| Comment Number: | EM-017599 |
| Received: | 3/14/2005 8:31:11 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 14, 2005 DoD NSPS Comments , DoD NSPS Comments: General: I believe the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD employees. 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. 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. 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. Subpart G Adverse Actions - 9901.701 to 9901.810: Due process and fairness demand that the independent body reviewing a major suspension as 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. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a ?company dominated dispute board.? Any dispute board must be ?jointly selected? by management and the Union. I believe federal employees should continue to have the same benefits as those in the military in regards to pay and time in grade. An E6 with 15 years of service is paid more than and E6 with only 8 years of service. This is because of the experience level of the E6 with 15 years of experience. The same holds true of civil service using within grade increases is the closest that the system comes for rewarding experience. The military wouldnt think of taking away time in grade for the military. Why do this for civil service? As I see it, NSPS is just a transition tool to privatize as much of government as possible. Under NSPS civil service employees will beave in droves and vacancies will be pushed to the private sector. Sad. Sincerely,