Comment on DOD-2026-OS-1321-0001
AnonymousOpposeOther
Summary: The commenter opposes the proposed action because it attempts to "adopt" personnel flexibilities from Science and Technology Reinvention Laboratory (STRL) notices rather than establishing them as standalone AcqDemo authorities. They argue that this approach introduces systemic vulnerabilities and fails to comply with specific federal codes requiring explicit legal waivers and operational text for each authority.
The Out-of-Cycle Within-Broadband Pay Increases, Distinguished Contribution Allowance (DCA), Retention Counteroffers, Official Transcript Requirement, and Student Loan Repayment flexibilities described in Section III New Flexibilities reference adoption from various Science and Technology Reinvention Laboratory (STRL) Federal Register Notices (FRN). The authority to adopt another demonstration project authority was authorized by Congress specifically for the STRL community as referenced in Title 10, United States Code (U.S.C.) 4121 and originally authorized in the FY2011 National Defense Authorization Act (NDAA) Section §1101. Referencing STRL Federal Register Notices (FRNs) within an AcqDemo FRN introduces severe systemic vulnerabilities. To comply with 5 U.S.C. 4703 and 10 U.S.C. 1762, the Acquisition Demonstration Project (AcqDemo) cannot simply "adopt" flexibilities by referencing STRL FRNs. The FRN must establish these personnel flexibilities as standalone AcqDemo authorities and document the complete operational text and explicit legal waivers for each authority.