Comment Number: OL-10504460
Received: 3/9/2005 1:51:10 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:

I am concerned with the proposal for the National SEcurity Personnel System. First, the proposals would override any collective bargaining agreement and expand management rights so much that very few issues could be bargained. These proposals violate Congress's explicit order to preserve collective bargaining. SEcond, the proposals create a new labor relations review board that would take the place of an already existing federal board (FEderal Labor RElations Authority. The Secretary of Defense would have unilateral power to appoint as many members to this board as he/she desired. This is wasted money and also violates Congressional requirement to ensure independent third party review of DOD's labor relations decisions. Last, the proposal includes provision for the DOD to unilaterally reverse the decision of an administrative judge if the department does not agree that the decision was correct. This completely nullifies any third party review. This proposal for the National SEcurity Personnal System needs to be drastically revised.