BETTY LYNN'S TIPS (BLTs)

New, improved SD Form 818, Comment Matrix for DoD Issuance coordinators and originators.

Directives Division revised the SD Form 818, "Comment Matrix for DoD Issuances," to provide some new features for coordinators and action officers working with issuances. The clearer, streamlined instructions outline the roles for both the coordinators and for the collectors of the comments. The drop-down menus, sorting features, and automatic numbering will make some of your duties easier.

The classification, comment type, and originator adjudication columns each have drop down menus - no more doubt about what's supposed to go in the column.

Sorting the table by page and paragraph numbers after all comments are consolidated will make your job easier.

Finally, you can use automatic comment numbering after your comments are compiled - no more having to correct comment numbers when updating or correcting the SD 818!

Watch the SD 818 video demonstration of the new drop downs and how to sort and automatically number.

Internet Explorer and ZIP Files

Due to Internet Explorer security restrictions, IE users will need to download the SD Form 818 as a ZIP file (Firefox users can download the MS Word file directly). While many of our testers had no problems, some who tried to open the .zip file and work it found the drop downs and other features were not active. When opening the .zip file you will have the option to either "save" or "open." Suggest you save it to your desktop first to avoid any issues; the drop downs and other features will be active once you do that.

Okay, you've answered all the What, Why, Who, Where, and How (See May 2012's BLT) for your issuance and now you are ready to put pen to paper (or finger to keyboard).

Before you do anything else (do not pass Go!, do not collect $200)—go to the DoD Issuances website and select the appropriate template for your issuance (instruction, directive, manual, or directive-type memorandum). Even if you are reissuing a document, always start with the latest template.

The template is a "blank" document with all the formatting set up for you. Requirements change and standards are modified, so it's always best to download the template directly from the website. While you're on the website, copy the accompanying Directives Division standard to your desktop for reference. The template shows you how your document should look; the standards tell you what you should say, how you should say it, and where in the document it belongs.

Writing clearly is not only good business communications, it's required by law (see the Plain Writing Act of 2010). Keep the basics in mind when working on your issuance:

Organize the material. We learned in school to use an outline, and it's still a valuable tool. Plan what you're going to discuss and what order makes sense (keeping in mind basic issuance standard requirements) and stick with it. It's very easy to lose track when your document's large or requests for changes are flying at you from all directions. If during the writing process it becomes clear the issuance needs to go in a different direction, rework your outline. This may seem like "busy work," but it will serve you well in the long run.

• Organize sections, enclosures, and appendixes so that the relationships between them are clear.
• Use paragraph headings to highlight important concepts so the reader can see at a glance what the paragraph's about.

Keep sentences short. Form subparagraphs if necessary. Limit sentences to one thought. A good goal is to keep them below 20 words.

Use parallel grammar construction. If you're listing items that must be included in a report and a, b, and c are nouns, d must also be a noun.

Example: Not	Example: But
Quarterly reports must include:	Quarterly reports must include:
a. Name of Component	a. Name of Component
b. Dates covered	b. Dates covered
c. Theater of operation	c. Theater of operation
d. Summarize the major events	d. A summary of the major events

Use active voice. Active voice means the sentence has an actor (subject) committing an action (verb). Instead of the typical bureaucratic, "reports shall be submitted quarterly by all installation commanders," start with the actors: "Installation commanders will submit quarterly reports."

Eliminate helping verbs in sentences. Helping verbs are usually a form of the verb "to be". Instead of "the committees will be meeting monthly" say "the committees meet monthly." Instead of "the Assistant Secretary of Defense will be responsible for ensuring all agencies comply" say "the Assistant Secretary of Defense ensures all agencies comply"

Use clear language.

Don’t use six words when three will do:
Instead of:	Use:
in order to	to
in the event that	if
on the occasion of	when
Use everyday words, not legalese or jargon:
Instead of:	Use:
aforesaid	the, that
heretofore	until now
herewith is	here is
Avoid turning verbs into nouns:
Instead of:	Use:
make recommendations	recommend
conduct an investigation	investigate
convene a meeting	meet

More tips are available in our Writing Style Guide and on the DoD Plain Language website.

