Comment Number: OL-10504115
Received: 3/8/2005 1:37:01 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:

WorkForce ReShaping. DOD is headed by a political civilian and the next several civilian layers of management are political civilians, naturally setting a heavy political tone. The current Reduction in Force system, refined over the years, allows restructuring to occur but provides some measure of employee protection from targeting political firing. The proposed NSPS work force restructuring plan, with its proposed multiple ways of isolating employee groups by geographical area or unit or funding line, etc, and at the same time shrinking displacment opportunities, would allow heavy political influence in firing actions, and subject all employees to severe RIF risk, almost at will, by management. The current RIF procedures should not be changed to the proposed NSPS RIF procedures during the first implementation phase in 2005, pending additional review and comment. This is a serious area needing careful analysis and broad discussion.