Subject: Re: For Urgent Review and Comment - Blue Book Commentary
From: Charles Greenlaw <cgreenlaw(--nospam--at)speedlink.com>
Date: Mon, 24 May 1999 17:58:54 -0700
Part TWO of Two. First part, with history and original commentary,
posted shortly before.
Suggestions and Comments on Draft Commentary:
Since the current Seismology Committee believes the 1997 UBC "has not
changed the state of practice in this respect, nor did it intend to," [Ali
Sadre, 5-12-99] it is not clear why the Seismology Committee should have
abandoned the original Commentary pertaining to that longstanding practice,
and instead have substituted in new commentary that loses the original
crispness and sense of purpose, and muddles along vaguely.
It seems that a better course would be to restore the original 1973
commentary, and selected updates, and enhance that with additional
clarifying information, such as genuinely confirmed lessons from Northridge
None of the five draft Commentary paragraphs shown to us speak to the
APPLICABILITY of "flexible" diaphragm determinations in the context of
actual code language. It appears the Committee in fact does not understand
this applicability thing, either from the language of the code, its history,
or past versions of pertinent commentary.
The paragraph No. 2 appears to beg the question of whether the Commentary is
informing code users, or that a "large majority" of code users are informing
the Committee, which then deems them correct simply because they prefer a
certain method, and the committee doesn't really know better than this
majority does. The second sentence of paragraph No. 2, beginning with
Observations, is limited in scope compared to the first sentence it purports
to explain, and is vague in multiple ways to the point of uselessness. What
does a person use that sentence for? Think how Pres. Clinton or Rep. Hyde
could parse those words' meanings at each other.
The big talent to become an SE is number-crunching. But regulation writing
and regulation explaining uses a completely different talent: Wordsmithing
and knowledge of interpretation of regulatory adoptions in the legal sense.
That's why the legislature has an office of lawyers, not engineers, to keep
its legislative proposals coherent, coordinated, and in context with
existing law. Same for appellate courts, whose writings are masterful.
State regulations other than building regulations are routinely challenged,
plan-reviewed, and rejected for shortcomings in demonstrated Necessity, in
Clarity (such that affected persons aren't confused or burdened with
multiple meanings,) and in Consistency with itself and with related
regulations. SEAOC should voluntarily comply with these regulatory
wordsmithing standards as a sense of pride and a duty of due care to its own
members and others similarly affected. Office of Administrative Law sells
guideline pamphlets on how to write regulations skillfully.
The most appalling thing about so many SEAOC endeavors in modern times is
the degree to which its controlling participants don't know what they don't
know, and don't seem to care.
Charles O. Greenlaw SE Sacramento CA