What do you need to know to develop a new issuance? There is a short answer and a longer one.

The short answer is simple: follow guidelines laid out in DoD Instruction (DoDI) 5025.01 as the authoritative guide for the mechanics of developing, coordinating, and issuing a new policy.

The longer answer requires answering several familiar questions: Why? What? Who? How? and When?

Why? In most cases, you develop a new issuance to fill an identified policy gap or to implement:

• An Executive order (E.O.)
• A change in law, statute, or Government-wide regulation
• A decision by the Secretary or Deputy Secretary of Defense.
• A decision by the Head of your Component
• A policy issued through the DoD Directives process that needs implementing guidance for your Component.

Why Tip: The E.O.s, laws, decisions, or policies virtually always drive the Purpose, Applicability, and Policy sections of a new DoD Directive or Instruction. That said, DoD issuances are directive in nature and must cite the authority to issue policy, but you should not include detailed history of how the policy was developed or why it's needed.

What? What needs to be done (or not done)? What goals and objectives am I (or DoD) trying to accomplish? This determination focuses the Policy section in the new document. Be sure to do your homework to verify that these policies are new (not established elsewhere). What parameters are being established, and for whom? What should the reader know and do after reading the issuance? Does that fit with your Why?

Who? You can usually identify the major stakeholders based on the originating decision or policy gap and what needs to be done. Who does the policy affect the most? What organizations can make the what happen? This is a good start toward determining the organizations to be named in the Responsibilities section.

Who Tip: Do not copy responsibilities from charters, other DoD policies, or from agency or Service issuances. They may not be appropriate for your issuance and they may be out of date.

How and When? Directives primarily address what. Instructions and Manuals may also address what in terms of implementing policy, but they routinely discuss how and when in terms of procedures. These are as detailed as necessary to make the guidance useful to those who must execute it.

How and When Tip: Always develop procedures in conjunction with those who must carry them out.

It sounds simple, and in most cases it is when you work through the questions systematically. That leads to:

A final Tip: When beginning to develop an issuance, go to the writing guide, templates, and standards provided on the DoD Directives Website (http://www.dtic.mil/whs/directives/corres/writing/process_index.html) for the latest and greatest guidance on the issuances development process.

Keep in Mind: Issuances set boundaries, assign responsibilities, and clarify relationships so organizations and people can operate legally and effectively. If your document does those three things, it will be worth all the time and effort you invest.

Stay tuned: Part 2 will address grammar and writing tools for issuance developers.

Formal coordination on your issuance closed more than a month ago. Your supervisor and others are anxious to see forward progress on this policy. You have been working with a coordinator to resolve a non-concur but have been unsuccessful. Can you move forward?

The short answer is yes, you can. While generally you want to address all comments during formal coordination and try to satisfy concerns of everyone with equity in your issuance, sometimes it is just impossible to make everyone happy.

If you as the action officer made a good faith effort to resolve the coordinating component's concerns, you may move the issuance forward with a non-concur. Here's where a legal adjudication review comes in handy. Working with the Associate General Counsel that performed your legally objectionable review, try to confirm that the change requested isn't a legal issue. If the Office of the General Counsel agrees that the requested changes aren't legally required, then you may move forward.

After formal coordination is completed, you prepare a presignature package to send to WHS Directives Division for review. One of the things included in the presignature package is an action memo requesting the Head of the Component sign the issuance. The action memo is where you make a case for signing the issuance over the objection of the non-concurring component. You should explain the efforts made to address the comments, your reasons for not accepting the proposed changes, and any legal opinion obtained about the issue. Generally you will request the signature authority sign the issuance over the objection of the non-concurring component.

Sometimes through informal negotiations you are able to satisfy a non-concurring component's issues but have not received an official withdrawal of their non-concur. Again, you do not need to wait until official paperwork can be processed. In the action memo, note that Component Z non-concurred at formal coordination, state what efforts were made and changes incorporated to address the concerns, and the informal approval received from the commenter.

