Comment Number: OL-10504743
Received: 3/10/2005 9:47:11 AM
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 I, Section 9901.901 to 9901.928: The proposed changes in this section severely overstep the authority of DOD as granted by the National Defense Authorization Act of Fiscal Year 2004. There are no allowances in the National Defense Authorization Act of Fiscal Year 2004 to modify management rights or employee rights to the extent proposed. These changes strip Unions of the ability to provide basic representation to employees, with the right to appeal decisions to an independent third party, and will undermine employee’s rights.