Comment Number: OL-10501150
Received: 2/23/2005 6:40:19 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
No Attachments

Comments:

I support the AFL-CIO lawsuit against the implementation of the NSPS regulations as they now stand. Congress has insisted that the DOD conduct negotiations over the construction of the language and rules with the full and fair participation of the Unions and this unfortunately has not happened. It would appear that the architects of this ponderous and discriminatory program are not interested in either abiding by Congressional direction or engaging the labor representatives in a meaningful discourse. Secretary Gordon England has maintained that a good faith effort was conducted in the process however this would appear largely anecdotal in light of the accounts by labor leaders documenting the numerous times they were shut out of the process, notified after decisions had been made and severely constrained by unreasonable time limits. There are always attendant difficulties when attempting major change to any organization, and this has truly been the case for DOD administrators. I believe that the success of any reform must be measured by the proportionate consensus arrived at by all parties involved. DOD employees would be better served by this assessment and better prepared to endorse a referendum designed to benefit all parties in an equitable and just manner. I see no consensus behind the final issue of NSPS. I see a token application of checks and balances in the system which could allow personal tendencies to guide management without the assurance of due process and the legal consequences against abuse. In short, if this is the best our Human Resources agents are capable of offering then I heartily endorse General Tony McCauliffes response to surrender at Bastogne "Aw, Nuts".