Since receipt
of the DHS "Notice of Proposed Rulemaking" regarding
Organized Camps, representatives of the California
Collaboration for Youth ("CCFY")
have collected extensive comments from Camp
Directors throughout the state, met with
the California Department of Health Services
("DHS") to discuss the comments
received to date, and worked together to
gain a better understanding of the process
going forward.
Summary
- These regulations, 10 years in the making
and not previously revised for nearly
50 years are finally moving forward.
- Your attention to this is time critical.
Please read this memo
completely and respond as requested by
friday, 4/6/07.
- What we need most from you is simply
to put the sample letter (MS Word) on
your letterhead and mail it to dhs so your
support is added to our collective voice.
If you do nothing else, please take 2 minutes
and do this now!
- If you don't need to know more, then
that's all you need to do. If you want
to know more, read on. . .
Background
To provide a context for considering our
comments, please understand that the current
process of updating the Organized Camp Regulations
began in the early 1990's. At that
time, a collaborative effort between all
of the stakeholders in the organized camp
community in California and DHS resulted
in a version of the proposed regulations. This
version began the regulatory review process
with DHS in 1997 where it has languished
until now.
We cannot emphasize enough the importance
of having these regulations updated. All
one has to do is pick up a newspaper (or
check Yahoo) to watch the daily drama surrounding
Walter Reid Medical Center in Washington
DC and care for our veterans to get a glimpse
of what would happen to us in the event a
major tragedy occurred in a California organized
camp and the media and parents subsequently
learned that our industry's regulations
had not been updated since the 1950s!
CCFY has convened two conference calls and
one in-person meeting with representatives
of numerous state and nationally affiliated
camp organizations to gather input on the
regulations. We
have prepared a response to the Department's
proposed regulations, reflecting the concerns
raised and the clarifications we have received
from DHS staff as well as suggested revisions.
With these regulations so long in the making,
we feel it is important that the Department
receive numerous letters of testimony in
support of the regulations moving forward,
with reference to the noted changes and clarifications
advocated by CCFY.
So while we may not love all aspects of the
proposed regulations, the fact that they
have been in suspense pending public comment
since 1997 and the reality of legislation
created in reaction to a bad event lead us
to urge DHS to move forward as quickly as
possible to finalize and adopt these regulations.
The current version was disseminated to all
of us on January 5, 2007, which is the first
time any of had an opportunity to see what
"edits" had been made during the review process.
The last thing we can afford is for these
regulations to end up on the same shelf gathering
dust for another 10 years. In the future
if technical changes are needed, CCFY can
pursue legislation to address these issues
on our behalf.
Comments Received
Attached please find a draft version of the
comments CCFY has received from camps and
professional associations (ACA, CCCA, WAIC)
throughout the state. All comments
we plan to submit are included in this letter.
If a comment or concern of yours is addressed
in this letter, you do not need to repeat
it in your own letter. We
have been advised that a "rulemaking" hearing
is different from a "legislative" hearing,
in that a volume of "comments" HURTS
the cause (does not help), because more comments
increases the time it takes for DHS to respond
as required by law. Ideally to the greatest
extent possible, therefore, it would be in
our best interests to submit one (1) letter
that incorporates all comments we feel DHS
needs to consider.
Please review the Comments (MS
Word) from
CCFY for your consideration. Please
review these comments carefully. If
you have additional concerns not reflected
in the attached "Comments" memo,
we would encourage you to speak to one of
the many camping representatives listed at
the bottom of this memo who were engaged
in the conference calls and meetings and
who may be able to speak to your concerns
by sharing information from our discussions.
Your comments should be directed to CCFY
through one of the people below. Please
let us hear from you if you have any concerns,
additions, or changes prior to March 30,
2007. If we do not receive any input by that
time, we will submit the Comments
letter (MS
Word) to
DHS as representative of our industry's position
on the proposed regulations.
Letters of Support
Where volume DOES help is in submitting letters
of support. Accordingly, we have a Sample
Letter of Support (MS
Word). If you are
so inclined, please send such a letter on
your camp or organization's letterhead
(or both) as soon as possible. The
more letters of support DHS receives, the
better!
Letters of support can be mailed to:
California Department of
Health Services:
Office of Regulations
P.O. Box 997413
Sacramento, CA 95899-7413
They can also be faxed to (916) 440-7714
or e-mailed to regulations@dhs.ca.gov,
but in each case you must reference the
package "R-15-97." It is our hope
(and belief), however, that our industry
can speak with one collective voice.
Process
In response to a written request, DHS has
scheduled a public hearing Monday, April
9 at 10 AM in Sacramento. This effectively
extends the comment period until April 9,
so all letters must be received by 5 PM on
April 9. The purpose of the hearing
is to accept oral and written comment on
the regulations. Pursuant to the administrative
procedures act there will be no discussion
or debate during the hearing. Furthermore,
there is NO difference between comments submitted
in writing and those submitted orally. As
such, the same guidelines discussed above
with respect to written comments apply to
oral comments given on April 9.
It is anticipated that, due to the lengthy
time involved in a regulatory process, these
regulations will not be implemented until
Summer, 2008. CCFY has been asked to
participate in the development of a handbook
highlighting the revisions to the Organized
Camp Act, a project we are pleased to undertake.
RSVP for In-person Hearing
If you have submitted a letter or comments
already, you will NOT need to say anything
at the hearing. However, we would like a
good number of people who support the regulations
to attend so we can ask you to stand and
show that you are in support.
Please let us know if you are planning to
attend the hearing so DHS can anticipate
ample time and space for participants. Thank
you in advance for your assistance in this
important process. If you have any
questions, also please feel free to contact
the CCFY legislative office at (916) 447-7341. Michele
Branconier - ACA So CA (760) 345-2926
Roger
Williams - CCCA (831) 430-1230
Tom Horner
- WAIC (626) 296-4040
Tim Holland - ACA No
CA (530) 273-6744
Frank Reigelman-Boy Scouts
of America (972) 580-2421
Stanton Whitling
- CCCA (559) 335-2000 x418
John Green - YMCA
of the USA (800) 872-9622
Andrew Townsend
- ACA No CA (831) 479 6714
Kim Rosiar - CCCA
(800) 833-1444 |
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