The point of the action memo is to be sure the Component Head is aware of all issues, especially non-concurs, and how they were addressed before signing the issuance. If a non-concur is withdrawn between the presignature review and signature, the action memo can be modified to reflect current status before being sent up for signature. The person signing issuances needs to be fully aware of any outstanding issues and efforts made to resolve them. But a stubborn component or delayed paperwork does not have to prevent your issuance from moving forward.

Is your policy languishing somewhere in the process as your supervisor rails at you for the apparent inactivity? 

To keep from making your own contribution to the cycle of frustration, save yourself some time by avoiding these Five Classic Process Mistakes when navigating the coordination process:

Skipping or Skimping on Informal Coordination

Policy development is a collaborative venture.  You have important equities, but so do others.  Don't ignore theirs.  If you fail to do solid informal socialization of your policy concept before finalizing your draft, you invite criticism that you will have to deal with formally later.  That eats up valuable time.  Acknowledging and defusing criticism up front reduces non-concurs and significantly streamlines the formal comment adjudication process.

Blowing Off Edits

Washington Headquarters Services Directives Division (DD) employs and trains professional editors.  They have one goal: to edit your policy so that it conforms to DoD standards and is understandable to the reader.  If your editor doesn't understand what you are trying to say, many others won't either.  Rejecting a DD edit should be rare practice.  Consult with your editor of record when rejecting any edits.

Ignoring Version Control

Once you submit your draft for precoordination review, you have established your baseline.  The draft that comes back to you from DD must be used throughout the subsequent coordination process.  That version has been edited to meet DoD issuance standards, and all subsequent changes as a result of comments must be posted to that version (and any updates your editor makes to that version at LOR or Portal review).  Using a different version (or versions!) after pre-coordination is a time-devouring disaster!

Waiting to Resolve Critical Comments

During formal coordination, comments from DoD Components are often received over several weeks.  As soon as a critical comment or non-concur is received, engagement becomes the word of the day.  The sooner you begin working to understand and resolve the commenter's concern, the more likely you are to meet your adjudication timeline.  Additionally, do not hesitate to raise the really hard issues to your supervisor.  Criticals are the hardest; work them first, not last!

Changing the Issuance After a Legal Review

The attorneys get multiple shots at every issuance to make sure we're on sound legal foundations.  Changing the document after a legal review and before the next process step invalidates the legal review!  For example, if you receive legal comments from a legally objectionable review, make the appropriate changes, and submit THAT revision for formal coordination.  DO NOT make changes the attorneys did not ask for.  Otherwise, you will pay for it in time to "re-chop."

Word to the Wise

The equities of other DoD Components are not irritants to be grudgingly accommodated, but an essential part of the process to ensure that policy developed effectively serves the entire Department of Defense.

Does your comment really belong in the ICU?

You've been tasked with reviewing a DoD Issuance that affects your division, component, team, or agency. Something in the responsibilities, procedures, or requirements is just not (a) feasible, (b) economical, (c) healthy, (d) or smart. You say "This must be changed!" and provide a comment. Just to make sure that the action officer for the issuance will take your comment seriously and make the change that you require, you label the comment "critical".

Not so fast! Before you load your critical comment into the SD 818, Comment Matrix, you need to see what DoD policy has to say about the criteria for critical comments. Not just any comment can be designated as critical. Critical comments are those that:

1. Violate a law or contradict Executive Branch or DoD policy.
2. Create unnecessary risks to safety, life, limb, or DoD materiel.
3. Waste or abuse DoD appropriations.
4. Impose an unreasonable burden on a Component's resources.
5. Raise legal objections by the DoD General Counsel or GC representative.

So before you designate your comments as critical, check them against the above criteria to see if they really are. Keep in mind that if you submit even one critical comment, your Component must automatically nonconcur with the issuance. Marking a comment "substantive" rather than "critical" does not mean it will be overlooked. All comments submitted in coordination must be adjudicated.

