Draft CAPR 52-16, July '10 - Posted for Comment

[MIKE]

http://www.capmembers.com/cadet_programs/index.cfm/draft_5216_ready_for_review?show=entry&blogID=198

[Eclipse]

What is the schedule for publication?

I personally like the idea that regs will start moving to online references for quick updates,
however it is hard to comment on those until they are live.

In a number of areas, best practices have been changed to requirements.  Will the respective
SUI areas be updated to reflect this?

2-1C:
Standard of Training. Because no cadet unit can succeed without adult leadership, every
cadet unit should have at least two graduates of the Training Leaders of Cadets course assigned (see
paragraph 2-2a). If a unit does not meet this requirement, the commander must develop a plan for doing so.

You cannot mix "should" with "must" - either this is a requirement or it isn't. "Should" is specifically
defined by other regulations as optional.  You can't mandate an optional component.
Further, if you increase the mandate of TLC at the unit level, you need to increase
the mandate of providing more classes at the Group (currently authorized) or Wing level.
Unit CC's cannot run a TLC on their own (nor should they), and have little control beyond asking
up the chain, so requiring a "plan" isn't going to have much teeth, especially if the actual requirement
is optional.

There also needs to be some teeth or logic in who has taken TLC.  Two random empty shirts
won't mean much, and I can envision Wings distributing their "000's" with TLC among failing
units to check the box.

5-5b
This should be a bright line, no testing or proctoring by family members.

5-6
Should require written accommodation plan approved by the next higher HQ to avoid any
appearance of impropriety.  Also, there should be intermediate intervention before NHQ/CP
is contacted.  This circumvents several layers of echelon.

6-1
Why is "Flag Officer" specifically indicated vs. "General officer"?

6-2
Suggest designating a specific color cord for Cadet of the Quarter - that ends a lot of
discussion and confusion. (we've been working this locally, and would require a Wing policy right now).
Further suggest a standardized award criteria, or at least a framework with local latitude.

[davidsinn]

6-1
Why is "Flag Officer" specifically indicated vs. "General officer"?

An admiral is not a general officer. An admiral is a flag officer. A general is a flag officer.

[lordmonar]

5-5b
This should be a bright line, no testing or proctoring by family members.

Not possible in some units.

If we are going to bright line this...then we will have to bright line all instances of conflict of intrest....up to and including friends.

We already have ethics and core values in place that should take care of this.  Making it a bright line will not help.

5-6
Should require written accommodation plan approved by the next higher HQ to avoid any
appearance of impropriety.  Also, there should be intermediate intervention before NHQ/CP
is contacted.  This circumvents several layers of echelon.

What?

It says to go to the next higher HQ....that means unit goes to group, then to wing, then to region BEFORE it goes to NHQ/CP.

[Eclipse]

In this context, a star is a star.

Written this way we'll have Unit CC's bothering the navy because they'll think generals are not allowed.
We'd be better off using the O-7+ terminology.

[Eclipse]

5-5b
This should be a bright line, no testing or proctoring by family members.

Not possible in some units.

If we are going to bright line this...then we will have to bright line all instances of conflict of intrest....up to and including friends.

Then that needs to be addressed in and of itself.  If the only senior members in a given unit are all family members, this is likely
a bad idea on any level you choose - inbred leadership, potential nepotism, lack of growth outside the family, etc.  In the rare instance
where it really isn't an option, it's time for Group or Wing to provide assistance.

I have no issue with us having more bright lines - its what the program needs.

[Eclipse]

What?

It says to go to the next higher HQ....that means unit goes to group, then to wing, then to region BEFORE it goes to NHQ/CP.

Where?

5-6. Cadets With Special Needs. CAP will make reasonable accommodations for cadets who have
special educational needs. Unit commanders may authorize testing accommodations at their discretion.
Examples of accommodations include testing orally, extending time limits, dividing the test into segments,
and reducing the choices on a multiple-choice test. Before authorizing an accommodation, the unit
commander should discuss the cadet's needs with the cadet's parents. Most schools use an Individualized
Educational Program (IEP) to support special needs students. If a parent chooses to share the IEP
information with CAP, the unit commander will adhere to all reasonable accommodations set forth in the
IEP. If the commander and the cadet's parents disagree about the need for reasonable accommodations,
NHQ/CP may act as mediator and is authorized to mandate testing accommodations, if warranted.


