Comment Number: EM-000351
Received: 2/17/2005 9:13:18 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:

February 17, 2005

 

  DoD NSPS Comments

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   DoD NSPS Comments:

 

  Dear Sir/Madam,

 

  I am writing to ask you to vote against the proposed National Security Personnel System (NSPS) that is to begin implementation later this year. There are scores of problems with the proposed system, including the fact that the Department of Defense did not follow congressionally prescribed procedures when it developed the new labor relations rules. The proposed overhaul will gut pay standards, appeal rights and collective-bargaining rights. People who support our soldiers and sailors will become second class citizens.

 

  Standard of living will surely decrease for the nation’s 750,000 civil servants with the NSPS as guaranteed inflation-fighting annual pay raises end. Many of us have purchased homes, and made financial commitments in good faith, knowing that our income would grow with as our length of service and work experience grows and that our pay scale would keep pace with market salaries and inflation. Now, the implied promises that were made to us as we entered the workforce are being revoked.

 

  Navy Secretary Gordon England’s argument that the department needs more flexibility to recruit and retain the best workers rings hollow. The government has always adhered to strict standards in hiring, promoting and retaining only the best workers. The new system will set up pay bands to replace General Schedule grades, allowing management to merge workers with seniority and specialized job descriptions with entry-level staff, journeymen or supervisors in general job descriptions. How would you like it if your experience and expertise were ignored and you were grouped with newcomers to Congress for competition for salary, committee assignments, etc.?

 

  Under NSPS, the amount of a worker's salary and pay increase will depend on the judgment of the manager. And the managers can change ratings if they wish with no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create worker conflict with one another, fostering an environment of fear to speak out about harassment, violations of the law, and workplace safety problems. There is no provision for a fair appeal process to challenge performance and pay decisions.

 

  Civil Servants have never been allowed to strike, but we have been able to enter in to collective bargaining agreements that prevent workplace abuses and improve morale and employee performance with the help of the National Labor Relations Authority (NLRA). The new system replaces the NLRA with a new, internal National Security Labor Relations Board. Talking about the fox in the henhouse! There will be no external impartial oversight. Defense management will be able to change workplace rules without a bargaining agreement in place, and then bargain about the changes later.

 

  NSPS will weaken civilian workers' rights and erode the quality of their jobs without doing anything to enhance national security. NSPS will harm local economies that have a concentration of federal workers whose federal wages will begin to mirror service, fast food, and retail salaries. Under


  NSPS, when conducting reductions in force, the new rules will allow Defense to consider performance as the first factor in laying off workers, instead of length of service. Under the current system, workers’ years of dedication to DoD counted a lot in the event of a RIF. Now it is clear that DoD doesn’t care about commitment anymore. These new standards are wrong, and will go a long way toward demoralizing the DoD workforce. Remember, we are the ones who support the war fighters, who work long hours to make sure ships and planes are supplied and deployed at the right time to the right place to make our country safer.

 

  Please do not alter our ability and will to continue to support the war fighters in Iraq and the continuing war on terrorism. Please do not create a second-class civil service in our first-class country.