| Comment Number: | OL-10511272 |
| Received: | 3/16/2005 2:50:18 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:
Page 7571 of the FRN redefines formal discussions with unions as discussions or announcements of new or substantially changed personnel policies, practices, or working conditions. First, discussion cannot be defined as an announcement. Discussion implies one party talks and listens to the other party. When one part merely "announces", no discussion occurs. Secondly, why are formal discussions limited to only "new or substantially changed" areas, and not open to all areas? Why are "operational matters where discussions do not involve the establishment of new policies or practices" excluded?