| Comment Number: | OL-10507679 |
| Received: | 3/14/2005 1:55:04 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:
Reference § 9901.607 Retention standing. (a) Retention list. Within each competitive group, the Department will establish a retention list of competing employees in descending order based on the following: (1) Tenure, with career employees (including employees serving an initial probationary period) listed first, followed by other employees on term appointments and other employees as identified in DoD implementing issuances. (2) Veterans’ preference, in accordance with the preference requirements in 5 CFR 351.504(c) and (d), including the preference restrictions found in 5 U.S.C. 3501(a); (3) The rating of record, in accordance with DoD implementing issuances; and (4) Creditable civilian and/or uniformed service in accordance with 5 CFR 351.503 and 5 U.S.C. 3502(a)(A) and (B). The Department may establish tie-breaking procedures when two or more employees have the same retention standing. My comments: Recommend (1) above be changed to delete "followed by other employees on term appointments and other employees as identified in DoD implementing issuances." Recommend (4) above be moved to (2) and the words "and/or uniformed" be deleted. I have over 24 1/2 years creditable Civil Service time, and I would like that to count higher for RIF purposes--also do not believe military personnel who retire and move to Civil Service should be given as much consideration for active-duty time under creditable service. This whole NSPS discriminates against current Department of Defense Civil Service employees, gives preference to retiring military so they can just roll over from military to civilian service, and is moving back to the good ole' boy system. Although I have received nothing but the highest ratings for the past 24 years, I fear for my career under this system as I am now over 50 years old and have never been in the military.