| Comment Number: | EM-017376 |
| Received: | 3/15/2005 5:39:44 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:
Dear Sir / Madam: I am writing to express my opposition to the proposed imposition of the National Security Personnel System (NSPS) on civil service mariners (CivMars) employed by the DOD on ships of the Military Sealift Comand (MSC) and the US Army Corps of Engineers (USACE). I am an active member of the International Organization of Masters, Mates and Pilots (MMP) and currently sailing as captain aboard containers vessels owned by American President Lines, Ltd. The current system that civil service mariners operate is in the best interest of national security and should not be altered by the proposed NSPS. Shipboard employment is unique and NSPS is not an appropriate model for managing civil service mariners and meeting the long term needs of DOD in times of war and national emergency as well as the needs of war torn nations when transportation of supplies, reconstruction and humanitarian aid are deemed necessary. Civil service mariners have performed outstanding service to our nation with successes in the recent Iraq War and Tsunami relief efforts. CivMars are part of a time-tested system that works and because of its uniqueness should remain subject only to 5USC71. CivMars have successfully answered the call time and time again under the existing system. It is a proven system that works. The proposed NSPS system would only undermine that system and ultimately, reduce the available manpower of qualified seafarers and decrease our country's military sealift capabilities. Why such as system at NSPS would be considered is beyond my comprehension. NSPS would actually be a detriment to national security and degrade DOD's mission capabilities. The contribution that MMP makes to the maritime community and the development of trained seafarers available to DOD in times of emergency cannot be duplicated by any government agency. Weakening the ability of MMP to provide training and to recruit CivMars and pilots into membership is not in the best interest of our national security. CivMars should be specifically excluded from the requirements of the NSPS. Respectfully submitted,