| Comment Number: | EM-017515 |
| Received: | 3/10/2005 7:06:05 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 believe the new NSPS regulations are flawed beyond repair and that the DoD needs to (once again) start over, but this time actually negotiating with the unions rather than hiding behind the word "collaborate" with the unions. Perhaps a more "flexible" word would be "co-author" with the unions' leadership. Presuming for the sake of argument that all parties agreed with the NSPS regulations as they have been published to date, I still have a problem with the regulations. I see absolutely NO BONIFIDE REASON to implement the regulations upon all the currently employed federal workers. These regulations totally disrupt existing working conditions and relationships, which form the most basic tools for individual employees to use for planning their future. Change the "rules" this drastically and you introduce CHAOS into the lives of the civil servants; chaos which is already lowering morale and hurting productivity. Since the majority of the federal workforce is rapidly approaching retirement age, to allow a choice between NSPS or the existing Civil Service rules seems appropriate. New hires as of the (estimated) implementation date of 1 July 2005 would fall under NSPS automatically, while existing employees would choose which one to work under. As the workfore retires, incoming new hires would gradually replace Civil Service employees with NSPS employees in a gradual and "painless" transition. New hires would know from the beginning what NSPS is and is not; thus, being able to plan their careers accordingly. Civil Service employees would continue to serve with no disruption in their planned careers and retirement funding. This is essentially the same thing that was done when the retirement system's funding plan was changed from CSRS to FERS. Employees had the option to choose which plan to save and retire under. Since we know that NSPS is seriously flawed and is not supported by everyone, it is not unreasonable to allow employees the option to remain under Civil Service rules until qualified for retirement. Sincerely,