| Comment Number: | EM-008391 |
| Received: | 3/9/2005 3:15:01 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:
March 9, 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 27 years. I believe the current system is not perfect and is in need of some reasonable change - evolutionary, not revolutionary as is NSPS. My primary concerns about NSPS include: 1. (Subpart A - General Provisions ) NSPS will be imposed on federal workers without the work force's knowledge of its specific provisions. This is unfair. The specifics should be put on the table prior to implementation and ample time allotted for review to occur. 2. (Subpart C - Pay and Pay Administration) I do not feel the new pay banding system is fair or equitable. This is especially true for those of us who have worked nearly full careers under the inflexible CSRS system. Pay banding will penalize those workers who are in high grades/steps by limiting any further increase in salary which will impact negatively on our retirement (high 3). I think CSRS employees who are close to retirement eligibility (say 3 years or less) should be exempted from the proposed pay banding. 3. (Subpart D - Performance Management)NSPS will turn employee performance ratings into a personality contest/favoritism. 4. (Subpart F - Reductions in Force). NSPS will greatly diminish the impact seniority has in the RIF process. To those of us who have given our full careers to federal service, this is a terrible way to reward us for our loyalty. I wonder just how much (or little) seniority will matter under NSPS. 5. I am a civilian, not a soldier. NSPS will treat civilians and soldiers as a single force with the possiblity of deployment anywhere in the world or nation. That is unfair and contrary to the conditions of my employment with the federal government. 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,