You have to add Congress to the mix.
Matter of fact, I blame Congress for most of the Acquisition ills as they wrote the rules.
(and I blame AFSOC for the CSAR-X Fiasco)
Proposed changes are made by the DAR Council and the CAA Council. According to FAR 1.201-1
(a) Subject to the authorities discussed in
1.103, revisions to the FAR will be prepared and issued through the coordinated action of two councils, the Defense Acquisition Regulations Council (DAR Council) and the Civilian Agency Acquisition Council (CAA Council). Members of these councils shall --
(1) Represent their agencies on a full-time basis;
(2) Be selected for their superior qualifications in terms of acquisition experience and demonstrated professional expertise; and
(3) Be funded by their respective agencies.
(b) The chairperson of the CAA Council shall be the representative of the Administrator of General Services. The other members of this council shall be one each representative from the--
(1) Departments of Agriculture, Commerce, Energy, Health and Human Services, Homeland Security, Interior, Labor, State, Transportation, and Treasury; and
(2) Environmental Protection Agency, Social Security Administration, Small Business Administration, and Department of Veterans Affairs.
(c) The Director of the DAR Council shall be the representative of the Secretary of Defense. The operation of the DAR Council will be as prescribed by the Secretary of Defense. Membership shall include representatives of the military departments, the Defense Logistics Agency, the Defense Contract Management Agency, and the National Aeronautics and Space Administration.
(d) Responsibility for processing revisions to the FAR is apportioned by the two councils so that each council has cognizance over specified parts or subparts.
(e) Each council shall be responsible for --
(1) Agreeing on all revisions with the other council;
(2) Submitting to the FAR Secretariat (see
1.201-2) the information required under paragraphs
1.501-2(b) and (e) for publication in the Federal Register of a notice soliciting comments on a proposed revision to the FAR
(3) Considering all comments received in response to notice of proposed revisions;
(4) Arranging for public meetings;
(5) Preparing any final revision in the appropriate FAR format and language; and
(6) Submitting any final revision to the FAR Secretariat for publication in the
Federal Register and printing for distribution.
Those making these changes are seasoned contracting professionals. The sad part is that a few (probably more than a few) have been out of execution for so long that they really have little to no knowledge any more about the actual contract writing process other than what is listed in CFR Title 48 Chapters 1 and 2. Yes, they are all SME's on the FAR and DFARS, but you tend to forget things and see how they actually work when you aren't active in execution. It is not a knock on them, it happens to everyone in just about every subject that you work in. However, it those of us in this career field do our jobs properly and contractors didn't try to play the system, there wouldn't be as much fodder to cut through to get to the meat.