| Comment Number: | EM-010806 |
| Received: | 3/2/2005 4:23:53 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 2, 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. The problem is not the system in use, although it may need some tweaking. The problem is the lack of adequate training and often adversarial mindset of supervisors. They can't beat us with the current system, so they want to take away all of our rights so that they can win be cheating. So much for Core Values. Years ago a new performance appraisal system was created. It required standards. We met and exceeded those standards year after year, in spite of their tightening the standards year after year. And one day standards disappeared. Do you have any idea how much time and effort it takes to prove a subjective evaluation wrong? Especially when you are not one of the supervisor's buddies? 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 NSPS. This system will 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, 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. I'm sorry to say that too many supervisors/managers in the military enviroment are inexperienced and poorly trained. Military superviors are often placed into supervisory positions based solely on rank. They know little of the job and often misinterpret the actions of employees with many more years experience. (For example: After a TSgt graduates a Basic Instructor Course (BIC) and teaches a class or two, he is declared an Instructor Supervisor. Because his training is basic he thinks think on the Basic Instructor level. Too often such supervisors misinterpret the more advanced techniques of employees that have 20 to 30 years of teaching experience. One would not think that to be much of a problem, but too many (not all) military supervisors act as if they are gods and know everything. They know only one way and evaluate based on that one way.) 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. (Example: I am aware on one case now in which every level of supervision, from immediate supervisor to Group Commander and civilian personnel specialists, have willfully disregarded law and Air Force Instructions. They have distorted the facts and have downright refused to allow the employee to show them what is wrong with the information they are basing their actions on. They are too full of themselves and those higher up choose to do nothing more than rubber stamp the actions of their subordinates.) 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. (In my case, I spent four and one-half years caring for my 79 year old invalid mother. I had to higher someone to be with her while I was at work. Very costyly. And all I got from supervision was grief once I discovered the Family Leave Act.) 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. Public employees are proud to serve our country, but they are also responsible for caring for their families and personal obligations. Seems that this abuse of civilians to to fill deployment gaps add merit to the argument that the military has been cut back too far. America is at war. We are fighting for democracy abroad. But these regulations are an attack on workers? basic rights. Rights that, in many ways, are what we are fighting for abroad. 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. Want an example of what happens when a dictatorship denies basic rights and human dignity? Try the former Soviet Union, or Iraq under Sadam Hussein. Is that the way you want to treat civilian defense workers? It may not be as bad, but it comes close. No rights! Poorly trained supervisiors and managers. Supervisors with their own personal agenda. Sincerely,