Comment Number: EM-008345
Received: 3/8/2005 12:20:24 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:

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. As a DoD Employee with many years of service, I consider the proposed plan a National Disgrace. My many co-workers have a long history of serving this nation in a dedicated, loyal, and cost-effective manner, no thanks to NSPS, and deservce much better treatment. I am sick of having the term "National Security" perverted to justify treating such a talented and loyal workforce in such a shabby manner. Remember President Nixon, who used the same "National Security" Justification to authorize the Watergate Break-in. How has history judged this event? To any elected official who may read this, I can only add that Federal Employees, who feel the same way I do, comprise a significant chunk in my local area's Voting Population. It seems to me that NSPS is a solution in search of a problem, and is a thinly-veiled plan to revive the old, corrupt 19th. Century Patronage Service System. Why anyone would seriously consider the NSPS Proposal, as currently written, a good thing for our Nation I cannot understand. The Pendleton Civil Service Act of 1886, from which the current system is descended, was imposed to clean up the hopelessly corrupt "non-system" which previously existed. It is a tragic statement of fact that President Garfield paid the ultimate price for that old system - read your history books. I am really concerned that NSPS will drive somebody over the edge, and I can only hope that that somebody won't be in the cubicle next to mine - NSPS provisions making co-workers compete with one another and "rat each other out" for so-called "pay for performance" and for promotions will definitely make the Government Workplace more divisive, less cohesive, and therefore less able to accomplish its mission, which ironically enough is National Security. While I am not opposed, in principle, to either changes in the present Civil Service Code or to Pay for Performance, I believe the sweeping changes of NSPS are not warranted and will create more problems than they solve. As an alternative to NSPS, I think there should be a serious discussion of how well the present system is serving us, from which targeted beneficial changes could be made. Let us not throw out the baby with the bath water!!! I CAN PERSONALLY ATTEST THAT PAY FOR PERFORMANCE SYSTEMS, EVEN WITH THE BEST OF INTENTIONS, ARE DIFFICULT TO ESTABLISH AND MAINTAIN - AND I HAVE LITTLE CONFIDENCE THAT NSPS WAS DESIGNED WITH THE BEST OF INTENTIONS. NSPS, in its present form, will nearly totally destroy DoD Accountiblity with the various procedures and processes which govern how employess 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. OVER THE YEARS, I HAVE SEEN A NUMBER OF QUESTIONABLE WORKPLACE HAPPENINGS, WHICH WERE AT LEAST SOMEWHAT HELD IN CHECK BY THE VARIOUS CIVIL SERVICE PROTECTIONS NSPS WILL ABOLISH!!! Below follow a number of comments made by a person I respect. I include them here for purposes of record. 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. 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 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' 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. Mr. Rumsfeld has stated that he can't do his job without NSPS. What is being asked of him that was not asked of his predecessors? If I were Secretary of Defense, I would be too embarrassed to make such a statement - it sounds like an admission of incompetence. Maybe a simpler solution, instead of NSPS, would be to hire a new Secretary of Defense. Sincerely,