| Comment Number: | OL-10508416 |
| Received: | 3/15/2005 8:18:05 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | DOD Letter.doc Download Adobe Reader |
Comments:
March 14, 2005 What follows are my comments on the Department of Defense National Security Personnel System, 5 CFR Part 9901. The agency names are the Department of Defense and the Office of Personnel Management. The docket number is NSPS-2005-001 and the Regulatory Information Number is 3206-AK76. The proposed rule appeared in the February 14, 2005 Federal Register, starting at page 7552. I strongly feel that this rule as written should not be implemented. Taken as a whole, this proposal is heavily biased towards weakening rights of DOD employees while doing little, if anything, to enhance the flexibility of the Department, the efficiency of the workers or the security of the country, and in fact is often counterproductive to those goals. As an example of the problems with the proposed rule, I offer Section 9901.905 which allows the Department to void collective bargaining agreements unilaterally. The effect of this will be to make collective bargaining meaningless and consequently to strike a significant blow to employee morale. The workforce responds to the respect to which it is shown. Another serious problem is with Section 9901.907 which establishes a labor relations board which is totally controlled by management. This board is given authority to control resolution of all matters of negotiability, effectively allowing management to decide when management has overstepped its bounds. An independent entity is necessary for checks and balances to be fact, not fiction. A third serious defect in the rule is the issue of leaving many items to be addressed by implementing issuances which would be announced, again solely by management, at some future time. These problems and numerous others make this proposed rule a giant step backwards on the road to good labor-management partnership. Since this rule is expected to become the model for other departments (and ultimately as a model for private industry), it is imperative that the Department’s workers be treated fairly and with respect, and not as the enemy. In closing, I again voice my opposition to this rule as proposed. I would suggest that if a change in the current rule is truly needed then a new proposal should be created with fairness and respect being included from the start. Respectfully, John Rowen Pennsylvania