| Comment Number: | EM-001430 |
| Received: | 2/24/2005 3:40:55 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 24, 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 29 years, 10 in the Navy and 19 in my present position at Tobyhanna Army Depot. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency?s mission. I am very upset by the NSPS. This system would 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. 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, the NSPS would 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 their salaries and bonuses would be funded in the future? In to days era of budgetary constraints and cost cutting measures the potential would exist for under funding these programs, which would result in frozen wages and no or decreased bonuses to the best workers that appropriately would deserve a fair increase. ?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. One of the reasons I departed the Navy was to be at home with my family and not be separated from them and sent, where and when I was told at a moments notice. I signed up for a civilian job and did not reenlist in the military, or so I thought. Today?s volunteer system works well, but if the NSPS forced system were to become a reality would I receive the same pay and benefits as my military counterparts. Would I receive combat/hazardous duty pay? How about life insurance? Free to the military, but paid by civilian personnel under the Federal Employees Group Life Insurance (FEGLI) program. And in my case I have additional private insurance that has exclusionary clauses that state that benefits are not paid as a result of acts of war or terrorism. Will legislation be forthcoming to mandate insurance companies pay the beneficiaries of such policies? America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers? basic rights. Furthermore, the 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. Sincerely,