Comment Number: 05-02582-EREG-220-d7391-c32360
Received: 3/15/2005 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:

9901.341, Pay based solely on performance will not be fair or equitable. Performance appraisals can be bias and subjective to the whims of the rater and could be based on non-work related issues, i.e.: fishing-hunting buddies, social friendships, and religious beliefs.

9901.601, Conducting a reduction in force based on these same performance ratings fails to recognizes the years of dedicated service employees have given to the government. The newer younger employees may appear to have more enthusiasm and aggressive work ethics but in fact the older more experienced employee is able to get the job done more efficiently.

The proposed regulations in regard to pay and RIF are a return to the good ole by system. Also, appeals of these ratings are insufficient.

9901.901, The term within the new proposed Labor Relations that stands out most to me is,The Secretary in his or her sole and exclusive discretion may do whatever he or she pleases.

It appears to this reader the proposed regulation will wipe out over 30 years of case law and severely reduce my assurance to a fair and meaningful work environment. DOD also failed to include my labor organization in the development of these proposed regulations as was required by Law.

Be assured my coworkers, family members, friends and I are writing to our congressional representatives concerning DOD abuse of the authority that congress had provided in establishing the NSPS.