| Comment Number: | OL-10508444 |
| Received: | 3/15/2005 8:43:35 AM |
| 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:
In your Myths and Facts document, you state, 'The proposed NSPS regulations are the product of a broad-based, collaborative effort across the Department that began in 2004. This included a number of meetings with employee representatives involving extensive and fruitful discussions on potential options for the design of the system. In several areas, the proposed regulations reflect the interests and concerns that were voiced during those consultation sessions. We also held numerous focus groups and town hall meetings, many of which included local union involvement, to gather input and feedback on the system design. Now that we have published our proposed regulations, the next step in this process is to gather comments and recommendations on the proposed regulations, and engage in more discussions.' Now for the rest of the story! True, the Department did meet with the Unions as stated, but meaningful dialogue did not occur. We met, they checked off block on the “things to do” list and then they moved on. As for those 'focus' groups, I cannot comment other than to say that I believe it was just another notch on the list of things to complete. No Union or employee focus group would ever have concurred with the language in this proposal (i.e. giving the Secretary sole, exclusive, and un-reviewable powers, mandatory removal offenses, loss of COLAs, no employee representation on pay panels, etc…). The Department is just going through the motions without any real intent to include stakeholder concerns or recommendations.