World Watches With Shock as Trump Mob Storms United States Capitol

 

We wished we could say that we were shocked with the insurrection that happened at the U.S. capital city today.  Given the last four years of  the president and his enablers living in world based in an alternate reality, this was the unavoidable conclusion. It is not a coincidence that a U.S. president who gave a speech about the American carnage during his inauguration now ends his administration this way. We kept hearing from TV people that they have never seen anything like this before. That’s true but if you have lived overseas in developing countries, you have seen something like this happened before, others have seen this many times before. It almost always never ends well for the country.
We as a country cannot let this stand. If there are no consequences for these actions, this is bound to happen again. How easy was it again for the mob to breach the U.S. capitol? How long did it take for reinforcement to come? Four hours? What’s going to happen next time, take lawmakers hostages so they cannot continue with the election certification?  For the elected officials who sheltered in place today inside the capitol, this guy sure learned his lesson!  Where is your red line?
Below, the world watched with shock and disbelief.

GERMANY

AUSTRIA

UNITED KINGDOM

SPAIN

ITALY

FRANCE

EUROPEAN UNION

OSCE

NATO

UKRAINE

LITHUANIA

ESTONIA

COLOMBIA

IRELAND

NORWAY

CROATIA

CANADA

AUSTRALIA

President-Elect @JoeBiden to Name Aide and Former State/D Tony Blinken as 71st Secretary of State

 

@Transition46 Releases Names of Agency Review Teams For @StateDept, @USAID, @USAGM, and @USUN

The Biden-Harris Transition has released the names of Agency Review Teams for the State Department, USAID (which includes MCC, Peace Crops, IDFC),  the U.S. Agency for Global Media (USAGM) and the U.S. Mission to the United Nations. A lot of familiar names here. Note that all members are currently listed as “volunteers”. According to Transition46, these are individuals who are volunteering for the Transition in their personal capacity. For these team members, their current or most recent employer is listed (for informational purposes only), and their source of funding is listed as “Volunteer.”
We have added a countdown to Inauguration Day on our right sidebar.

 

MikeyPo Shows Once More His Smallness as Secretary of State #ByePompeo

We’re not sure why people expects anything better from the 70th secretary of state. If you were shocked, you have not been paying attention. This secretary of state has shown repeatedly, despite a much touted swagger, that he was not the man for this job. Why do you think he needed that swagger?  But swagger can only take one so far. Reality eventually catches up with you. He will go down in history not only as the most political secretary of state in modern times, but also the worst one by far.
No, we haven’t forgotten about Rex Tillerson, but the 69th secretary of state was not an  ideologue nor an opportunistic hack like his successor. SecState 69th was also his own man, and he recognized a moron when he saw one. Unfortunately, this is something we cannot say about the soon to be former secretary of state otherwise known as ‘a heat-seeking missile’ for … oh, golly, you undiplomatic, you!
Folks may complain in the future about other secretaries of state, but we expect it will always come down to the threshold question — is he or she Pompeo-bad?
The leadership behavior at State appears to be trickling down. A senior security official at the US Embassy in Kabul recently called the U.S. election on social media, a “fraudulent election”, called President-Elect Joe Biden, a “senile idiot” and Vice President-Elect Kamala Harris, “a woman that claims to be black, but she’s not.” As if that’s not offensive enough, this senior career official also writes, “Oh and did I mention, so much for the economy, when this stupid fucking moron appoints Bernie Sanders and Elizabeth Warren to his cabinet. Watch it all collapse and then you’ll wonder what happened to our country. Obama fucked it all up and Trump turned it around. Now it all goes to shit again.”  Meltdown at the Kabul aisle!
This is not only unacceptable and outstandingly bad behavior for a senior official overseas, this is also against the Department’s Foreign Affairs Manual, see 3 FAM 4123.3  for Political Activities for starters. But given the tolerance for bad behavior in Foggy Bottom, will US Embassy Kabul, DGHR, or the State Department clean up or just look away with a sigh?
There are some good news though; come January 20, Mr. Pompeo (and his buddies), whether he accepts the Biden reality or not, will have to step down from his job. And oh, my gosh!  He also must leave the USG-provided housing he now occupies (one flag officer says yay!) and return to … well, we’re not sure exactly where that might be. Maybe Kansas where he almost run for the Senate and could have won a six-year term.  It doesn’t matter, really, does it?  He’ll be working on his 2024 project unless somebody crashes it.  Somewhere, we imagine, he will be grilling a journalist or two with blank world maps. And he needs to walk and scoop after Sherman and Mercer.
Also on January 20, please fumigate swagger from Foggy Bottom and get moving. There is much work to be done. We hope folks will pour their energies in the rebuilding and strengthening of our institutions. But we also hope they won’t forget to write down their memos to file documenting their last four years of organizational life. May y’all remember because the world will not go back to what it was as the Kabul incident shows.  Something broke here. And it will take many long years to repair. But it’s important to remember, and uphold — as Sheila S. Coronel of the Columbia University Graduate School of Journalism wrote in “A warning from the Philippines on how a demagogue can haunt politics for decades” — uphold “a truthful record of history” even as some of these people swagger into the sunset.

