Posted October 6, 20222 yr comment_73970 Here is what we're up against: On November 18, 2021, the president issued a 2,223-word executive order, No. 14055, Nondisplacement of Qualified Workers Under Service Contracts. See 86 Fed. Reg. 66397, published on November 23, 2021. E.O. Section 7, Regulations and Implementation, paragraph (a), ordered the Secretary of Labor to issue "final" regulations to implement the E.O. within 180 days of the date of the order (November 18, 2021)—i.e., by May 17, 2022. Section 7, paragraph (b), ordered the FAR Council to amend the FAR within 60 days of the Secretary of Labor's issuance of that department's final regulations. On July 15, 2022, the Secretary of Labor published a 49,773-word notice of proposed rulemaking. The Secretary gave the public until August 15, 2022, to read the proposed rule and submit comments. According to the Open FAR Cases Report of September 30, the oldest FAR case is 2015-014, Prohibition on Providing Funds to the Enemy, which is to implement the 2015 National Defense Authorization Act. The most recent status report on that case states: "04/15/2015 DAR staff notified FAR staff that DARC agreed to draft proposed FAR rule. Awaiting CAAC concurrence." Make what you will of all that.
October 6, 20222 yr comment_73981 This is a great example of how our government can make something simple exceptionally complex. Very little in the DoL published notice of rule making is really needed to explain. But I’m sure they first consulted employee unions across the nation and had all their legal advisors weigh in. It takes a long time for unions to provide input and DoL must weigh in, consider, and consolidate all the responses. It’s also amazing how they can just take their time and be two months late responding to the EO. The government is so afraid to act and tries their best to avoid criticism that they create other types of problems. The FAR Committee fits that perfectly.
