Comment Number: OL-10507850
Received: 3/14/2005 3:32:36 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:

Chapter 71 USC should be the 'floor' of any labor relations system DoD and OPM design. The apparent design of this plan is to minimize the influence of collective bargaining so as to undermine the statutory right of employees to organize and bargain collectively. When it enacted provisions to protect collective bargaining rights, Congress did not intend those rights to be eviscerated in the manner that your concepts envision. Any regulation reflecting any of the ideas listed above is unacceptable and contrary to law.