May 8, 2012 at 12:28 pm #160721
They solicited suggestions for possible regulatory changes from staff, they created an internal working group to review staff suggestions and propose a few possible changes. Then they sought written input from 30 stakeholders, receiving comments from 15 who were then invited to make additional, in-person comments to them.
If you’re even slightly cynical or a bit of a skeptic, this scenario could sound like an organizational campaign to find and persecute messengers, especially since we’re talking about the Merit System Protection Board. Add to that, the fact that its 3-member board is comprised of political appointees, the balance of which generally weighing-in in favor of the current Administration; and this is a first-of-its-kind review of their adjudicatory regulations since their inception in 1979.
So one might wonder if it’s worth making comments.
What do you think?
According to the work group’s chairman, Susan Grundmann, “This is a watershed event … We knew <our> staff and our external stakeholders would have good ideas about improving the adjudicatory process for all participants. We are taking those suggestions into account in order to better serve everyone going forward.”
May 10, 2012 at 3:20 pm #160729
If you make no comments, you eliminate the possibility of making an impact or shaping the final results. So, speak up … or live with the results.
If you are concerned about personal attacks and retribution, then you may want to characterize you comments as suggestions that have been presented to you from various un-named co-workers & you may want to use some subtlety and tactful language to avoid a confrontational approach.
May 10, 2012 at 8:42 pm #160727
I am not sure why you suspect “an organizational campaign to find and persecute messengers.” Are there facts that you are leaving out? Though I have not been involved with the MSPB in their quasi-judicial role, I have found MSPB reports useful. Also I would say it is past time for a review after 33 years.
June 15, 2012 at 4:32 pm #160725
I apologize for being so late to this conversation. Doris, thanks for your rather provocative take on our considerable effort to review and improve our regulations! I agree with Scott and David–we encourage all interested persons, agencies, and organizations to help shape the final rules; after all, it’s been 33 years! Everyone should take a closer look at http://www.mspb.gov/regulatoryreview. I think you’ll see it is not about “persecut[ing] messengers” or “political appointees.” And it is “worth making comments,” which you can submit through July 23. We look forward to everyone’s input!
June 15, 2012 at 5:41 pm #160723
In over a decade, I’ve never found a single request from MSPB to be insincere.
Bill, If you run into Harry Redd, Paul van Rijn, or James Tsugawa, give them my best.
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