| Comment Number: | OL-10505054 |
| Received: | 3/10/2005 2:34:47 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:
The FRN, page 7553, says that the law (PL 108-136) provides DoD and OPM - in collaboration with employee representatives - authority to establish a flexible and contemporary system of civilian human resources management. There is no collaboration with employee representatives here. One hundred twenty-seven (127!) members of Congress had to write and sign a letter to Secretary Rumsfeld and Director James, instructing them to comply with the wishes of Congress to discuss the NSPS proposal with the employees' representatives. This proposal is fully of 'implementing issuances' that will not be collaborated with representatives. And it further severely restricts the opportunities for collaboration. In the words of the FRN, NSPS violates PL108-136 because it denies collaboration.