Comment Number: EM-017413
Received: 3/14/2005 11:33:47 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 14, 2005 DoD NSPS Comments , DoD NSPS Comments: WE are at war! We do not need to reinvent the civil service system at a time of war. This will cause employees and supervisors to spend half their time going to classes and trying to figure out a whole new system that does nothing to improve our warfighting efforts. 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 term ?implementing issuance? is used 105 times in the NSPS proposal. That alone should be the reason to slow down this implementation. An ?implementing issuance? refers to some rule DOD hasn?t figured out yet, but they will just put it out when they get around to it. That means this new system is half-baked and will lead to confusion and frustration in the workplace; not the atmosphere you want to have at the time of war. Uncertainty about policies and procedures leads to unintended consequences. Look at Abu Ghraib prison for an example. Now multiple that by hundreds of thousands. It is time to go back into the kitchen and work with the union to create something palatable. Allowing foreigners to take jobs that were formerly designated as US civilian only is not in the interest of the War on Terrorism. All overseas civil service jobs will go to local nationals, because the job can be declared local and no PCS (Permanent change of station) would be paid. What US citizen wants to pay for their own transfer overseas. This is outsourcing civil service, just to save money. There is no enhancement there. Only the loss of valuable experience and expertise. The loyalty to our country will not be there. We now receive annual cost of living raises and step increases. Management can reward their "top performers" with QSI's/cash awards. Under NSPS we are not guaranteed any increase. They state we will not lose money going in (that lasts one year) and they will "try" to keep the same money allocated for NSPS in the aggregate as would have been available under our current system. With no within grade increases, we lose money in the long run. Also, if we hit the top of your pay band and they don't increase it (it is established based on a market survey of our local area) we receive no increase (that's where the stand alone cost of living saves us now if we are at the step 10 level). They can give us a cash award, but that does no good for retirement high-three. I have worked for DoD for 25 years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. It is anti-union, and it limits their powers. The union is the loyal employees, though. So, when the reg is anti-union it is anti-employee. 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. 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. This will be grounds for dismissal, if we refuse to move to a war zone. It has happened in careers with mandatory rotation, and this basically calls every job now a mandatory rotation position. 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,