-----Original Message-----
From: H.
Sent: Monday, December 12, 2011 12:01 PM
To: R., the lawyer on the doomed project
Cc: me
Subject: FW: the doomed project weekly review
FYI below -- I tried to discourage this but TMBB will be reviewing L** sections during your review. Please provide a link to the document you want them to review.
Very respectfully,
H.
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-----Original Message-----
From: B.
Sent: Friday, December 09, 2011 3:03 PM
To: H.
Cc: B2.
Subject: RE: the doomed project weekly update
Will push for this to be in parallel with the legal review. I don't know that we'll see changes as a result, but with those portions being fairly contained, this being a conceptual review, and PC review going for another week, I think we should be ok even if there are some changes...
-----Original Message-----
From: H.
Sent: Friday, December 09, 2011 1:26 PM
To: B., H.'s boss
Cc: B2., H.'s other boss
Subject: FW: Large OSV: The Week In Review (Dec 5, 2011)
Hello,
Please see email below -- this will delay legal review, which is currently underway. We were given assurances that this was vetted through all impacted offices. Please advise.
Very respectfully,
H.
Signature block
-----Original Message-----
From: N.
Sent: Friday, December 09, 2011 12:10 PM
To: H.
Cc: several people on the team and their bosses
Subject: RE: The doomed project weekly update
H.,
Since there is lots of ongoing discussion on L**, I think it would be worthwhile to have [team members' bosses' bosses, or TMBB] do an "informal" review & comment on those pieces of the reg text at this point rather than wait. This would include the new sections recently added to address training, construction, etc for L**, which were not in previous versions reviewed and commented on by TMBB. I'm not advocating that you delay any of the other work or adjust the timeline.
R,N.
To summarize, a bit about operational L** was added to the doomed project relatively late in the process. Fine. It's there, it's in, just in time for the "pens down" date when the subject matter experts would stop work as everyone agreed, so that me and the lawyer and economist could do our work in turn. But last week the team members' bosses' bosses, or TMBBs, pointed out that they've had an "informal review" of all the rest of the rulemaking, but it didn't include the bit about operational L**. So they're asking for the chance to do an informal review of operational L** as well.
At first glance that might look reasonable. Just a chance to do with one section what they've already done with all the rest. However, there are at least four problems with it.
1. "I'm not advocating that you delay any of the other work or adjust the timeline." I found that breathtaking. Why isn't he advocating that? He should be. Experience indicates that he should: the previous informal review took more than a month. I'd personally say that the last-minute stuff is in a rougher state than the rest, but you don't need that level of familiarity with the project to know that there's a problem here. Simple logic indicates that he should: the whole point of a review is that TMBBs might want to make changes, and if they do, that would take time. And really basic human courtesy indicates that he should: other team members have their own jobs to do. This guy wants to take other peoples' time for his review. All in all, that one line was ridiculous.
2. As H. points out, it was agreed upon by everyone that the "pens down" date came and went more than a week ago. The time to ask for something like this was back then. It's not like they just noticed the operational L** stuff on Friday. But either TMBB are so disorganized or haphazard that they didn't think of it at the time, or they thought of it but didn't want to kill the feeling of progress at the meeting. Neither of which speaks well of the quality of management here.
3. H.'s own boss said "with those portions being fairly contained, this being a conceptual review, and PC review going for another week, I think we should be ok even if there are some changes". The assumption there is false. These portions are not fairly contained. There are literally a dozen different sections in the document relevant to this. It took me a nontrivial amount of time just to make the document for review: find all the sections, copy-paste them into another document, and ask the lawyer about four borderline cases and an illegible section. TMBBs asked about the operational L** stuff added at the last minute, but he also asked about "training, construction, etc", neither of which is the last-minute stuff. This leads into yet another problem.
4. I left a ton of details out of the above e-mails, but basically, we decided we should put together everything related to L**. "Training", "construction", the operational L** that was added at the last minute and all the rest. All together, that's over 60 pages, about 20 percent of the total document. If they really did just want what they specifically listed, then that wouldn't have saved too much effort because I couldn't have easily figured out what those were without help, and if they were unclear that's just replacing one problem with another. But if they want to do an additional review of 20 percent of the document, this is a very, very late date to start it.
What a mess. I finished putting together the file for review this morning, so my job here is done until TMBBs have comments on it. But I found it interesting how such a relatively simple request could get so much wrong.
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