| Comment Number: | OL-10504991 |
| Received: | 3/10/2005 2:19:48 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:
9901.409(b)(2) There is no information on how the rating of record affects retention standing. The only thing that the notice says is that the rating of record affects standing. Retention standing is a very big deal and not providing that information is a major flaw. Additionally, the sections that deal with RIFs don't mention rating of record in factors that the Department may use in development of retention lists. There is logical inconsistency between the goal of using rating of records in retention lists and how retention lists are developed. It is such an fundamental inconsistency, that the inconsistency casts doubt on the whole NSPS, as written.