Are you sure? I heard they were. I was told this at my old facility when the staffing MOU came out.
Not in the same way as anything else, no.
"Transfers under this
Article shall not be constrained by any release policies; however, release
under this Article shall not negatively impact employees who have already
received release dates. Transfers under this Article shall not be eligible to
receive any permanent change of station benefits. If the Agency
determines that the request cannot be accommodated due to staffing, the
request will remain active for fifteen (15) months and reviewed every six
(6) months by the Parties at the Service Area/AFSIAG level. After each
six (6) month review, a notice will be sent to the employee regarding the
disposition of the request."
It does say at the end if it can't be accommodated due to staffing etc but that would be only in a situation where it's extremely dire, hardships out of n90 have even been approved. It's like the notes in the leave sections about a leave exigency. Yes theoretically the agency can declare at your facility you aren't allowed to take leave or hardship, but they won't because it would be publicly admitting a huge failure.
The important part is that you aren't subject to any release policies. Also the decision is made above your ATMs level so even if their a bonehead it doesn't really matter.