| Comment Number: | OL-10509870 |
| Received: | 3/15/2005 7:53:21 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:
NFFE LOCAL 639 provides, as the “EMPLOYEE REPRESENTATIVES,” the following comments on the Proposed NSPS Regulations—RIN 3206–AK76/0790–AH82 - NFFE Local 639 objects to the requirement, as stated in the Supplemental Information (SI at 7552) that all comments submitted must reference the regulatory text by subpart and section number as well as the Supplemental Information by page number. We believe that this requirement is inconsistent with the Administrative Procedures Act and rule-making via public comment. We further believe that this requirement will be unduly complicated to the most DOD employees. NFFE Local 639 believes therefore, that the Agency will not consider any comments which do not meet this requirement, thereby discarding a great number of critical statements from field and headquarters employees on the single ground that DOD’s unreasonable requirement is not met. To this we strenuously object and would hope that the elected representatives take notice and step in to correct this flawed process!