| Comment Number: | OL-10506843 |
| Received: | 3/13/2005 4:08:08 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:
Section 919, "Collective bargaining above the level of recognition" is misleading, since the provision authorizes bargaining only at the DoD and Component levels, rather than subordinate command levels above the level of recognition, it would be more appropriately titled, "national level bargaining above the level of recognition." Subsection 919(b)(6) does not fit in the 919(b) subsection of "Any such agreement reached in these negotiations will--Be subject to impasse resolution by the Board under procedures prescribed by the Board..." because issues referred to impasse resolution are those where the parties are unable to reach agreement. That section should be 919(c) stating: "Negotiable impasses may be resolved by the Board..." Also, (7) should be (d) and (8) should be changed to (e) because those sections do not make sense under the draft language of subsection 919(b).