Comment from Brian Mitterling

I strongly oppose these proposed changes. As a Bureau of Prisons employee, I work in a high-stress, high-risk environment where decisions affecting employees must be fair, balanced, and based on the totality of the circumstances. Eliminating the Douglas factors removes an important safeguard that helps ensure discipline is consistent and proportional. Every situation is different, especially in correctional institutions where staff routinely face emergencies, inmate assaults, mandatory overtime, and rapidly changing conditions. Managers should be required to consider an employee's work history, intent, and mitigating circumstances before imposing discipline. Limiting Performance Improvement Plans to 30 days is unrealistic for many positions within the Bureau of Prisons. Employees deserve a meaningful opportunity to improve their performance with adequate coaching and support, not an arbitrary deadline that may set them up for failure. The proposed "voluntary abandonment" standard is especially concerning.