2. On December 3, 2002 the Director, OMBE, for the Deputy Secretary and the DOE Management Council, issued a Memorandum, subject: Improvements to the Directive Process. This memorandum made changes to the Directives process (e.g. the DMD process has been abolished), yet the draft Order does not reflect the changes made by this Memorandum. If the Order does not make the changes and continues to focus only on CRD concerns, the Department would be potentially issuing an Order in violation of extant Departmental policy.
Other comments: In the subject change, the 'Contractor Requirements Document' section of DOE Order 251.1A has been deleted and replaced by a 'Contractor Applicability Template' section and a 'General Guidelines For Drafting Contractor Requirements Documents' section. The only contractor requirement is stated in paragraph 4a of the Order. This deletes two main contractor requirements from the current Order. This will clearly hamper the Department's ability to fulfill contractual obligations and formal commitments by decreasing consideration of contractor concerns prior to the issuance of new and/or revised directives.]]>

3b. and renumbered paragraph 3c. as 3b. ]]>

Failure to resolve this issue will jeopardize DOE's ability to accomplish policy objectives and missions. Michael H. Schlender, Deputy Manager for Site Transition, authorizes this comment. ]]>

In paragraph 3. b. (3), replace everything before the brackets with:
'This CRD does not apply to other than site/facility management contracts. (Any application of any requirements of this Order to other than site/facility management contracts will be communicated by issuance in the Department of Energy Acquisition Regulation, through the regulatory process, of an appropriate contract clause.)'
In paragraph 3. b. (5) in the last sentence, add after 'CRD' the following: 'to the extent necessary to ensure the contractor's compliance'.]]> Failure to resolve this issue will jeopardize DOE's ability to accomplish policy objectives and missions. Michael H. Schlender, Deputy Manager for Site Transition, authorizes this comment. ]]>

Failure to resolve this issue will jeopardize DOE's ability to accomplish policy objectives and missions. Michael H. Schlender, Deputy Manager for Site Transition, authorizes this comment. ]]>

In the last line of the CRD before the bracketed language, add after '(1) ensure that it and its subcontractors comply with the rquirements of this CRD' the following: 'to the extent necessary to ensure the contractor's compliance'.]]>