so, i got the review from the department, and, as expected, it's not worth the bytes required to store it.
it's not even a review per se. it's simply a two page letter that states that they uphold the decision. there's no legal component to the document whatsoever, and no attempt was made to react to my arguments. so, if my basis for review was that the chief did not look at the correct legal questions, there is no evidence that the review attempted to even address that.
if this is what this bureau does, it should really be abolished. the purpose of these panels is to attempt to keep cases of the sort out of the court system. but if they refuse to actually do their jobs - through lengthy and unnecessary delays - and everything just ends up in court anyways, then there's not any reason for them to exist. we should just go straight to court, which is where we're going to end up, anyways.
as mentioned previously, i wasn't expecting anything better from this; i was aware that this proces is a waste of time. but, the statute requires that i go through the process. so, all that would have happened if i had filed immediately would have been that the judge would have sent the issue back to the panel.
i am essentially going to be arguing for absolute gross institutional incompetence on behalf of the oiprd, and asking the judge to adjudicate directly.