| Comment Number: | OL-10510004 |
| Received: | 3/15/2005 11:25:38 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:
Section 9901.907 sets up a new National Security Labor Relations Board, Section 9901.908 outlines their duties. In order to comply with the Congressional mandate and the guiding principles and key performance parameters of: Put mission first-support National Security goals and strategic objectives; Respect the individual-protect rights guarenteed by law; Value talent, performance, leadership, and commitment to public service; Be flexible, understandible, credible, responsive, and executable; Ensure accountability at all levels; Balance HR interoperability with unique missionn requrierments; and Be competitive and cost effective. Section 9901.907 should be abolished and Section 9901.909 redefined to include the powers and responsibilities that are outlined in Section 9901.908. The proposed language to establish the Board lacks understandibility and credibility. With the OSC being both the Appointing Authority, Approving Authority, questions will arrise over the independence of the Board. Whereas the Federal Labor Relations Authority does not answer directly to OSC, a level of independence and creditbility is maintained. The Authority has the offices and personnel in place to manage the responsiblilities outlined in Section 9901.908. This meets the Principles of Ensuring accountability and cost effective. To establish the Board, their support staff, and all other related costs would not be cost effective, therefore taking funds from other warfighting priorities and disregard the first Guiding Principle- Put the mission first. I strongly urge this issue be given serious consideration.