Comment Number: OL-10506857
Received: 3/13/2005 5:14:01 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 9901.514 Non-citizen Hiring: Although historically, non-citizens have been allowed to enlist in the armed forces under restricted circumstances in order to fill certain low-skill positions, the role of DoD civilians is completely different. DoD employees are often the “corporate memory” for their organizations, and are expected to properly handle non-classified but sensitive information, the disclosure of which could cause injury to the national interest. It is inappropriate to place this trust in persons whose loyalty may be to another government. Furthermore, it is insulting to assume that only a non-citizen could fill a position of special trust within the defense establishment. Is the real intent of this paragraph to enable DoD to out-source functions to impoverished nations where rates of labor compensation and standards of workers’ rights are considerable lower than in the U.S.? While this practice may have resulted in short-term cost savings in industry, it poses a unreasonable risk to national security.