 

Biden-Harris Presidential Transition Website Now Live But ….

The official Biden-Harris Presidential Transition website is here: https://buildbackbetter.com/.
You may follow it on Twitter at @Transition46 or on Facebook at https://www.facebook.com/Transition46/

A LOOK BACK to Nov 10, 2016:

ALSO:

Wait – @StateDept Has a Deputy “M” Again, a Position Discontinued by Congress in 1978

Posted: 2:30 pm  PT

 

With vacant offices and multiple departures from members of the Foreign Service and the State Department, it is hard to keep track sometimes of what’s happening amidst the opportunities and chaos in Foggy Bottom.

Bill Todd, the Principal Deputy Assistant Secretary & Acting Director General of the Foreign Service & Acting Director of Human Resources apparently has a fresh new title to add to his Twitter profile: Deputy Under Secretary of State for Management, a position discontinued by Congress in 1978.

How did that happen?

Apparently somebody convinced the now outgoing Secretary of State to sign a memo reconstituting this title on March 4. Did anyone bother to inform Secretary Tillerson that the position of Deputy Under Secretary for Management was discontinued specifically since Congress established the permanent position of Under Secretary of State for Management in 1978? And if nobody informed him …

Yo. This is sad.

Since the discontinued title/position was made “live” again a couple of weeks ago, there were people wondering why this title was resurrected now, and without any official announcement. Today, of course, a day before Tillerson is set to exit Foggy Bottom, the first memo sent under this office is out, so it’s not a secret anymore (bland, routine memo with A Message From Deputy Under Secretary for Management Regarding Planning for a Potential Lapse in Appropriations). And our inbox lighted up from folks with “Whoa, did you see this?” or “State has a Deputy M? or “When was the last time the State Department had a Deputy Under Secretary for Management?”

Whoa, indeed! Not since 1978, my dears.

What we want to know is if Congress is okay with this given that it purposely killed this position when it created the  permanent”M” by legislation decades ago.

Trump’s nominee as the next Under Secretary of State for Management Eric Ueland was nominated last year, renominated earlier this year and was cleared by the Senate Foreign Relations Committee in February. The last Senate-confirmed “M” Patrick Kennedy retired in 2017 in the mass departures of top officials following the arrival of Secretary Tillerson and his aides in Foggy Bottom.  If Mr. Ueland’s nomination survives the current churn, he would be wise to seek assistance from Kennedy during his transition. Whether you like Patrick Kennedy or not, he was the longest serving M at State and no one who knows him questions his dedication to the institution. He also made Foggy Bottom run. The new secretary of state cannot focus his attention on the business of diplomacy if his own building and the people in it are in disarray.

In related news —

Stephen Akard, the nominee to be the next Director General of the Foreign Service has now been withdrawn. We are hearing that a career nominee for DGHR is forthcoming but we don’t have a timeframe for when the announcement might happen. We are guessing that the DGHR position could be among the first that will be announced in the next few weeks leading to Secretary-Designate Pompeo’s confirmation hearing.

Although Akard was a former FSO, his nomination as DGHR was fairly unpopular in the career service and even among retirees, and we understand that the State Department leadership, particularly the Deputy Secretary is aware of this. We think that the withdrawal of the Akard nomination and the announcement of a respected career diplomat as the new DGHR nominee could give the new secretary of state and the career service a fresh start without the baggage of bad feelings casting a shadow over Pompeo’s transition as the country’s top diplomat.

