Policy Letter Still Needed

[MIKE]

Do we still need an option for an official publication in a letter format that:

a. Do not expire until rescinded and,

b. Are not intended to become incorporated into an appropriate publication as the letter format is deemed sufficient for the application.

Versus:

4. Interim Change Letters (ICL). Situations requiring immediate action due to a state of emergency, an unforeseen circumstance involving the preservation of life or property, or other contingencies that may require prompt action may result in an interim change letter being issued outlining immediate policies. ICLs may be issued by any level of command unless specifically limited or prohibited by the regulation or manual governing that subject matter. Issuance of policies by ICL is a temporary measure.
a. ICLs outlining immediate policies to be followed for a limited time will be issued with a stated expiration date. Such expiration dates shall not be more than 180 days from the date the letter was issued.
b. ICLs outlining immediate policies that are intended to become permanent shall be incorporated into an appropriate publication within 90 days of the date the letter was issued.

[Eclipse]

Do you mean locally or nationally?

At local levels (wing or below), there is still a need for supplements and addendum as those will never be regulatory outside the AOR.

[DC]

Might be a good idea.

Last time I checked, whether our name tapes said 'U.S. Civil Air Patrol' or 'Civil Air Patrol' was any kind of emergency..

And now ICLs seem to just be an excuse to not update regs...

[IceNine]

We pretty much already have that.  there are ICL's that are still being followed that are well outside the 90 day window.

[MIKE]

Do you mean locally or nationally?

At local levels (wing or below), there is still a need for supplements and addendum as those will never be regulatory outside the AOR.

Both, but may be more applicable locally.  Something that is neither supplement, pamphlet or OI.

And now ICLs seem to just be an excuse to not update regs...

We pretty much already have that.  there are ICL's that are still being followed that are well outside the 90 day window.

Not how it is supposed to work.

[Eclipse]

To my understanding, the only thing we've seen since HWSRN left was corrections and reversals to his ICLs, which are going to take time to clean up.

Has there been anything else?

[RiverAux]

Do we still need an option for an official publication in a letter format that:

a. Do not expire until rescinded and,

b. Are not intended to become incorporated into an appropriate publication as the letter format is deemed sufficient for the application.

If it is not meant to be rescinded, why wouldn't we want to put it into a regulation, if it is regulatory in nature?  You don't have to put every single policy or guideline in how business is carried out into an ICL -- just those that actually change or modify a regulation. 

Say BG Courter writes a letter saying that all phones will be answered at the NOC as "Who's knocking at the NOC?", I don't know of anything that would require that this be put into an ICL or regulation, so it could remain as a letter from now until the end of time.

But, if you want to change the meaning of a regulation, you would need an ICL and there would be no reason that it wouldn't need the deadline as the intent would be to put it into a regulation when they get it revised.   

The thing they need to do is to change the 90-day limit on meant-to-be-permanent ICLs to something a little bit more reasonable.  I'd say make it 180 days as well. 

[MIKE]

If it is not meant to be rescinded, why wouldn't we want to put it into a regulation, if it is regulatory in nature? 

Only NHQ may issue regulations and manuals.  It would be intended for something that is both specific, relatively brief, and ill-suited for a supplement, pamphlet or OI.  An ICL is either temporary, or will be incorporated into another pub and made permanent.

[RiverAux]

I suppose I'm just not getting what you're looking for.  BG Courter can issue a letter on policy regarding something not covered in the regulations, and not suitable for the regulations, tomorrow that would remain in force until the sun burns out without issuing an ICL.  Are you saying that there is a regulation that prevents that?

I suppose there is some line between what needs to be put in a regulation (or an ICL to a regulation) vs what does not need to be that you're trying to pinpoint. 

[MIKE]

BG Courter can issue a letter on policy regarding something not covered in the regulations, and not suitable for the regulations, tomorrow that would remain in force until the sun burns out without issuing an ICL.  Are you saying that there is a regulation that prevents that?

CAPR 5-4 as currently written.

[RiverAux]

Can you give an example of something that is an ICL now that you think would be more appropraite as some sort of informal, never-ending policy letter?