| Comment Number: | EM-010812 |
| Received: | 3/2/2005 2:47:34 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: Particularly disturbing is the deployed part. Seems they can deploy us anywhere, anytime. That is truly scay and completely irresponsible to us as parents of young school age children. It appears that Rumsfield's plan is to move as many jobs from the military to DoD civilian personnel as possible. He just wants to use DoD personnel to replace the declining Guard and Reserve forces who are not meeting their recruitment goals. . There are no details on classification, bands, pay, performance ratings...all the details will be provided in "implementing directives, instructions, manuals and other issuances". It is an impossible situation they have created here. If we can't see the details, we can't comment on what's right or wrong. We can only object in a general sense to the concepts of pay banding, pay pools etc. We don't necessarily object to the concepts (at least our local doesn't as we have negotiated agreements on demos), but we most certainly will object to some details. When the Federal Register for the TACOM demo was published, we had specific details to comment on, they've really screwed us here by not publishing details.Control points sound like they are putting steps into the pay bands. The really scary part is that we don't know what the requirements will be. Room for abuse is so great here it is unbelievable. We want Congress to set our Annual Pay Increases. The mandatory removal offenses are mentioned but they don't tell us what they are but they will be defined by the secretary later and can be changed at any time. Totally unfair. The National Security Labor Relations Board will be appointed by the secretary. You can forget about getting any rulingsbin favor of the union with the NSLB. Performance rating is now of greater weight than seniority in a RIF. Speaks for itself...as unfair as anything in the NSPS...I'd hate to be around for the next RIF. We can no longer grieve pay actions, performance ratings or removals. DoD and OPM will develop a formal process whereby employees may seek reconsideration of their rating. This is the most ridiculously unfair part of the whole NSPS. Your first line supervisor has complete control over your salary through pay for performance and if you think your rating is unfair you have no grievance procedure that gets you out from your chain of command?? More totally unfair than the rest of the unfair, biassed, union busting piece of crap personnel system that NSPS is. 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 31 years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. 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. 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 the 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. Sincerely,