And for those not too familiar  with State, DGHR is one of the bureaus and offices that report to the Under Secretary of State for Management. We have to point out that when the next DGHR is nominated and confirmed, the Acting DGHR right now would presumably be overseeing the Senate-confirmed DGHR in his capacity as the new Deputy Under Secretary of State for Management.

Oh, lordy! We can’t wait to read all your oral histories!

image via imgur

Via history.state.gov:

Deputy Under Secretaries of State for Management

The Department of State by administrative action created the position of Deputy Under Secretary of State for Administration, after Congress authorized ten Assistant Secretary of State positions (two of which could be at the Deputy Under Secretary of State level) in the Department of State Organization Act of 1949 (May 26, 1949; P.L. 81-73; 63 Stat. 111). Between 1953 and 1955, the ranking officer in the Department handling administrative matters was the Under Secretary of State for Administration. The Department re-established the position of Deputy Under Secretary for Administration in 1955, after Congress authorized three Deputy Under Secretary positions in the State Department Organization Act of Aug 5, 1955 (P.L. 84-250; 69 Stat. 536). The Department of State by administrative action changed the title of the position to Deputy Under Secretary of State for Management on Jul 12, 1971.

The position of Deputy Under Secretary for Management was discontinued when an Act of Congress of Oct 7, 1978, established the permanent position of Under Secretary of State for Management (P.L. 85-426; 92 Stat. 968).

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Trump Formally Nominates Pompeo to be 70th Secretary of State as Tillerson Exits

Posted: 3:14 am  ET

 

Plus 1:

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Why Tillerson Not Sullivan Needs the Town Hall: Morale Is Bad, “S” is Accountable

Posted: 3:01 pm PT
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On August 8, while Secretary Tillerson remains on travel (seen in Thailand with Foreign Minister Pramudwinai in Bangkok), Deputy Secretary John Sullivan had a town hall with employees at the State Department.

According to Politico, the State Department’s No. 2 official assured staffers Tuesday that plans to restructure the department would take their concerns into full account, comparing the coming changes to U.S. military reforms following the Vietnam War. The report notes that his “reference to post-Vietnam reforms in the U.S. military suggests major changes are afoot; the military saw major changes in organization, doctrine, personnel policy, equipment and training.”

While it certainly is a good development that employees were able to hear directly from the deputy secretary and he did take and answer questions, we remain convinced that Secretary Tillerson himself needs to do the town hall, not his deputy. Secretary Tillerson often talks about accountability as one of his three core values, one that he asked his employees to adopt.

Well, morale is bad. And S is accountable. Folks need to see him and hear him address their concerns.

Had Secretary Tillerson and his inner circle expended the necessary time and energy to get to know the building and its people during the transition before jumping into reorganization, they would not be battling bad press every day six months into Tillerson’s tenure.

Politico also reported that toward the end of the town hall, Mr. Sullivan “urge State staffers not to believe everything they read in the press about what is happening in the agency.” 

Okay! So that’s funny.

This was going to be our one post on the town hall, but we saw that Mr. Sullivan had now given an on-the-record briefing to members of the press regarding his town hall. So, we will do a separate post dedicated to Mr. Sullivan’s town hall.  While still working on that, we have three points to make quickly.

One, the press did not invent these stories. State Department folks in and out of service are talking to media outlets. We’ve never seen these many sources talking to the press in all the years that we’ve covered Foggy Bottom. The press reports these stories, of course, some with less restraint than others, and some without context; that’s just a couple of the complaints we’re heard. Is this healthy for an organization that is already undergoing stresses brought about by the re-organization? Obviously not. And Foggy Bottom is practically a rumor machine these days.  But there’s a reason for that.  If folks are talking, that’s because management is not doing a good job communicating with the employees. Heck, we have more folks reading this blog this year, and it’s not because we’re irresistibly entertaining.

(Hello to our 500,000th visitor this year! We’re glad to see you here!)

Two, there’s a lot that the Tillerson Front Office is doing that we don’t understand. And that’s okay, we’re not privy to their thinking or their plans. And since the State Department’s Public Affairs shop has put us on its shit list (you know, for laughing out loud during April Fools’), there’s no way to get an official word from the Building.  If we’re using our own resources without official comments from Foggy Bottom to help explain whatever it is they’re doing, just know that we did not ask them to put us on their shit list. That was perfectly voluntary on their part.

