| Comment Number: | OL-10506264 |
| Received: | 3/11/2005 1:14:05 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:
9901.712 creating a separate category and process for mandatory removal offenses is unecessary and simply inflames the argument of a heavey handed Department of Defense. The other proposed modifications to the appeals process i.e no mitigation for sustained penalties will achieve the same end. 9901.714 DoD proposes that the notice period under the crime provision will be five days advance written notice. DoD proposes the same five days as the employee's opportunity to reply to the proposed charges taken under the crime provision. If the deciding official is to fairly consider the employee's reply before rendering a decision, shouldn't the notice period be longer than the reply period? I suggest an eight day advance notice period with five days to reply to the charges.