Comment Number: EM-017401
Received: 3/14/2005 8:02:37 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:

Sharleen Brookshire R. R. 2, Box 94 Bloomfield, IN 47424 March 14, 2005 SUBJ: NATIONAL SECURITY PERSONNEL SYSTEM (NSPS) I'm writing 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 at the Naval Surface Warfare Center, part of DoD, for more than 21 years. My husband served in the Army in Viet Nam and Germany. He has worked for DoD nearly 30 years, mainly in a support role for Public works, and retires in early June 2005. I am upset that these proposals seem to treat the employees who help defend our country as the enemy. Most all the DoD employees both my husband and I know work very hard and are committed to supporting our troops and country. I worked for the Strategic Systems Programs over 17 years and now work for the U.S. Air Force Predator Electro-optics program. We?ve received emails and letters often from our sponsors telling us the difference our support makes. I believe that mistreating the DOD employees will hurt the agency?s mission. I am also upset at how the NSPS system will change the way workers are paid, evaluated, treated, promoted, fired, and scheduled. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. That has been true sometimes at NSWC Crane and other locations as we've heard from those who've worked at other locales. 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. Annual pay raises, 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 salaries and bonuses will be funded in the future? With the new patronage pay system, what DoD calls ?pay for performance? the amount of a worker's salary will depend almost completely on the personal judgment of their manager. To me this means if you're not a good ?buddy? of the supervisor, this system will force workers to compete with one another for pay raises, which will destroy camaraderie and teamwork as well as 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. I've learned personally how unfair and biased toward management and against the employee the EEOC system is. NSPS could allow managers to schedule employees to work without sufficient advance notice of the changes. This will make it extremely difficult for working parents to care for their children and family. It could also mean abusive managers could harass employees by giving them bad schedules or short notice. Overtime rotations can also be canceled for little reason, which means that employees may not be able to plan adequately for childcare or other responsibilities. I have several health problems and have been told not to work overtime by three physicians, so this would mean I'd most likely have to take an early retirement with a cut unless I qualified for a medical disability. Federal civilian employees could be deployed 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 health and obligations at home. The program I now work for has had several employees stationed in war zones for extended periods of time. We signed up for a civilian job. We did not enlist in the military. I feel that today?s military volunteer system works well. America is at war. We are fighting for democracy abroad. But these new regulations are an attack on workers? basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers? welfare while they try to protect themselves from abuse on the job. I urge you to force or at least vote for DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. In the Pay & Benefits Watch of March 3, 2005 an article titled ?Pick Your Fights? stated: ?House Minority Whip Steny Hoyer, D-Md., told a union rally Wednesday that while pay for performance is a good idea, the Bush administration plan for overhauling the civil service is fundamentally unfair. Speaking to a National Treasury Employees Union rally in Washington, Hoyer said that federal workers' organizations should not oppose performance pay and outsourcing in principle. Instead, he urged union members to fight for equitable and transparent systems. "We are not afraid of pay for performance, but what we want is a fair system in which to operate," Hoyer told the cheering crowd. Specifically, he said the White House is trying to weaken the appeals process. The Bush administration is implementing sweeping reforms at the Defense & Homeland Security departments that will abolish the General Schedule pay system, restrict union bargaining rights and implement stricter disciplinary rules. Bush and other federal officials have suggested that this reform should be spread to other federal agencies. On Wednesday, Hoyer said that the administration is using improved performance as a guise to install its own management preferences. He said that existing civil service laws allow for performance pay if they are correctly applied. "They do not philosophically believe in your right to organize," Hoyer said. "They want to do away with collective bargaining." The White House did not respond to questions about Hoyer's accusation. Hoyer and NTEU National Vice President Frank Ferris also told the rally that the Defense and Homeland Security departments are being pushed into an untested personnel system. "That makes absolutely no sense," Hoyer said. At one point in the rally, he asked employees not to denounce the concept of outsourcing on principle. "We are not against doing the best job for the taxpayer," Hoyer said. He told NTEU members, however, that they should fight for a fair and transparent system that provides the best service at a reasonable cost. "Nine times out of 10, we will win the competition," he said. Hoyer also said that he had introduced a House Resolution - H. Con. Res. 40 - to support pay parity. President Bush has proposed a 3.1 percent raise for military personnel in 2006 and a 2.3 percent raise for civilian workers. In previous years, Congress has granted equal raises to all federal workers. "Let me tell you what we are going to do," Hoyer said. "We are going to pass pay parity." The crowd chanted "Steny, Steny, Steny" as he walked away from the podium. "He's our hero," said one union member.? Please consider all this when you vote. Thank you for your time. Sincerely,