So anyway, when people — who have dedicated their lives to this organization for years, who have gone through other transitions and survived, who have served under Democratic and Republican administrations and supported the policies of those administrations when they were in office (as they’ve affirmed when they were appointed to these jobs) — when those folks throw up their arms in frustration and distress, and they, too, do not understand, then we have to sit up and pay attention. It doesn’t help that Secretary Tillerson and his immediate people, when they do talk uses descriptions of what they’re doing as if they’re in an alternate universe. “No preconceived notions,” “employee-led reorganization” “no chaos” — we do not need to be a genius to recognize that those are talking points intended to shape their preferred narrative.

Three, the notion that Secretary Tillerson and his people arrived at Foggy Bottom where everything is broken, and they are there to fix it is kinda funny.  They did not know what they did not know, but that did not deter them from doing stuff, which broke more stuff. Perhaps the most substantial reinvention of the State Department in modern times, about systems, and work, and people, happened during Colin Powell’s tenure. That happened because 1) Powell was wise enough to recognize the value of the career corps; and 2) he brought in people who were professionals, who knew how to work with people, and — let’s just say this out loud — people who did not have atrocious manners.

When Secretary Powell showed up in Foggy Bottom in January 2001, he told State Department employees, “I am not coming in just to be the foreign policy adviser to the President,… I’m coming in as the leader and the manager of this Department.”  The building and its people followed Secretary Powell’s lead because they could see that his actions were aligned with his words. And of course, Secretary Powell did not start his tenure by treating career people with 30-year service like trash by giving them 48 hours to clear out their desks.

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Is @StateDept Reporting Its Vacant Positions Under the Vacancies Reform Act? Barely, According to GAO Database

Posted: 1:56 am ET
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The Federal Vacancies Reform Act of 1998 (Vacancies Reform Act) was enacted on October 21, 1998. (Pub. L. No. 105 -277, Div. C, tit. 1, §151, 112 Stat. 2681-611-16, codified at 5 U.S.C.§§3345-3349d.) The provides new rules for the temporary filling of vacant executive agency positions that require presidential appointment with Senate confirmation. According to the Government Accountability Office, under the Act, an acting officer may serve in a vacant position for no longer than 210 days, with adjustments to be made if the President submits a nomination to fill the position and under other specified circumstances.

The Act requires executive departments and agencies to report to the Congress and to the Comptroller General (GAO) certain information about a vacancy immediately upon the occurrence of events specified in the Act. The Act also provides that the Comptroller General report to specified congressional committees, the President, and the Office of Personnel Management if the Comptroller General determines that an acting officer is serving longer than permitted by the Act.

The GAO notes that its database includes only vacancy information that federal departments and agencies have actually submitted to GAO and may not be complete or the most up-to-date information regarding those vacancies.

The Partnership for Public Service’s  appointment update notes that 48 positions have been referred to the Senate Foreign Relations Committee, 16 have been reported out, and only 9 have been confirmed as of July 31, 2017. PPS’ Political AppointeeTracker for the State Department includes 131 positions.

The State Department has only 36 vacant positions reported to the GAO.  The GAO database for State Department includes one filled vacancy, the Secretary of State, zero officials with pending nominations, 24 positions with identified acting officials (some of those listed have since left the positions), and the rest are positions with no acting officials.

Here’s the relevant part going forward with a ghost town at the top floors of the State Department, via the GAO:

If a vacancy exists during the 60-day period beginning on a transitional inauguration day, the 210-day period begins 90 days after such transitional inauguration day or the date the vacancy occurs, whichever is later. 5 U.S.C. § 3349a(b). The State CFO position became vacant on January 20, 2009, the transitional inauguration day. Accordingly, the 210-day period began to run 90 days after January 20, 2009—on April 20, 2009—and ended on November 16, 2009. Consequently, the position should have been vacant beginning November 17, 2009, until June 12, 2012, when the position was filled.  […]  We have previously determined that using the acting title of a position during the period in which the position should be vacant violates the time limitations in the Vacancies Reform Act.

The item above is from the GAO report on the Violation of the 210-Day Limit Imposed by the Federal Vacancies Reform Act of 1998—Chief Financial Officer, Department of State when James Millette served as Acting CFO at State after November 16, 2009, through on or about November 15, 2011.

