Comment Number: OL-10507863
Received: 3/14/2005 3:36:03 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:

DoD employees and their unions are like our counterparts at the DHS, compelled to comment on what is, at best, a 'rough draft' or skeletal plan. The unions are now forced to exercise their statutory collaboration rights on vague outlines, with no fair opportunity to consult on the 'real' features of the new classifications, pay and performance system. This circumvents the congressional intent for union involvement in the development of any new systems, as expressed in Public Law 108-136.