Federal Docket Management System Office

1160 Defense Pentagon

Washington, DC 20301-1160.

REF: **32CFR, Part 64: Management and Mobilization of Regular and
Reserve Retired Military Members**. (DOD-2006-OS-0069, RIN 0790-AH92)

20 April 2006

Sir,

I would like to address several concerns after reading Regulation
**32CFR, Part 64** entitled, "**Management and Mobilization of Regular
and Reserve Retired Military Members"**. Like most regulations, it is
not so much what the Regulation says, as what it fails to say, that
bothers me. Some of my comments are more in the line with developing
appropriate policy concerning the promulgation of this regulation.

First, I would like to know if the individuals writing the changes to
this regulation are considering any 'triggers' that must occur before
this regulation is used to bring someone back on active duty. Will
'**stop/loss'** be initiated 'first' to prevent further erosion in these
critical specialties, [before]{.underline} activation of a retiree is
considered? Pulling veterans out of retirement, while still allowing
active duty soldiers in the same MOS/SSI to depart the service, is
inappropriate!

Secondly, the regulation and/or resulting policies must specify a time
limit for the activation of these individuals. Will they be treated like
reservist and brought back on active duty for 90 days, as they are in my
specialty, or as in other specialties for a maximum of 365 days? Will
any resulting downrange deployments be for six months, as are active
duty soldiers in my field? It would be inappropriate, if retirees were
brought back to active duty after serving twenty plus years (in my case
thirty-three years), disrupting or destroying businesses they have
developed, marriages, and retirement lifestyles without due
consideration to the already tremendous sacrifices these veterans have
already made! There has to be some mechanism in any regulation to
protect our veterans from abuse! If you don't have guidelines set up in
the Regulations, then who will look out for their interest? The answer
is probably...no one! That should be unacceptable treatment for any
citizen, who has already given far more then their fare share in the
defense of our country.

Third, has any consideration been given to the fact that a lot of
retirees, myself included, are already occupying a Department of Defense
positions identical to the positions we had as active duty military
members? A position identical to the one we would occupy, if we were
called back to active duty! Where is the benefit in activating someone,
who is already serving the military mission as a GS civilian in the same
field he/she would occupy on active duty? Does anyone track this?
Probably not, but they should! There would be 'no' net gain in the
number of providers available, and you would then be required to
activate another individual to back fill the, "now", vacant GS spot,
that you just created. This would disrupt two retiree's lives, just to
increase the overall numbers by one.

On a similar note, we could consider the activation of retirees, who
currently occupy a GS position in their respective fields, [to remain in
their current duty locations]{.underline}? If overseas deployment proves
to be necessary, they could then deploy from their current duty
assignment and return to their current home. This would be far less
disruptive to the lives of the retirees and their families. I believe
the government owes them at least this much consideration, after so many
years of service. This regulation must be constructed thoughtfully. We
must not misuse our veterans, because it is a bother to take the time to
construct appropriate safeguards. That is partly why so many good folks
have left the service and why we are in this dilemma to start with. I've
been saying this for thirty-three years but, "Do what's right, not
what's convenient!"

> John Fierro
>
> LTC, AN (RET), CRNA
>
> Anesthesia & Operative Services
>
> Bassett Army Community Hospital
>
> Fort Wainwright, Alaska