The only mention of any higher HQ intervention is a direct-to-NHQ, and to a person who is not actually in the
chain of command.

I don't personally want my unit CC's making accommodations that haven't at least been vetted at the wing level to
insure they are reasonable and required.  This is a potentially very slippery slope, and could be abused very easily
with the best of intentions in mind.

Note my bolded in red...
Extend time limits by how much?
Reduce the choices by how much?

How many of us know a "good cadet who just can't get past the Mitchell test...?"  Objective testing is the core of the Cadet Program -
everyone is supposed to be equal on that level.  Taking an hour for a 20 minute test with only two choices for 4-choice questions isn't exactly equal.  As written the questions could be reduced to one answer.  You can't play the "common sense" card in this, not with tests.

I'd be surprised if CAP-USAF was consulted on this point, and they should, since it goes to the heart of the integrity of testing.

Who defines "special needs"?.  Documented learning disability?  Economic issue?  Just didn't have time to study?
In draft, it is the Unit CC, and since you're not in favor of a bright line for family members, what stops a Unit CC deciding
his son needs "special accommodation"?  Integrity? Yes.  The regs?  No.

That is not a power that should be in the hands of the Unit CC.  Worse, we're mandating the Unit CC adhere to an IEP, written by
people unrelated to CAP.  You think parents don't "play" those things to the advantage of their children?

Any "special accommodation" truly needed, should stand up to the scrutiny of review by higher HQ, and NHQ should only get involved
when the parents feel a mediator is needed.  Otherwise what are the Wing and Regions there for?

[A.Member]

First I want to say I appreciate the effort towards making changes to the regs because they do need updating/clarification.   That said, here is some of my initial feedback based on a quick once over...

Comments on Specific Changes
*  1-1 Drop "aerospace" prior to "leaders".  Our cadets are tomorrows leaders period.  While focus is certainly on aerospace we are broader than that.  Don't pigeonhole it into aerospace only.  1-2 elevates the aerospace emphasis appropriately.

*  1-2, so we're now mandating an optional program (AEX)?  That is a disconnect that needs to be reconciled.

* 1-6 is now confusing.  Do we have 4 elements or 5?  It says 4  but references a 5th (Activities) and subsequent sections reference the 5th (Activities).   Consider changing back to 5 elements or rework.

*  Concur with Eclipse on 2-1C.  "Should" and "must" cannot be mixed.   It's either a requirement or it's not.   Also, agree that compliance lies beyond the control of a squadron and without mandates at group and/or Wing levels this becomes problematic.  This item still needs more work.  Also, this seems to go more appropriately in section 2-2a.

*  2-5b – OK

*  In the summary High Adventure refers to 2-9, it's actually 2-10 otherwise OK.

* 3-1a - Requiring an annual open house is no guarantee of success or quality.  Reasoning indicates increased retention of first year cadets is a goal.   An open house does not address this and may further add to the perceived issue.  Remove this as a requirement.

  3-1b  - Agree on the orientation – setting expectations.  However, for units that don't use the material cited, how will adherence/success be measured?   

* 4-2 – Agree with the idea of goal setting but this reg is far too vague.  There must be consistency across squadrons in how they are measuring success.  Is SMART required or not?  It's unclear.  Again, "should" and "must" cannot be mixed in a regulation.  Do not implement until further defined.

* 4-3a – Agree with creating a schedule in advance but if a given format is not required, then reference a pamphlet or another publication rather than within the reg where it may be viewed as required (see 4-1a for a good example of how to make an external reference – it refers to CAPP 52-16).

* 4-4 – OK (this is valuable).  Consider suggesting outreach be done by senior member

* 4-5 – Agreed.  However, as it pertains to the rationale, I'd suggest that what really needs to occur is a shift in mindset by Wing staff to realize they are there to support the squadrons, not the other way around.   Such a change in mindset will help with more than just the o-flight issue.

* 5-3 - OK

General/Overall Comments:
*  Some of the rewrites provide some glimpse of rationale behind the regulation (ex. 2-10c Paintball).  I'm torn on this.  While I appreciate the explanation, I'm not convinced it's appropriate in a regulation.  It may lead to unwanted questioning of the rationale and ultimately the reg.  Seems to be too much mixing of handbook and pamphlet type comments with regulations.  Some OK, others perhaps not.

*  Also how was cadet feedback cited in the reasoning obtained?   We do not conduct exit interviews.   Was a formal survey conducted or are changes based on anecdotal evidence/observation?

