| Comment Number: | EM-017497 |
| Received: | 3/10/2005 7:04:21 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 9, 2005 DoD NSPS Comments , DoD NSPS Comments: 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 find it incongruous that "pay for performance" could be introduced by the same administration that suggests minimal pay raises for the Civilan work force every year. This is an indicator of their perception of our "performance". I work at Portsmouth Naval Shipyard in NH. If this NSPS is instituted, then our record of performing the fastest and most economical submarine overhaul would equate to large bonuses for every employee! Why don't I believe that it will happen? And if we are even being considered for inclusion on the BRAC list, then "pay for performance" is a complete SHAM! Supervisors will not become fair evaluators overnight (if ever), due to the human factor. Favorites are already promoted without much regard for expertise or skill level, and the present system is geared to limit the abuses. There is nothing in place that defines how this system will work, other than amophous "guidelines". Talk about a "pig in a poke"! I would prefer to see something concrete before I "buy in". Using the recent "whistleblower" law as an analogy, there is very little protection for any one who reports an abuse, and the damn law is in place to protect the reporting party! Actual case studies have shown that retribution is NOT uncommon! NSPS would discourage any original thinking or initiative, in favor of "going along" to get the appropriate raise, I BELIEVE. My 28 years of government service have convinced me that a pay system which is independent of personal favoritism is the least likely to be abused. It also encourages input that "goes against the grain" or the "majority opinion" for improving foolish or cumbersome work practices. Most DoD employees work hard and are committed. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. Forcing workers to compete with one another for pay raises will destroy teamwork, increase conflict among employees, and reward short-term outcomes. The best workers will receive a pay raise? The pay offered will be fair? I have personally spoken to people here at Portsmouth that have been asked by their supervisor to write their own job description when an opening is being advertised! That rather limits the competition, and is an example of supervision that is improperly trained. How will this change, other than being easier to violate? The 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. 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. I proudly served my country for four years iun the US Air Force, 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. These regulations are an attack on workers' basic rights. 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,