| Comment Number: | OL-10510804 |
| Received: | 3/16/2005 12:07:37 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:
I wish to comment on the use of the FLRA to continue to perform investigative and other services subject to the regulations (p. 7569). I believe that an independent body to investigate unfair labor practice charges is necessary to ensure the vailidty of the process. the FLRA has 25 years of this experience and should continue. Inasmuch as NSPS proposes to continuing using the MSPB in its entirety so should the FLRA be used. Currently, NSPS only proposed to have the Authority members review cases. Furthermore the FLRA is the labor relations expert for the entire US government within a budget of 25 to 30 million dollars. NSPS and the Board associated with it will cost at least this much alone. Why spend money on a system that is already in place? Use that money in other areas. The FLRA provides traning, advice and investigative functions on behalf of the Statute that Congress created. The FLRA could do the same with the NSPS. Futhermore, there has been much criticism of the FLRA because managers feel strapped in what they can/cannot do. This simply is due to lack of training in labor-relations. Ultimately the power lies with the managers to get the job done. I have never seen the FLRA preclude an agency from fulfilling its mission or putting its mission on hold. I urge DOD to continue to use the FLRA as the independent body in its entirety to ensure that its labor-relations component be conducted in a manner that sits right with Congress as well as the employees of DOD. The FLRA should continue to work these cases from the investigation all the way to the appeals process. I again state that the budget is 25 to 30 million for the FLRA which overses approximately 1.8 million employees verses a proposed 150 million for NSPS for 800,000 employees.