| Comment Number: | EM-017478 |
| Received: | 3/10/2005 2:14:32 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 10, 2005 DoD NSPS Comments , DoD NSPS Comments: To the Department of Defense and to Congress, I would like to express my strenuous opposition to the new proposed DoD Personnel System (NSPS). I am currently employed by DoD at the U. S. Army Tank-Automotive and Armaments Command (TACOM) at Warren, MI and I have faithfully served as a Federal employee for over 18 years. I do not feel that the new proposed system is an improvement over the current employment system and, in fact, is actively opposed to my welfare, job security, and my family?s standard of living. Several points of the new system are of particular concern to me: 1) DoD civilian employees as deployable assets. I know that our country is at war but at no time in my career did I ever sign a mobility agreement or intend that I might have to perform my duties in a war zone. If that was my intent, I would have enlisted in one of the armed services, not as a Federal employee. The idea that I could be forced to deploy to Iraq to retain my job for an indefinite period of time instead of being asked to volunteer disgusts me and makes me truly wonder how arrogant this administration is. I have heard our Personnel Dept. here at TACOM and other sources say that NSPS won?t change DoD?s ability to force us to deploy overseas but this is a complete lie. Our Command was going through a drill designed to try to involuntarily deploy civilian personnel to Kuwait and Iraq if our list of volunteers wouldn?t be enough to fill vacancies in SWA. I did quite a bit of research on this issue since I was in the middle of the list to be forced to go overseas and it was determined that DoD couldn?t force a civilian into a Permanent Change of Station (PSC) situation unless they had signed a prior mobility agreement. However our Command, in their finite wisdom, decided that there wasn?t anything in the rules against sending us on Temporary Duty (TDY) for 120-180 days. This was a violation of at least the spirit of TDY regulations if not an actual violation of the law. But their attitude was ?We?ll go ahead until somebody complains or files a lawsuit and then we?ll find out if we can get away with it or not.? It?s this kind of attitude within our Command structure and the higher levels of DoD that makes me think that the only reason Rumsfeld and the Bush administration are going through with this is to make things easier for them to do what they want with Federal employees. The last thing they have on their mind with the implementation of NSPS is the welfare of DoD civilian employees. And my family would suffer immeasurably if I were to be killed in Iraq or wherever. In addition to the loss of a husband and father, my family would immediately lose their home, school, and would most likely be shattered financially without the life insurance policy I have paid for over the last 15 years. My insurance company WILL NOT cover me anywhere near a war zone and the pitiful coverage afforded by DoD is more of a slap in the face than anything else. 2) I just don?t trust Donald Rumsfeld?s or the Bush administration?s motives on this change to our personnel system. Would I trust my welfare, future wages and retirement to an organization that, at best, couldn?t reliably determine if Saddam Huessein possessed weapons of mass destruction before they embroiled this country in the largest war since Vietnam or, at worst, actively deceived the American public and the rest of the world to fulfill their own secret agenda? I can?t believe that they would actually do something to improve the benefit?s I will be receiving as part of my Federal service. I find it much easier to believe that they are doing this to bypass established OPM regulations and set the personnel system up so that they can do anything they feel like. Rumsfeld and the Bush administration have systematically dismantled 25 years of changes that the military has made rebuilding the armed services from the mess that civilians made of the military after they ran it into the ground during Vietnam. NSPS is just their attempt to do the same to the OPM system that has served us for the same period of time. The truly sad thing is that in four years they will all move on and we will be stuck with their misguided attempt to reshape the civilian side of DoD. This whole push to NSPS reminds me of the change from the CSRS retirement system to FERS. FERS was not an improvement as far as the employees were concerned, it was an improvement for the Federal government. It all but eliminated the guaranteed retirement benefit and shifted most of the cost and all of the risk to the employee. And at the time there was a big push by Personnel and higher DoD officials to get CSRS employees to switch to FERS citing greater benefits and larger retirement checks from money invested in the stock market. The only problem is the stock market tanked and now there are people here at TACOM who can?t retire when they planned or even retire at all because they were foolish enough to believe the government claims that FERS was a better program. I?ve seen the effects of that mistake on others and I don?t want to be the unwilling recipient of the Federal government?s ?largesse?. For me, this all comes down to comes down to a simple maxim: Dilbert?s Law: Any change to a personnel or pay system results in less benefits and pay for the employees. After all, if they really wanted to give us more money, they?d just give us more money? 3) Hiring qualified personnel. I just do not believe DoD?s assertion that this system will allow them to hire more qualified people to replace those fired or retired under NSPS. TACOM has hired over 700 new interns over the last 3 years as our workforce reaches retirement age; so many new hires that there isn?t enough parking places or desks to accommodate them. And do they truly think that they will be able to hire any but the most desperate people once NSPS goes into effect and new hires learn they can be sent indefinitely into a war zone whenever TACOM decides to send them? The Army should understand that this sort of thing is what is stopping anyone in their right mind from joining the National Guard and causing experienced soldiers in the Active Army and Guard to retire in droves. It doesn?t seem to me that TACOM is having any trouble hiring people as witnessed by the huge influx of interns over the past few years. A lousy economy has much more to do with the quality and number of recruits at this installation than the current OPM regulations. 4) Extremely short timeframe to evaluate this proposed change. The Army Material Command (AMC, TACOM?s higher HQ) had proposed a similar change to the personnel system several years ago. Several of it?s stated objectives were streamlined hiring and firing, pay banding, performance based bonuses, and changes to the employee grievance system. In most respects, it was superior to NSPS based on the small amount of information available to me on NSPS. The AMC initiative was worked out with the input of TACOM employees and was developed over about a year and a half. TACOM?s AFGE local was also given the opportunity to have it?s members vote on whether the union would approve the plan or not. The union membership voted over 2 to 1 not to accept the plan. Now we have NSPS which, according to a union lawsuit in Federal court, was developed totally within the Bush government with no outside input from any employee or union group and which was sprung upon us about 60 days ago in the Federal register. This is way too little time to determine the merits and deficiencies in any plan as far reaching and comprehensive as NSPS. It seems as though this is a deliberate attempt by the Bush administration to rush this through whatever approval channels required to get this signed into law. As I said before, the AMC personnel change was formulated and debated over at least a year and a half and now we have only 30 to evaluate this new program and make our opinions known? Sorry, that?s much too fast for something that?s going to effect 700,000 people and which we?ll be stuck with for years to come. In conclusion I would like to say that I am violently opposed to NSPS and ask anyone with the power and conscience to oppose this arrogant attempt by Donald Rumsfeld and the Bush administration to destroy DoD?s civilian workforce to do so. Any proposed change to a personnel system which potentially puts my life at risk isn?t worth implementing no matter how convenient it makes things for Donald Rumsfeld.