| Comment Number: | OL-10510563 |
| Received: | 3/16/2005 10:28:06 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:
Subpart A - General Provisions - Section 9901.101 - 9901-108 It makes no sense to implement the Labor Relations portion before most of the activities have implemented NSPS. It should be illegal for NSPS to arbitrarily implement the Labor Relations portion which contradict the agrrements in force today. Subpart C - Pay and Pay Administration - Sections 9901-301 - 9901.373 By throwing out the existing pay systems DOD is enabling discrimination in pay and performance with no recourse for the employee. The existing system is fine. Subpart D - Performance management - Sections 9901.401 - 9901.409 Management under the new system has two much arbitrary power to change expectations with no recourse for the employee. Subpart G - Adverse Actions - Sections 9901.701 - 9901.721 mandatory Removal Offenses should not be solely on the whim of management. Subpart H - Appeals - Sections 9901-801 - 9901.810 The appeals process has been gutted! I don't see how the new system can be arbitrarily implemented without a real bargaining effort. Subpart I - Labor management Relations - 9901.901 - 9901.928 It should be illegal to overturn all the local collective bargaining aggreements.