COMDTINST 5860.2A
(3) procedures for responding to requests from members of Congress and Congressional staffs
for drafting assistance and technical advice on legislative issues.
b. This Instruction does not address:
(1) Testimony and budget materials. Preparation and clearance of Congressional testimony by
Coast Guard witnesses, reports to Congress, and preparation and clearance of Coast Guard
budget and appropriations materials should be coordinated with the Office of Budget and
Programs (CG-82). See reference (c) for additional guidance.
(2) Regulations. The Office of Regulations and Administrative Law (G-LRA) coordinates
preparation and clearance of proposed Coast Guard regulations and review and comment on
other agencies' proposed regulations.
(3) Congressional liaison. Communications with Congress on other issues should be
coordinated with the Office of Congressional Affairs (G-ICA) and CG-82.
(4) Legal opinions and advice. Questions about the application or interpretation of current laws
should be addressed to the appropriate servicing legal office.
7. COAST GUARD LEGISLATIVE STRATEGY.
a. Consistency with Administration policy. The Coast Guard's legislative program must carefully
balance a number of factors to achieve the greatest potential for success. Each proposed
legislative change is thoroughly reviewed by DHS, OMB, other Executive departments and
agencies, and Congress. To reach Congress, Coast Guard legislative proposals must be
consistent with DHS objectives, the President's annual budget proposal, and overall
Administration policies. Any provision that is inconsistent will face intense scrutiny during the
clearance process and is extremely unlikely to be approved for transmittal to Congress. As a
general rule, legislative proposals that seek to "drive" the budget process by statutorily imposing
resource requirements or overcome opposition to specific regulatory actions are unlikely to be
successful. See reference (a), OMB Circular A-19, for details on OMB clearance of proposed
legislation.
b. Scope of Change. Generally, the Coast Guard has the greatest chance for successfully achieving
legislative changes in those statutes that grant authority or apply specifically to the Coast Guard.
These statutes are found primarily in titles 14, 33, and 46 of United States Code. Whenever
possible, legislative proposals should be narrowly tailored to Coast Guard-specific authority
rather than seek changes to government-wide provisions. Additionally, any proposed change
that affects another department or agency (e.g., GSA property management authority) must be
closely coordinated with that other department or agency.
c. Justifying requested change. Congress is often unwilling to grant authority in the abstract.
When seeking a change to or an increase in authority, the Coast Guard must be able to clearly
explain why the change is needed and how it intends to use the new authority to address a
specific problem. Objective data and real-life examples are especially helpful, while seeking
authority for its own sake with no specific plan for its use is unlikely to be successful. Similarly,
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