| Comment Number: | OL-10507039 |
| Received: | 3/14/2005 7:56:16 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:
The proposed National Security Personnel System (NSPS) regulations issued by the Department of Defense (the Department) and the Office of Personnel Management (OPM) are deeply disturbing to me as a Department employee. I believe that these proposed regulations exceed the authority Congress granted in the NSPS statute in the following ways: In 5 U.S.C. 9902(m)(6), Congress required the Department to ensure that any new labor relations system provided for an independent third party review of the Department’s decisions. However, the Department’s proposed NSPS regulation 9901.907 (a)(1) intends to create a new labor relations review board, costing hundreds of millions of taxpayer dollars to invent a structure similar to the existing FLRA. Further, under proposed NSPS regulation 9901.907, the members of this board would be appointed solely by the Secretary of Defense, with no Congressional or outside oversight. This is the equivalent of the “fox guarding the henhouse,” violating Congress’ specific instructions to ensure an independent third party review. DoD and OPM should scrap their harmful proposals for NSPS and work collaboratively with employee unions to develop a new system, as Congress directed them to do!