| Comment Number: | OL-10503862 |
| Received: | 3/7/2005 8:22:22 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:
In 5 U.S.C. 9902(m)(6), Congress required the Department to ensure that any new labor relations system provided for an independent third party review of the Department’s decisions. However, the Department’s proposed NSPS regulation 9901.907 (a)(1) intends to create a new labor relations review board, costing hundreds of millions of taxpayer dollars to invent a structure similar to the existing FLRA. Further, under proposed NSPS regulation 9901.907, the members of this board would be appointed solely by the Secretary of Defense, with no Congressional or outside oversight. This is the equivalent of the “fox guarding the henhouse,” violating Congress’ specific instructions to ensure an independent third party review. It's ludicrous to think that many of those in managerial positions right now have the skills to fairly and effectively work with the employees. In education, some are there becasue they were so bad at teaching or were burnt out, while others are there via EEO settlements. To develop an entirely new system without cleaning up the entire system to start is irresponsible. To state that the unions were involved with the development and discussions of these proposals is a slap in the face - no one in their right mind would propose this manner of working with employees.