Comment Number: | OL-10506815 |
Received: | 3/13/2005 11:11:14 AM |
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:
You're going to implement NSPS in spirals, with the first agencies and organzations converting to NSPS as early as July 2005. The comment period for this proposal ends 16 March 2005. These comments must be read, evaluated, considered, and at the least, published in the final FRN, which can't happen for at least 30 days. Then you have to 'develop' the remainder of this system - that is all the procedures, issuances, etc. that according to the propsal haven't been designed yet, and get these in place BEFORE July 2005. No reasonable person on earth will believe that you don't already have the procedures and policies already defined and ready to go. You are being untruthful in this endeavor. I suggest that you cancel this FRN, republish it with all the missing pieces, and delay the first spiral implementation until employees, unions, and the general public have a true chance to comment.