| Comment Number: | EM-001241 |
| Received: | 2/22/2005 1:41:00 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 22, 2005 DoD NSPS Comments , 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 since April 16, 1984. My parents worked for DoD during and after World War II and throughout the Korean and Vietnam wars. My father was an electrician working on the submarines that won the Cold War. I am the first of my family to serve in both bargaining and non-bargaining roles. The NSPS is fundamentally wrong. The workplace rules treat employees as opponents of the public good. This is offensive. There is no more risk of employees ruining the defense of the country than there is of managers, in there unchecked self interest, ruining the defense of the country. As a DoD employee, I work hard and am committed. Failing to involve employees fully, and thwarting their good will hurts the agency?s mission. The NSPS is wrong in spirit and direction. This system will drastically 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. The risk of mismanagement is increased and the check of dedicated non-political employees is threatened. Annual Pay Raises Under the General Schedule and FWS, 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. 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 will 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 the 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? basic rights. 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. DoD managers will become as corrupt as managers in private industry Mangers in private industry often ignore the best interest of shareholders and the long term interest of the company in favor of short term profit and unnecessary risk. This is not the type of public service our nation deserves. Civil servants do not serve to maximize the bonus of their immediate supervisor or his boss. They serve the American people (both taxpayers and non-taxpayers, and both citizens and non-citizen residents, both workers and managers.) Protections are in place to assure this and protect employees from arbitrary and capricious managers. Almost all characterizations of systemic problems in the civil service are based on anecdotal evidence that does not bear up to scrutiny. There are no problems in the system that smaller, less drastic corrections, cannot fix. How many bad managers are not in the news because of dedicated underlings who quietly, and, if necessary, noisily, keep him in line? Do you really want to give these managers free reign to stifle employee dedication and promote their own self interest? The purpose of the NSPS is to decrease employee rights and enable managers to bully the weak and dismiss the strong who oppose their self-interest. The theory that a manager?s self-interest coincides with the country?s self interest is a foolish basis for these reforms. It is as foolish a basis as assuming the rank and file employees as a group systemically act against the public interest. The current, working, balance should not be upset by these drastic changes when small changes will do. The appeal to national defense and anti-terrorism is shameful. My colleagues died at the Pentagon. I haven?t forgotten them. The NSPS dishonors them. Sincerely,