Comment Number: | OL-10511323 |
Received: | 3/16/2005 3:04:04 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 9901.106. a. Collaboration is defined as "working together, especially in a joint intellectual effort." Although the NSPS law states that implementation of the new HR system will be carried out....."in collaboration with, employee representatives," paragraph (3)(ii) states that "to the extent the Secretary deems necessary, employee representatives will be provided with an opportunity to discuss their views with DoD officials..." This is not actively collaborating but merely acting as though collaboration is taking place. b. Paragraph (3)(i) references "final draft implementing issuances". It is difficult to comment on a document when so much of the proposal is still un-issued. We are commenting on a "Proposal" that needs to be more thoroughly fleshed out, with more review and revision.