| Comment Number: | EM-017581 |
| Received: | 3/13/2005 6:14:00 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 13, 2005 DoD NSPS Comments , DoD NSPS Comments: I I am writing to you as a concerned citizen, civil servant, and member of the American Federation of Government Employees. Frankly I can?t believe I am being asked to comment by subpart on a document that is a definite incomplete. Mary Lacey says people will know upfront, what is expected. If this is any indication, God help us. I just can?t comprehend the why for such radical thinking/action. History has told us that the American people will stand together in National crisis. Just look at the actions/sacrifices of 9/11. Our common citizens reacted with their own conscience (not bound) and in defense of this great country we live. I believe that strength to come from first our Creator and am reinforced by what is committed to the preamble of the constitution, ?Establish justice, insure domestic tranquility, provide for the common defense, and secure the blessing of liberty.? The proposal as presented falls short and could even be characterized as a strategy to divide and conquer. I would question the cost at a time when our deficit is $427 billion. This administrations budget suggests cuts already under scrutiny. And as Stephen Barr reflects, training, of course, is usually the first thing that gets cut in the government when budgets are tight. He also states that if there is not a proper training system in place and budgets that allow adequate training, the system is doomed for failure from the start. I would assert that this to be the major fallacy of our current system and the lack of virtue in performance leadership. Mary Lacey in an interview with the Federal Times says she gets a fair amount of concerns about supervisors. Robert D. Behn, Harvard University Lecturer says, ?the magical performance system doesn?t exist, even a good performance system doesn?t exist. Systems don?t improve performance, leaders do.? Rule driven approaches are unlikely to be very effective, he contends. The challenges of Transformation, to do more with less, and the requirement to be multi-functional are already taxing our priorities. I rely on the local union as a barometer, to keep us informed, voice the discern. and resolve issues at the lowest possible level. This allows me to better focus on the duties as assigned. Have you considered what you don?t see in the offices, questions/discussions/resolution that don?t meet the manager?s desk? Or the collaboration for uniformity. To limit the interaction of local Unions is not a good thing. In summary, on 9/11 my daughter, who has children of her own called, terrified she asked, dad what?s going, what are we going to do. My response was ?Tracy; we have some very smart people working this. We will get through it. You are very well educated; it?s the agenda?s you need to consider. There is a cost for Freedom and inherent risk for liberty.? With that and for lack of detail and/or time, I need to beg to differ on your proposal and I will ask my Representatives to intervene, wheels down and chock. For as it currently sits, how can it be executed with any assured fairness. Dictatorial and ambiguous. ?As long as laws are absolute there can be no justice, life in itself is an exception.? The Editorials and Articles Influencing this writing are: ? New Personnel Systems put premium on training; By Stephen Barr ? Rough Draft #3, Comments as presented by Minahan and Shapiro P.C. Attorneys at Law, Daniel Minahan and Barrie M. Shapiro ? Expert Sees Problems in Search for a Perfect Performance System, by Stephen Barr ? Sample Comments for NSPS, Classification, (subpart) 9901.201 to .231 ? 2,429 Arsenal workers to be among the first round to lose civil-service status, by Edward Felker ? Complaints About NASA Raises Follow Switch to Performance-Based System, by Stephen Barr ? Department of Defense Proposed National Security Personnel System ? DOD?s Personnel Overhaul, by Tim Kauffman ? Commentary, Perspectives and Analysis, Off to a Bad Start, Federal Times, 7 Feb, 2005 ? Potential Options for the National Security Personnel System and Human Resource Management System ? Fact Sheet, DOD National Personnel System-Proposed Regulations 10 Feb 2005 ? Union distributes pamphlet with negative reactions to performance pay, by David McGlinchey, 18 Nov 04 To do Justly and to Love Mercy and to Walk Humbly with thy God MICAH 6-8 Sincerely,