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CAP Talk  |  General Discussion  |  The Lobby  |  Topic: Delinquent Interim Change Letters
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SarDragon
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« Reply #100 on: February 04, 2010, 06:39:28 AM »

Regulations mostly just state policy. Manuals are more detailed, and explain methodology for implementing the policies contained therein.
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Dave Bowles
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JoeTomasone
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« Reply #101 on: February 04, 2010, 10:03:33 AM »

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. 

Quote from: CAPR 5-4
“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.

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RiverAux
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« Reply #102 on: September 03, 2011, 02:08:57 AM »

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. 
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CAP Talk  |  General Discussion  |  The Lobby  |  Topic: Delinquent Interim Change Letters
 


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