| Comment Number: | EM-017682 |
| Received: | 3/11/2005 6:42:11 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 11, 2005 DoD NSPS Comments , DoD NSPS Comments: I'm writing to express my concerns about changes to work rules in the Department of Defense (DoD). I am vehemently opposed to the proposed regulations known as the National Security Personnel System (NSPS), printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. 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. Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past ? as recently as just last year ? DoD did not fund its awards program. Consequently, there is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. 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 as 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 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. Sincerely,