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Making Sense of Tillerson’s Rescinded Delegations of Authority @StateDept

Posted: 5:07 am ET
Updated: Aug 11, 2:24 pm PT
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We recently blogged about the rescinded delegations of authority at the State Department (see Tillerson Rescinds Delegated Authorities Department-Wide, Further Gums Up Foggy Bottom).  A State Department official (SDO) told Politico that Tillerson only rescinded three delegations of authority. Just three.  SDO frequently is the attribution used when the folks at the State Department press shop do not want to speak on the record.  The same official who commented to Politico also said Tillerson has requested the Under Secretaries to undertake an immediate review of the remaining authorities. The SDO forgot to remind himself that the State Department currently do not have Under Secretaries but only one Under Secretary (P).

The sources who informed us of the rescinded authorities are SDOs but are not part of the agency’s press office.  They are folks who are not known for running around with their hair on fire.  One of them told us “all”, another confirmed that it was “department-wide,” and that’s the story we ran.  One of our sources subsequently told us that decisions will be made quickly on which authorities will be redelegated. It was pointed out to us that some will be quick and obvious to make like authorities concerning consular services.

We understand that there is also a memo floating around outlining the delegations of authority that have been rescinded.

 

DA-14: Delegation of Authority to Under Secretary for Political Affairs (P) and the Under Secretary for Management (M), January 18, 2017
(no text publicly available)

One the three authorities the State Department said it rescinded was DA-14 dated January 18, 2017 granted by then Secretary Kerry to the Under Secretary for Political Affairs (P) and the Under Secretary for Management (M) that the State Department says “allowed for almost unlimited re-delegation of those authorities.”  DA-14 has not/not been published in the Federal Register nor the GPO so we don’t know all the details that it covered.

A former State Department official (SDO) familiar with this issue, however, told us that the January 18 delegation was essentially envisioned as “a temporary, unlimited delegation of authorities to P and M because it was anticipated that there would be no “D” and perhaps no “S” for some period of time” and that its revocation “would not have a dramatic effect” on operations.  According to the former SDO, the revocation of this specific DA is not surprising since the Secretary and the  Deputy Secretary are now both in place.  The former official further told us that rescission of ALL of the delegations of authority would be much more significant but said, “I can’t imagine that all of the delegations were rescinded.”

The former SDO added that “If the Secretary did revoke all of the delegations one would hope that this would be very temporary.” The former official explained that “Without delegations in place, any decisions that by law lie with the Secretary literally would need to be made by the Secretary. This could result in significant delays, including on decisions that are by and large technical.”

A piece published by the New York Times over the weekend notes that “all decisions, no matter how trivial, must be sent to Mr. Tillerson or his top aides: Margaret Peterlin, his chief of staff, and Brian Hook, the director of policy planning.” 

A Foggy Bottom worker bee told us that whether or not Tillerson rescinded delegated authority “the effect is the same –the paper goes to him.” FBWB added that “In normal circumstances we would know the staffers in S, as we do in other 7th floor offices, and can keep paper moving with a telephone call” but that this is now “unknown” territory.

So what does it mean if ALL decisions must now go up to the Secretary of State?

Please don’t tell us that the next wrinkle we’re going to hear would be folks unable to PCS (Permanent Change of Station) because Tillerson is traveling and is unable to approve travel orders.


DA 284-1: Delegation of Authority to the Under Secretary for Political Affairs, Feb 13, 2009

Text: Delegation of Authority No. 284–1

By virtue of the authority vested in me as Secretary of State by the laws of the United States, including 22 U.S.C. 2651a, I hereby delegate to the Under Secretary for Political Affairs, to the extent authorized by law, all authorities and functions vested in the Secretary of State or the head of agency by any act, order, determination, delegation of authority, regulation, or executive order, now or hereafter issued. This delegation includes all authorities and functions that have been or may be delegated or redelegated to other Department officials but does not repeal delegations to such officials.

This delegation shall apply only when the Secretary, the Deputy Secretary, and the Deputy Secretary for Management and Resources are absent or otherwise unavailable or when the Secretary or either Deputy Secretary requests that the Under Secretary exercise such authorities and functions.

Notwithstanding this delegation of authority, the Secretary of State, the Deputy Secretary of State and the Deputy Secretary of State for Management and Resources may exercise any function or authority delegated by this delegation.

