Comment on FR Doc # 2011-15307

am writing to request that the National Labor Relations Board immediately withdraw the Notice of Proposed Rulemaking, Representation Case Procedures RIN 3142-AA08.
The proposed rule is completely unnecessary and would infringe on my rights as a member of management and my employees’ rights.
The proposal would make drastic and unnecessary changes in an effort to promote unionization at the expense of my right to communicate with my employees and their right to make an informed choice about union representation. My understanding is that we could find ourselves facing a representation election in as little as 10 days after the union files a petition, as opposed to the current average of 38 days before an election.
This would severely limit an employer's opportunities to talk to employees about union representation or respond to promises union organizers may have made to secure union support, even though many of those promises may be completely unrealistic. Not only is this unfair to my employees, but it also promises to destabilize future relations as parties would enter a bargaining relationship with unrealistic expectations.

I am also very concerned that the new rules would require employers to turn over confidential information about employees, including phone numbers and e-mail addresses. Many people have unlisted phone numbers and use personal e-mail addresses for online shopping and banking. Requiring the disclosure of this information is irresponsible, dangerous and unfair to employees.
The proposed rule represents a devastating blow to free speech and due process rights and will deprive employees the right to make an informed decision about union representation. It also violates an individual’s right to privacy of their personal contact information, which in this case they have entrusted to their employer. For these reasons, I respectfully urge the Board to withdraw the proposed rulemaking in its entirety.