Comment Number: OL-10506846
Received: 3/13/2005 4:25:26 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:

Imposing another review level at DoD for appeals cases in both the adverse action and labor relations programs is contrary to the DoD claim that it is interested in resolving those cases more quickly and efficiently. In addition to SLOWING the resolution and due process procedures, it imposes a very heavy fiscal and administrative burden on an agency that is driving the country deeper and deeper into debt. DoD would be wiser to impose its adjudication requirements on the MSPB and neutral labor relations agencies of FLRA/FSIP/FMCS/OGC and evaluate the results of their adjudications after a two year period before going to the unnecessary expense of instituting an unnecessary step in those processes.