Comment Number: 05-02582-EREG-153-d7391-c32249
Received: 3/10/2005 8:00:00 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
No Attachments

Comments:

My comments are about my concern of the National Security Personnel System (NSPS), scheduled for implementation for more than 700,000 employees of the Department of Defense over the next year.

There is a great difference between the skeletal authorities that Congress approved and the crushing authorities that Secretary of Defense Donald Rumsfeld is now implementing.

During congressional hearings, the Secretary asserted that the Pentagon's broad mission requires greater "flexibility" in hiring, disciplining, compensating and assigning civilian personnel.

Basically, the Secretary wanted the same "chain of command" authority over civilian personnel as he enjoys over uniformed military personnel. I have the same problem in the workplace, being a civilian technician & a traditional Guardsman. Neither the Secretary nor his subordinates offered any documented or solid evidence to explain how union rights might have hindered the Pentagon's mission in the past.

Although Congress agreed to the broad requests lodged by the DOD, it attached certain strict conditions, including a specific requirement that DOD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. The Pentagon has done neither, ignoring the past accomplishments made while the Partnership Councils were in effect, which President Bush has eliminated. This has become a deteriorating relationship.

Although DOD has convened over a dozen meetings to "brief stakeholders" and to "solicit the views" of unions, there has been no information sharing from DOD and absolutely no response to repeated union requests for specific information as to exactly what problems management wishes to address with the adoption of NSPS.

I am certain that one of the Pentagon's objectives in advancing NSPS is to construct a so-called "pay for performance" system. This is another case of deceptive labeling. Various government agencies have been testing performance pay systems for more than 20 years and invariably, the results have been that the majority of workers feel cheated when advancement, promotion and pay decisions are given over to the sole discretion of a supervisor. The process typically reduces salaries and morale. It is too autocratic and eliminates any redress for decisions made on the basis of considerations other than merit.

For these reasons, I oppose the implementation of NSPS and I urge you to act to instruct the Secretary of Defense to halt any further development of NSPS unless and until the Pentagon is willing to substantively address the issues raised by the United DOD Workers Coalition.