| Comment Number: | OL-10510568 |
| Received: | 3/16/2005 10:28:36 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:
Section, "Workforce Shaping - Subpart F", While the first paragraph states that "The proposed regulation retains existing veterans' preference protections in reduction in force (RIF).", reality is reducing the competitive area as proposed to as small an area as "..product line(s), organizational unit(s), and funding line(s)" as to render verterans' preference impotent. This proposal puts veterans' and all employees' at risk of having their careers ended without consideration of past performance and qualifications. It will permit managers to load up a particular unit through reassignments, with people they don't like and then RIF them all without any recourse for the affected personnel. This proposal ignores the investment the Govt has made in training and preparing personnel by eliminating retreat rights to previously held positions. In general employees have advanced because they have demonstrated proficiencies at their then current position, as well as demonstrating their abilities to advance to greater responsibilities. Currently, in a RIF their ability to retreat to previously held positions only improves the Activities overall performance as they return to a position they have demonstrated proficiencies at. This proposal give a manager the right to decide what veterans' preference protection he/she is entitled to, not the requirements of 5 U.S.C. 2302(b)(11) requirements.