| Comment Number: | OL-10510891 |
| Received: | 3/16/2005 12:48:19 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:
Subpart I Labor Relations The DoD needs to work with the unions to improve labor relations, not just shove these new regulations upon everyone unilaterally. All collective agreemetns should have to be renegotiated. Otherwise, effective upon these regulations being implemented, all existing agreements would substantially be null and void. The current catch word with our agency's LER is that an issue is "non-arbitrable" but the new catch word will be "unenforceable." the 60 day limit to bring into conformance remaining negotiable terms really is not a very sufficient amount of time. When you consider that agencies are having locations enter NSPS in different spirals, it makes it nearly impossible to negotiate for all locations, and for those locations not under the new provisions, they may not fully comprehend the needed changes. A better resolution is a 60 day limit for each provision as requested by the exlusive representative. so that the union and LER are not trying to negotiate hundreds of items all at once. The last date to request negotiation should be 120 days after the last remaining sites or sections of the agency has been incorporated into NSPS.