Comment Number: OL-10507849
Received: 3/14/2005 3:32:20 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:

The proposed section, 5 U.S.C. Section 9902(m) requires that employee representatives participate in, not simply be notified of, the development of the system. I do not believe DoD, the Secretary, nor the Director have allowed employee representatives to participate in the development of this system. In fact, DoD had previously refused to release a copy of the FRN proposal to the Coalition of Unions prior to it's publication. A letter from well over 100 Senators and Representatives requested that the copy be furnished to the Coalition - this appears the only way to make DoD live up to the law.