| Comment Number: | OL-10504995 |
| Received: | 3/10/2005 2:20:45 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:
DoD's schedule is such that they will receive comments on this proposal until 16 March, 2005, take time to assemble, digest and consider each one, possibly make changes, publish a final Federal Register Notice, and develop and issue all the implementing guidance, procedures, and policies before begining converting employees in organizations. The first organizations included in Sprial 1 are scheduled to begin coverage under NSPS in July 2005. I find it hard to believe that DoD has not already developed the implementing guidance, procedures, and policies - in fact any reasonable person (to quote from Subpart I, section 9901.807(d)(3)) would be hard-pressed to believe that DoD can develop the over 60 instances of implementing issuances after the final FRN is published but before July. The truth of the matter is that DoD already has the implementing guidance ready, but refuses to publish them in the FRN so that the public and DoD employees are left in the dark, and are prohibited from commenting on them. This is totally shameful.