Comment from Public Employees for Environmental Responsibility

Summary: Public Employees for Environmental Responsibility (PEER) opposes the proposed "Promoting Employee Accountability" rule, arguing it weakens civil service protections and creates a "spoils system" by making it easier to fire employees without due process. They request that the OPM and MSPB withdraw the rule entirely, citing concerns over shortened performance-improvement windows, the removal of the Douglas Factors, and the narrowing of comparison pools for fairness.