| Comment Number: | OL-10511073 |
| Received: | 3/16/2005 1:56:34 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 9901.104 is misleading. It states that only the specific chapters of title 5 of the U.S. Code listed may be waived by NSPS regulations. According to the NSPS law, 5 USC 9902(b)(5), the NSPS “shall not be limited by any specific law or authority under this title [title 5, U.S. Code], or by any rule or regulation prescribed under this title. . . “. There are many more laws and regulations on DoD’s chopping block other than the ones listed in section 9901.104. These concern hours of work and alternative work schedules (5 USC Ch. 61), annual leave, sick leave and family and medical leave (5 USC Ch. 63), workers compensation (5 USC Ch. 81), retirement (5 USC Chs. 83 and 84), life insurance and health insurance (5 USC Chs. 87 and 89). Also, the proposed regulation lists 5 USC Chapters 33 and 35 as waivable, meaning that veterans preference in hiring and RIF situations are changed. I believe DoD has intentionally misled Congress, DoD employees and the general public in what major changes they intend to make on the civil service system.