| Comment Number: | EM-017592 |
| Received: | 3/15/2005 11:21:00 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 15, 2005 DoD NSPS Comments , DoD NSPS Comments: General: First and foremost I believe the proposed NSPS will undermine the Civil Service system and hurt the mission of the DoD employees. Our Nations defense should be geared towards a team work like effort. This new system will not only do a way with team work, but it is also going to promote the good old boy network. In addition the incidents of one worker stabbing another worker in the back, to further their career is going to increase dramatically! Second, how can we be expected to intelligently comment on this proposed regulation when it is so vague! There are absolutely no details in this regulation. Everything seems to be based on ?Implementing Issuance? that will be released at some unidentified point in the future. Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive. Every American is entitled to at least a annual cost of living raise. If you want to tweak the current awards system go a head, but please assure us of at least an annual cost of living allowance! The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Management - 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. To base our annual increases on our performance and not have an independent third party to review it is outrageous! Subpart F Workforce Shaping - 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. This new system could very easily be construed as discriminatory towards older workers. Subpart G Adverse Actions - 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension or termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor-Management Relations - 9901.901 to 9901.929 The labor management law that has governed the employees? right to organize and engage in collective bargaining has worked well since 1978. Nobody denies that the current system could use some tweaking, but there is no compelling reason to take away most of the collective bargaining rights or grievance rights. How are these changes going to improve national security? DoD should not create a ?agency dominated dispute board.? In order to operate fairly any dispute board must be made up of both members of management and employees or their representatives. Sincerely,