation within one hour - and I'll be generous and allow for 6 more hours to have the updated PDF put on the web site.

Absolutely correct.  The only thing that might hold things up a little bit is if the staff has to come up with the exact language for some of the more complicated things approved by the boards.  But even then that can't take too long.

Wholesale revisions such as what they've done with 60-1 and 60-3 lately are a little different and would require a ton of time. 

[JoeTomasone]

I find it hard to believe that 99% of the ICLs cannot be reflected in a revised regulation within one hour - and I'll be generous and allow for 6 more hours to have the updated PDF put on the web site.

Absolutely correct.  The only thing that might hold things up a little bit is if the staff has to come up with the exact language for some of the more complicated things approved by the boards.  But even then that can't take too long.

Wholesale revisions such as what they've done with 60-1 and 60-3 lately are a little different and would require a ton of time.

Quite frankly, that should be the FIRST step, and the NB should be voting on the proposed CHANGES, which, when approved, are updated in the affected Reg and published.

Your comment would suggest that they are voting on IDEAS, which then need to be codified.   That's not a good idea, as it leave the NB's intent to the opinion of the author of the revised regulation.   Imagine if Congress proposed a law as an idea, then passed it by vote, then had a clerk write up the actual law...  Plenty of room for interpretation issues.

The NB should decide that they want to change something -- remove the Wing patch, say -- then have the research done (does this affect other regs, what are the potential downsides such as member cost, etc), have a proposed rewrite done for each affected reg, then have it all read to the NB for a formal vote.   If it's approved, WHAM - publish that puppy.   This procedure takes time -- which is why the ICL procedure exists for matters that are so important (perhaps for safety reasons) that it cannot wait that long.   But again, it's being used for non-emergency purposes (like removing the Wing patch), and never codified into the Reg. 

"Lead by Example" comes to mind here.

[heliodoc]

Wholesale revision of 60-1??  Haven't done a real sit down with 60-3 yet, but that MIGHT have taken some time

The only wholesale revision was increasing boundaries from 50  miles to 100 miles and a few other gems.

AND separating mission profiles as a stand alone document, by itself, in the Stan Eval  side of the website

What did that take?  Six months of thought?  Maybe eighteen minutes of keystroking and hyperlinkin

Come on now, is that reallly something to be proud of ??

The whole thing thing is there ought to be drop dead date ON ALL CAP ICL's

Again corporate emulation of wanting to be like the military.......only CAP is rarely on time with regs.

Again, I know there are folks who are going to defend the actions of those "volunteers" at Maxwell.  There are more than enough paid staff there and enough work study students, as mentioned before, to get this done.

Anything more than 90 days old OUGHT tobe incorporate into regulation...Day 91 dropped.  Just like folks dropping the ball.

CAPers love to talk about IT and the ease of computer use as a Sqdn CC in other threads.  How hard is this stuff at NHQ-CAP??

Really how hard is it?  Everyone loves to talk inefficiencies in Government.  CAP is about  equal in those inefficiencies, and for an organization of approx 56,000, I'd think I'd be rather embarrased (sp) that things as "simple" as an ICL can not be agreed upon by NHQ-CAP, NB,and NEC in a REASONABLE amount of time. 

[Eclipse]

The whole thing thing is there ought to be drop dead date ON ALL CAP ICL's

Again corporate emulation of wanting to be like the military.......only CAP is rarely on time with regs.

To truly emulate the military, the expiration date of an ICL would simply be removed.
http://www.armyg1.army.mil/hr/Uniform/default.asp

Note the last line of some of these:  "Expiration date can not be determined."

[heliodoc]

Thanks, Eclipse

With that Army logic....and its numbers exceeding CAP and its ability to assist in Theater and now Haiti  Still makes the Army look like a mover while CAP is STILL standing still.......

Whats wrong with CAP's ability to do the same?

I'm still standing by what I have said......CAP still REALLY could improve on alll the basics...again this stuff isn't remotely hard at 56,000 pax compared to the reallll movers and shakers of the military and volunteer world!!

[lordmonar]

You are all correct that there is really no reason why these changes can't be made withing 15-20 minutes of the NB approving them.

Having said all that....who enforces the regulation?  It is the NB telling the NB what to do.  If they decicde defacto to ignore the ICL experation date...that is within the scope of their powers.

Why are we bellyaching?

Granted it can make our jobs a little bit harder to make sure we are following the regulations....but if it ever came to inspection or IG time.....we can legitmaly say "but that's not in the regulations" and press on.

[Eclipse]

Why are we bellyaching?

Granted it can make our jobs a little bit harder to make sure we are following the regulations....but if it ever came to inspection or IG time.....we can legitmaly say "but that's not in the regulations" and press on.[/quote]

Sort of. 

You could use that to make an excuse as to why you're not doing "x", but you'd still have to adjust behavior once notified.

[sparks]

I think all of us want to follow the regulations we're just having trouble figuring out what that is. The 0-2 and O-9 apparently only provides part of the story. Having copies of all of the National Board minutes now seems to be a requirement. Given the maybe or maybe not nature of the minutes keeping track of what's correct could take a full time senior members attention.

It is correct that an inspection finding could be deflected by saying it isn't in the regs. A side not on inspections, I have had inspection teams arrive with a new regulation published the day before expecting compliance, an unrealistic "gotcha" tactic.

[RiverAux]

Recently I have seen explicit guidance that if a reg has been updated since the last CI inspection manual was published, you are expected to be following the regulation.  Haven't seen it done on something that new though. 

[Eclipse]

^ Does it really matter?

If there's a finding which is trumped by an ICL or updated reg, you put that in your response.  Rinse, repeat.