| Comment Number: | OL-10504096 |
| Received: | 3/8/2005 12:49:29 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:
Our first comment applies to the proposed regulations as a whole. There is a tremendous amount of fundamental information left out. The proposed regulations repeatedly state that more detail will be provided by “implementing issuances” at some point in the future. This will include such items as the identification of “mandatory removal penalties,” the appeal process for performance ratings, the identification and description of premium pay and the procedures to be used by the NSLRB in resolving unfair labor practice charges, negotiability appeals and impasses. These “implementing issuances” are just as much a part of the NSPS as what has been proposed so far. They will be subject to the same collaboration, mediation and notice to Congress requirements the NSPS law requires for these proposed regulations. Thus, even if the proposed regulations became final in 60 days, they could not be implemented until the rest of the NSPS is subjected to the same process. It seems to us that DOD ought to propose the entire NSPS at once. Why is DOD being allowed to implement a new system without all of the information being in writing before it is we are changed to this personnel system? Is it so they can do whatever they want because we will already be under this system and not be able to change it after the fact?