| Comment Number: | EM-008401 |
| Received: | 3/8/2005 7:56:42 AM |
| 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 8, 2005 DoD NSPS Comments , DoD NSPS Comments: General comments; There is nothing wrong with the current system other than mismanagement. All elements of the new system are currently in the existing system. The significant difference between this system and NSPS is the reduction/removal of accountability and oversight. You indicate that the unions were given the opportunity to participate. Sitting in a room and being dictated to is not participation. My installation has never had a problem providing DoD with whatever request they have made. NNSY delivered 44 employees to USS Cole within 48 hours of notification. The vast majority belonging to exclusive bargaining units. When asked for 50 volunteers to report to Bagdad 150 of our employees requested to be deployed. NNSY has 25 volunteers working at a Humvee plant in texas all members of an exclusive bargaining. Our installation routinely provides support around the world in all theaters of operation. How is this level of support considered a hinderance to DoD mission? Part of the hiring delay is due to security clearance background investigations. Why is SECDEF jepordizing national security? You have done nothing to facilitate demotion of non-performing supervisors and managers. Your proposals are akin to giving a poor mechanic a new set of tools and hoping that it improves their performance. How can you say you have retained due process when there is no independent third party review? Please retain the current appeals process. It can be processed via a single source but it must be independent. How can you say collective bargaining were retained when SECDEF has the authority decide what is a negotionable item? What is your plan if this new system fails? Why are we spending money on this when our troops overseas are in need of equipment and Navy and Air Force budgets are being drained to support the war? Our installation answers numerous unscheduled events every year and we are still able to meet or exceed our scheduled events. This is possible only to our ability to have a sufficient overhead to accomodate excess employees during periods without emergent situations. We accepted 90,000 additional mandays of work a one year when we were already above normal capicity. Although overtime pushed us over cost and schedule (about 7 days longest) on some projects we met most of our targets. You propose that available funding will be budget sensitive. The current system has significant overhead charges but this is because in DoD you can not have any delay to respond to surge requirements. Your plan puts DoD at a disadvantage when it comes to the unforeseen. All other agencies may be able to operate under such a plan but DoD is what makes all we have possible. Veterans; You indicated in several places that veterans preference would not be changed. However in RIF (you specifically indicated no change here) veterans preference is changed from a vet gets preference to they only get it within the performance rating group they are in. i.e., when a vet with 30 years of service, 28 of those years they received the highest rating, the last two they received the second highest rating and new employee with two years service and two highest level ratings are in a are RIF the vet loses their job! This is not unchanged as you claim. Pay; The only reason poor performers receive the same pay is poor supervisors and managers. The current system addresses this problem but if the supervisors/managers do not apply it properly it will not work. Despite your assertion that objective criteria will be applied it will not happen because objective criteria already exists and it is not being used. Nothing will change except the suffering of the employees will increase. You indicate that ?market-sensitive compensation? will be used to set pay. We already have a system that does that. For GS employees it?s the locality pay and for WG employees it?s the wage survey. Government wide pay set by this program is below the civilian market rates. If you are ignoring this now why should we believe you will honor the same program under a new name. Basing pay on assignments provides employees on high visibility tasks greater recognition than those on lesser tasks even when they are high level performers. There are currently several ways to reward employees. Special act or achievement awards, on the spot awards, group achievement awards and quality step increases. The only bar to receiving one of the above is poor performing supervisors/managers. There are current several ways to deal with poor performers. Poor performance ratings automatically trigger improvement programs, time off, reduction in step and or grade and termination. The only bar to any of the above is poor managers/supervisors. Hiring; The only impediments to hiring are due to suitability and security investigations. Are you inferring that we reduce security investigations? You indicate that ?market-sensitive compensation? will be used to set pay and attract new employees. You already ignore the current systems (GS locality and WG wage surveys) and refuse to honor congressional direction and fully fund the difference between private and public sector pay. You actually intend to hire foreign nationals to work in DoD? This is approaching treason. Bargaining; Collective bargaining is the cornerstone of the United States. The Jamestown pact, the Mayflower Pact, the Decleration of Independence and The Constittion are all collective bargaining agreements. DoD has never suffered a loss of mission accomplishment due to union bargaining. You currently have the ability to implement mission demands and do post implementing bargaining. Unions are not opposed with national level bargaining but must have installation level bargaining to address local concerns. Four tiers of bargaining at the following levels, each bargaining only on those matter specific to that level of concern. DoD, agency, command and installation levels. This permits the appropriate control at the appropriate level, addresses the unique concerns at each level and allows your most valuable assets, the employees, to have some legitimate avenue of input. i.e., DEFAS would have DoD agency and installation level because they cover all commands in all agencies while Navy would have all four because Naval commands are varied and numerious, NAVSEA, CICLANT, CICPAC, NACAIR ect. Classification; Current position descriptions are designed to outline the qualifications and skills required to perform those duties. How can you generalize the skills for a tank mechanic, airframe mechanic, fire control technician or nuclear power plant refueling technician? The pursuit of liberalized job assignment is already available. I have yet to see a position description that does not include the phrase ?and other duties as assigned?. How much more flexibility do you need? Defined classifications ensures qualified personnel are performing the required duties. Sincerely,