| Comment Number: | OL-10511205 |
| Received: | 3/16/2005 2:30:22 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:
General The proposed rule as drafted is so lacking in detail that it is an outline without content. NSPS as published in the Federal Register is a "plan to implement a plan" and is convoluted, unnecessarily vague and undefined. Additionally, it guts current GS employee protection and grants too much power and authority to DoD. Specifically 9901.373 "DoD will convert employees to the system without a reduction in their rate of pay" is a fiscal impossibility if DoD is not increasing the DoD personnel budget to reflect the increases that would be paid to individuals that should be placed in a pay band that is higher than their current pay under the GS system. VR, Neil F. Quinlan, Sr. CDR (SS) USNR Ret. General Engineer