This is one of the three DAs cited  by the State Department official to the press.  The language is clear that this authority apply only when the Secretary and the Deputy Secretary are “absent or otherwise unavailable” or “when the Secretary or either Deputy Secretary requests that the Under Secretary exercise such authorities and functions.”

Excuse us, but this is perplexing to us, ok? If Secretary Tillerson and Deputy Secretary Sullivan are traveling who has authority over the State Department in their absence if it’s not going to be the third highest ranking person in the agency?

A separate source  familiar with inner workings at State but has no direct knowledge of these developments suggested that the Delegation of Authority exercise exposes more than anything else “the profound lack of knowledge and grasp” on the 7th floor especially with the political appointees.  This source says that there are practical and long standing reasons for delegations to D and P of certain things, such as making it possible for Tillerson to seamlessly have things done without having to go through the “Acting” designation every time he’s not around or unavailable. It appears that no one understood that.

And no one thought about asking the Office of the Legal Adviser?

 

DA 280-1: Delegation by the Secretary of State to the Under Secretary for Political Affairs of Authorities Regarding Congressional Reporting Functions, Feb 13, 2009:
Text: Delegation of Authority No. 28o–1 

By virtue of the authority vested in me as Secretary of State by the laws of the United States, including 22 U.S.C. 2651a, I hereby assign to the Under Secretary of State for Political Affairs, to the extent authorized by law, the function of approving submission of reports to the Congress.

This delegation covers the decision to submit to the Congress both one-time reports and recurring reports, including but not limited to those recurring reports identified in Section 1 of Executive Order 13313 (Delegation of Certain Congressional Reporting Functions) of July 31, 2003. However, this delegation shall not be construed to authorize the Under Secretary to make waivers, certifications, determinations, findings, or other such statutorily required substantive actions that may be called for in connection with the submission of a report. The Under Secretary shall be responsible for referring to the Secretary, the Deputy Secretary, or the Deputy Secretary for Management and Resources any matter on which action would appropriately be taken by such official.

Any authority covered by this delegation may also be exercised by the Deputy Secretary and the Deputy Secretary for Management and Resources, to the extent authorized by law, or by the Secretary of State.

This is the last of the three DAs cited by the State Department as having been rescinded by Tillerson. According to Reuters, the authorities regarding congressional reporting functions will now go to the Office of Policy Planning (S/P), The current S/P head is a member of Tillerson’s inner circle, Brian Hook. The position does not require Senate confirmation.  Three former officials told Reuters that giving the policy planning staff final sign-off on the reports could inject political considerations into their preparation.  (For what it’s worth, a Foggy Bottom denizen who knew Mr. Hook during his prior stint at State during the Bush administration told us that he is “very smart and thoughtful — a good pick for the head of the policy shop — and also really a nice man.”)

S/P was created in 1947 by George Kennan at the request of Secretary of State George C. Marshall. The office serves as a source of independent policy analysis and advice for the Secretary of State. According to state.gov, the Policy Planning Staff”s mission is to take “a longer term, strategic view” of global trends and frame recommendations for the Secretary of State to advance U.S. interests and American values.

Note that there are at least 300 congressionally mandated reports required by Congress. So S/P will now have sign off on all those reports? The rumors of an expanding S/P empire is in all likelihood, true, because how are you going to clear all these reports?  And if this is the case, who’s going to be doing “longer term, strategic view” for the State Department if S/P is signing off on all reports and every policy memo? What’s the career diplomat at “P” going to be doing?

One other thing pointed out to us, particularly on the delegation to P for signing off on reports to Congress is that these reports must have a “policy sign-off.”  We understand that the Bureau of Legislative Affairs (H) never had this function which is primarily coordination of legislative activity/strategy and principally as liaison to Congress.  Apparently, the 7th floor is not even aware of this and was under the assumption that the bureau’s responsibility to “transmit” reports is the same as responsibility to “sign-off” for policy purposes.

Did somebody send the Office of the Legal Adviser (L) a smoke signal for help?

NOTE: Delegation of Authority: 245-2 Delegation from the Secretary to the Deputy Secretary, July 31, 2017 to be published in the Federal Register on August 14, 2017. This DA supersedes Delegation of Authority 245-1, dated February 13, 2009. PDF

AND NOW THIS —

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