*  What is a "CAPVA" – ex. 1-7 refers to CAPVA-100.  This is new.  Is this regulation?  Must it be followed?  This is undefined.

*  Still seems to be an overall struggle between ensuring program consistency – and hopefully quality – and that of flexibility. 

*  There is still virtually no real reference to the role of the Deputy Commander for Cadets within the entire reg.  This seems odd for a reg that is most likely directed at and read by the DCC.

* I'd also like to see some sort of a strategic plan (not necessarily a reg per se...although perhaps it falls under promotions) within the program for motivating cadets to achieve beyond the Mitchell.   My antecdotal observation is that this acheivement is often a point of stagnation.

[lordmonar]

Eclipse.....you are right....I misread what you wrote.  It thought you were quoting the reg....but you were making a suggestion.  I can read that the intent of the regulation is for CAP to work with the local school/health provider with the IEP...but as you say it does not mandate that.  I would support having at least wing approval for any accommodations.

2-1c.  You can mix should and must....in the way that it is used here.  Each unit SHOULD have 2 TLC trained members......it is not mandatory........Separate line.....any units that don't have have 2 must have a plan to fix it!

Come inspection time.....if you don't have two....you are not in violation of the regulation (provided you have a plan to fix it).    You DCC leaves and that drops you down to one....you identify your new DCC and schedule him for the next TLC (that is the plan).  All is good.

If you say each squadron MUST have two....then you must have more then two to insure that you NEVER drop below two if someone were to drop dead suddenly.

So....it is not incompatible to have should and must in the same paragraph.....in this case.

Overall I like it....including the explanations.....I would rather have a book full of expectations and goals then a book full of thou shalls and thou shall nots.

We need to be flexible in how or what we do....(paintball and rappelling for example).  Before Thou Shall not rapell except at DoD facilities....is now replaced with a broader guideline of what is really intended....."don't be chucking your cadets off of buildings with binder's twine....but you can use the local ropes course or climbing gym."

It allows us to use our local resources better while still keeping us on the safe side of liability.

The BSA exemption to rappelling still needs to be better spelled out. 

One local commander here in NV read that to mean that if you do rappelling under the BSA hat....you can't wear CAP uniforms at all......but under the BSA duel charter chapter they clearly say that we are always CAP...and must wear the uniforms....but there are some times where we have to buy BSA insurance.

[dwb]

*  What is a "CAPVA" – ex. 1-7 refers to CAPVA-100.  This is new.  Is this regulation?  Must it be followed?  This is undefined.

CAPVA = CAP Visual Aid.  They're referring to the "super chart", the big poster of CP requirements.

[DakRadz]

So I notice the new wording of the CAP-JROTC relationship section states "on uniforms requiring a wing patch" when defining which AFJROTC uniforms can be worn to CAP. So is this saying that any uniform can be shared? I see that as referring to BDUs.

[NC Hokie]

Two cents don't buy much, but here's mine:

2-1.c.  As mentioned before, the requirement that a unit commander must develop a plan to get two TLC graduates has no teeth, as TLC is not something that the unit commander has any control over.

3-1.a.  This idea has no teeth as written, as planning a recruiting campaign is NOT the same as executing it.  I can plan lots of things without actually doing any of them.

3-1.b.  This is just my opinion, but let's not beat around the bush.  If NHQ wants all of us to adopt pipelining and the Cadet Great Start model, they should come out and say so.

3-2.a.  I like having options, but the simple fact of the matter is that there is no easy way to access ALL of the data captured on the CAPF-66 in eServices.  An online CAPF-66 that collects it all in one place would be a tremendous resource for all of us.

4-5.  The 90 day mandate may be too aggressive.  Six months may be a bit more realistic.

5-2.a(3)  In my opinion, this needs to be a "may" instead of a "will,"  as the general expectation should be that cadets get it right the first time.

5-4.d.  Change the wording from "at least seven days" to "seven days" since the system automatically removes the lock-out on the seventh day.  Also, change "senior member" to "commander or testing officer."

5-7.  I have always wondered why we test cadets on drill, but are not required to capture those results anywhere.

[Bluelakes 13]

Great comments folks, but are you also sending them to Curt?

I like that we finally have published requirements for RCLS. Will negate some difficult conversations I was going to have soon.  But the suggested curriculum is not listed yet.  Hopefully soon.