from Nate's letter: "mandatory reporting and prevention training for adult members who have regular contact with minor athletes"
Regular contact means routine or on-going participation in activities directly with minors.
Regular contact means ongoing interactions during a 12-month period wherein an Adult Participant is in a role of direct and active engagement with any Minor Athlete. This includes coaches, and team managers, staff, physicians and trainers.
source: https://www.lawinsider.com/dictionary/regular-contact
What I see above are roles whereby the person is in extended, direct personal contact or frequently recurring contact. The roles appear to be associated with adult positions assigned to manage or lead groups of youth by the designation of that role.
Again, from Nate's letter: "The definition of regular contact is debatable but typically covers coaches, instructors, officials, leadership boards and national team members."
I think no one debates the appropriateness of coaches, instructors, and team leaders of youth teams. However, officials is where the debate starts. There is nothing that I see in the law that states that ALL officials in a sport where sometimes youth may participate must be BGC-ed. This is the part where USA-WSWS needs to regroup.
Nate's letter then cites California and Show Skiing as reasons to force this on the entirety of the sport divisions. Those are irrelevant to the bulk of our states and divisions. It is clear to me that USA-WSWS feels ill-equipped to handle local municipality or unrelated sport divisions separately.
Both Nate and my regional EVP have asked for ideas and help. I have not yet responded, because I don't get any sense that they see anything as negotiable, flexible, or up for modification.
I do have a poorly developed idea. So, consider this a rough draft. We have Assistant, Regular, Senior, and Emeritus official levels. We have functional designations (driver, judge, safety, scorer, etc.). We have a database which tracks our ratings.
Simply add "-B" to those who voluntarily submit to the BGC.
Thus, the database would contains two flavors for all existing designations. An assistant judge would be "AJ" while another with BGC would be AJ-B. When the LOC sanctions an event, the LOC can decide to allow under 18 or not to participate. If they chose to allow under 18, then they must secure "-B" officials for their event. Events with no competitors under 18 have no risk for USA-WSWS and therefore could still occur in compliance with the law using normal officials with no BGCs.
Clearly, this would have a potential to reduce the number of youth-allowed sanctioned events. Also, the demand for "-B" officials might exceed the supply. The solution is simple, the parents of all youth skiers should be required to have at minimal an assistant official rating with BGC. Then, the parents can work the events in which their children participate. Many already do, so that would not be a big change in truth.