Comment Number: OL-10501633
Received: 2/27/2005 1:54:17 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:

Comments concerning - Federal Register: February 14, 2005 (Volume 70, Number 29) Proposed Rules: FR Document 05-2582/NSPS (National Security Personnel System) Page 7570: "To carry out its national security mission, the Department must have the authority to take actions quickly when circumstances demand; it must be able to develop and rapidly deploy resources to confront threats in an ever-changing national security environment; and it must be able to act without unnecessary delay." Is that not the logic used that brought on prisoner abuse at Abu Gharib prison in Iraq. In other words, bad planning on your part is not an emergency on my part. This section allows DoD to react to situations that planning and worker flexibility they already possess would have made unnecessary. This section prevents the examination of DoD failures by quickly shifting personnel and resources to an emergency (or a so called emergency) to cover its mistakes, regardless of how the shift leaves other areas thin, unprotected, and subject to failure. If DoD would look critically and examine its needs and resources (not wants, whims, or wishes), DoD would be able to fulfill its obligations without resorting to ad hoc quick fixes. Without stability and stable rules, the situation will deteriorate rapidly to unacceptable levels of performance. The gutting of labor law, especially 5 USC 71, will send us down that road. "Where management is not required to negotiate over procedures stemming from the exercise of its rights, the proposed regulations provide a mechanism for obtaining an exclusive representative's views and recommendations regarding such procedures." Labor can now write a letter. It will be given little attention now and even less under NSPS. There is no need to trample on decades of labor law and fundament rights granted under the Constitution and Bill of Rights (assembly, petition) and spend countless millions of dollars to change the system when all the tools, rights, and power already exist. "Determination of Appropriate Units for Labor Organization Representation" This section guts local representation that has more that satisfactorily represented the needs of local commands and units for decades. False statements and accusations of untrustworthiness are made in this section.