Comment Number: OL-10503213
Received: 3/4/2005 12:25:30 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:

Subpart F, page 7589, paragraph 9901.605. Subparagraph (a): Add "Commuting area" to the list of considerations for establishing a competitive area. It is possible that there could be several government installations in close proximity to one that is experiencing a reduction in force (RIF). Available positions at those other installations should not be considered off-limits when it comes to placing displaced employees. In addition, some of the considerations are rather nebulous. For example, does "organizational unit" mean a MAJCOM (AFMC), a center within the MAJCOM (ASC), a wing/group/squadron within the center, or a particular office (ASC/YA)? Similar ambiguities exist with "Lines of business" and "Funding lines." Finally, recommend adding the following sentence to this subparagraph: "The competitive area will be established as broadly as possible to ensure minimal adverse impact to affected employees." Subparagraph (e): Rewrite this paragraph as follows: "The Department will establish competitive areas as broadly as possible--preferably on the basis of the commuting area or geographical location. Competitive areas will not be established for the purpose of targeting individual employees for reduction in force." The current wording of this paragraph is ambiguous because the term "organizational units" is no where defined. Therefore competitive areas could be constructed at an organizational level that is so low as to, in effect, target individuals. Subpart F, page 7589, paragraph 9901.608. Subparagraph (a)(ii): Recommend deleting this sub-subparagraph. RIFs always create interruptions and disruptions of functions/jobs for all of the parties involved. In addition, there is no way to measure whether an interruption is "undue."