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place. Further, as a matter of fairness the 400 employees scheduled for removal in April 2000 should be allowed to continue their employment for the length of time they are registered in the PPP. Current personnel regulations allow employees (who are removed from their civil service positions for reasons outside their control) to remain in PPP for up to twelve months. During this time, they are given priority consideration for positions for which they are qualified.

We believe that delaying implementation of NDAA would allow these people a fair opportunity to obtain other employment, negate the loss to the Army Reserve of the expertise accumulated over their years of employment with DoD, prevent an immediate financial strain on many of these people and their families, and eliminate an avoidable and immediate adverse impact on unit readiness.

b. To date, USARC has refused to allow priority consideration to these people for any current or future vacancies in non-military technician positions throughout USARC. Their briefing to Congress assured that this would be an action that they would take.

We believe a delay in the implementation of these provisions would allow time for your committee to force compliance as well as afford those soon to be removed a fair opportunity to seek alternative employment.

c. A review of positions presently identified as military technician positions reveals many inconsistencies. Throughout USARC, there are currently positions identified by Table of Distribution Allowances (TDA's) as Mil Techs that should be identified as Department of the Army Civilian (DAC) positions and vice versa. DAC positions require specialties or expertise not found in the military structure or qualifications that are not inherently military. Additionally, some positions have been identified as both Mil Tech and DAC. The following are examples:

Budget analyst positions at Regional Support Command (RSC's) Headquarters identified as Mil Tech and DAC although grade and requirements are the same. (Often in the same office). Other positions, which are also inconsistent, are Auditor, Information Management Officer, Engineer, Environmental, and Military Personnel Specialists.

2. Public Affairs Specialist identified as DAC, should be Mil Tech.

Congress has made it clear that Military Technicians must only fill positions required for deployment. In 1998 OCAR identified positions in non-deploying headquarters that required change from Mil Tech to DAC. In spite of this finding, these positions at RSC's throughout USARC remain identified as Mil Tech positions. To add insult to injury, the people in many of these positions are the ones identified for removal in April 2000. An additional problem is the fact that all RSCs are non-deploying units which raises the question whether any position at these headquarters should be identified as Mil Tech. We believe that before any employee is involuntarily removed for not being a Mil Tech in a so-called Mil Tech position, these positions must be correctly and consistently identified.

d. To date, USARC has not allowed any technician to return to drill status that was removed involuntarily from the Selected Reserve and transferred to the Retired Reserve with transition benefits. This prohibition exists in spite of the fact that they are fully qualified to return. As an example, four requests were made well over a year ago and to date they have been denied the opportunity to return to the Selected Reserve. Many others in the same category who were interested in returning have inquired but have been informed that they will not be allowed to return.

Recent correspondence from USARC has stated that DA has indicated that the Secretary of the Army will require any non-dual status technician, currently in the Retired Reserve with transition benefits, to prove "indispensability in the military

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