| Comment Number: | OL-10512094 |
| Received: | 3/16/2005 9:13:05 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 classification system described in Subpart B of this proposed regulation contains very few specific details about the career groups, pay schedules, pay bands, and other classification structures and rules that will apply to DoD employees under this regulation, if implemented. Much more detail is needed to allow for a meaningful and thorough review and discussion of this regulation, as required by law. No changes should be made to the classification systems currently used by DoD agencies until a full comment and review period is completed, followed by a full collective bargaining process with the unions representing DoD employees. A personnel system without fair and appropriate classification structures and rules will be rejected by employees, and will result in distrust of management, decreased morale, and lower productivity, ultimately harming national security. Subpart I, at 6. National Security Labor Relations Board (p. 7569) of the Proposed Rule that appeared in the Federal Register on Monday February 14, 2005 "specifically solicit(s) comments on other alternatives, such as requiring (or entering into a service level agreement with) FLRA or some other organization to provide investigative and other services..". My comments follow. The FLRA already has a staff trained, experienced and highly professional in performing investigative services in labor-management matters. The staff is composed of Labor Relations Specialists and Attorneys, and many, if not most, have been working exclusively in the federal sector for 15 years or more. The FLRA remain seasoned neutrals and are a dedicated cadre with proven ability to investigate labor-management issues, particularly unfair labor practice allegations. The FLRA staff should be retained and they tasked with carrying out the standards and functions required by NSPS. Save tax payer dollars by using the staff that Congress provided for and funded.