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George W. Bush discovered that PAS positions were on average vacant for one-quarter of an administration’s tenure, and the length of vacancies in federal companies is on an upward trend. See NLRB v. Sw. Gen., Inc., 137 S. Ct. 929, 936 ; Committee on Governmental Affairs, U.S. Senate, Report Together with Additional and Minority Views to Accompany S. 2176, S. Rep. No. , at three . Several statutes governing the president’s capability to nominate performing officers preceded the FVRA. Its quick predecessor, the Vacancies Act of 1868, had created a default

 

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