i'm drafting our reply-comments to the Policy vs Implementation working paper.  as i've read the other comments, i have started to come to the position that we may be trying to over-legistlate this.  my basic idea is this -- rather that a huge effort to develop detailed criteria for each possible Policy vs Implementation decision, what if we put a review by the AC/SO's into the process?  

so i've drawn a flow diagram of a possible way to handle the process and would be very interested in your thoughts.  the two changes to the process implied by Marika's drawing are:

- insert the AC/SOs in the decision-making process

- indicate that the process of review is iterative -- that AC/SOs get to send the decision back to the staff for review/refinement

i think this does a few things

- it's an appropriate task for AC/SOs, in their policy-management role

- it reduces the need for excruciating detail in criteria and (correctly, in my view) increases reliance on the judgement and wisdom of the policy-management bodies

- provides a chance to iteratively arrive at an approach that has broad approval and acceptance in the community.

the picture is attached.  any thoughts?  slashing criticism ("Mikey you're crazy") is fine!

mikey