Staff should not count on LWOP as part of the vacation schedule. It is the employee's responsibility to request and management's responsibility to schedule. You indicated that it would be paid leave. We feel you cannot block the opportunity to staff to request time. We are discussing annual leave and comp time.
Staff always have a right to ask for time.
LWOP is not vacation, in our opinion. We believe the issues we raised and the scenarios we described are not addressed with your proposal and that it accomplishes nothing. We have past practice and established practice. Staff have been given LWOP for vacation purposes and we see no reason to change that. We would prefer to keep it as it is now.