If, based on the criteria, you still believe your comment qualifies as critical, specify what needs to be done to satisfy your component's concerns. For example, a comment that is tagged as "critical," but simply says, "how are you going to address the security issues created by this database?" makes it difficult for the action officer to address the comment in a concrete way. Suggest new language, request deletion of certain phrases, or specify precisely what needs to be added or subtracted to satisfy your concerns. That way the action officer has an opportunity to accept your comment and thereby satisfy the nonconcur without requiring additional emails, memos, or re-signed SD 106s.

While a critical comment is an automatic nonconcur, several substantive comments can also result in a nonconcur. If your comments don't meet the criteria for critical but you are concerned about several issues, you may submit substantive comments with a nonconcur. This then requires the action officer to address the issues submitted in the comments and satisfy the coordinator's concerns enough to get the nonconcur withdrawn. If you specify which substantive comments led to the nonconcur, it is considered automatically revoked if the AO accepts the comments and makes the required changes to the issuance. Everyone saves time and effort!

Let's start with the types of issuances DoD publishes:

DoD Directives (DoDDs) are "big picture" issuances signed by the SecDef or DepSecDef. They establish DoD policy, assign responsibilities, and delegate authority to DoD Components. DoDDs do not contain procedures. There are two types of Directives: direct oversight and chartering. In almost all cases, the Directive you write will be a direct oversight Directive, that is, one that includes activities that require SecDef or DepSecDef oversight. Direct oversight Directives contain:

• SecDef or DepSecDef responsibilities that cannot be delegated.
• Assignment of functions and resources between and among Principal Staff Assistants (PSAs) or DoD Components.
• Designation of DoD Executive Agents and assignment of related responsibilities and authorities.
• Matters of SecDef or DepSecDef special interest.

Chartering Directives, or charters, establish the mission, responsibilities, functions, relationships, and delegated authorities of the Head of an OSD Component; an OSD Presidentially-Appointed, Senate-Confirmed Official; or the Head of another major DoD or OSD Component. They have names such as "Deputy Secretary of Defense" or "Under Secretary of Defense for Policy." These are usually developed exclusively by the Office of Organizational and Management Planning, or O&MP. If you think your issuance should be a charter, you should contact O&MP first.

Directive Type Memorandums (DTMs)

Directive Type Memorandums (DTMs) are issued ONLY for time-sensitive policy actions that cannot wait for a Directive or Instruction to be coordinated and published. DTMs may establish policy and assign responsibilities, or they may implement policies and responsibilities established in existing Directives or Instructions. Think hard before using this one; while DTMs move through the issuance process faster than other types of issuances, DTMs are effective for only 180 days from the date signed. The other issuances are valid for 5 years. The policy or procedures established in DTMs must be incorporated into another DoD issuance by the expiration date. DTMs requiring SecDef or DepSecDef direct oversight must be signed at that level, but OSD Component Heads or their Principal Deputies may issue DTMs within the scope of their charters.

DoD Instructions (DoDIs)

DoD Instructions (DoDIs) are usually signed by a PSA (e.g., an Under Secretary of Defense or Assistant Secretary of Defense). They can establish or implement policy, and they provide general procedures. Policy Instructions allow the PSA to establish policy and procedures for activities within his or her chartered responsibilities. Be sure to cite your Component's charter as a reference in your Instruction. The charter gives the authority to publish your Instruction. Non-policy Instructions implement policy established in either a Directive or a policy Instruction, which must be cited as a reference in the Instruction. Policy Instructions are signed by the PSA; non-policy Instructions can be signed by the Component Head, the Principal Deputy, or other officials authorized by the charter.

DoD Manuals (DoDMs)

DoD Manuals (DoDMs) implement or supplement policy established in a Directive or Policy Instruction and must cite either as a reference in the DoDM. Manuals usually focus on procedures for managing activities or systems. A Manual may summarize policy that has been established elsewhere, but cannot establish policy. DoDMs are often issued in multiple volumes. Manuals are signed by OSD Component Heads, Principal Deputies, or other OSD officials as authorized by their charters.

Administrative Instructions

Administrative Instructions provide guidance on administrative matters related to implementing policy established in DoDDs or DoDIs that focus on administration of the DoD Components in the National Capital Region. Most AIs impact only Components that are serviced by WHS, but they can also apply to all Components.