Comment Number: EM-000673
Received: 2/16/2005 1:07:16 PM
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 16, 2005

 

  DoD NSPS Comments

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   DoD NSPS Comments:

 

  I write to express my concerns about changes to work rules in the Department of Defense (DoD).  The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005.  This message will be sent to both DoD and my representatives in Congress. 

 

  I have worked for DoD for 30 years.  I am angry that these proposals seem to treat the employees who help defend our country as the enemy.  They are based on the belief that these workers are lazy and useless. Most DoD employees work hard and are committed. I believe that mistreating the employees will, by reduced retention and loyalty, hurt the agency’smission far more than it may help it.  As regards NSPS,  this system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated.  These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. I am already paid less than most of those who have been hired years later than I was. Though favoritism was always a factor, seniority was the balence that allowed appeal. Now, after years of loyal service, I will be subject to having to deal with a favoritism that does not account for those years.

 

  Annual Pay Raises

  Under the General Schedule, employee pay was clear.  It was funded by Congress and could not be taken away.  However, NSPS will take away this certainty.  Salaries and bonuses are funded by DoD and have been, for many years, below the community standard for pay and benefits for  the same job.  In the past – as recently as just last year – DoD did not fund its awards program.  Given the agency’s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? 

 

  “Friend of the Supervisor” Pay System

  With the new patronage pay system, which DoD calls “pay for performance,” the amount of a worker's salary could depend almost completely on the personal judgment of his or her manager.  This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is 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 a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems.  Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. 

 

  Schedules and Overtime

  NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes.  This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice.  Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities.


  Civilian Deployment

  Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice.  I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home.  We signed up for a civilian job.  We did not enlist in th military. Today’s volunteer system works well. 

 

  America is at war.  We are fighting for democracy abroad.  But the regulations are an attack on workers.  Furthermore, NSPS will divert the attention of defense workers from the soldiers’ welfare to protecting themselves from abuse on the job.  I urge you to force DoD to rethink this proposal.  We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers.