Comment Number: OL-10504956
Received: 3/10/2005 2:10:25 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 her letter on 9 Mar 04 to Secretary Rumsfeld, OPM Director James states, "... The issuance of broad enabling regulations will give you far more internal flexibility as you implement NSPS. Once those enabling regulations are publined in the CFR, you will be in a position to issue as manay standardized, detailed internal NSPS implementing directives as and when you see fit, including the document you have provided us for comment - generally withoug further public comment, formal collaboration with unions, or OPM approval." However, Director James states previous to this paragraph that there are several major flaws with the document presented. This is a conflict - how can the head of OPM say there are flaws in a document, then give instructions on how to proceed with implementing the document?