| Comment Number: | EM-019755 |
| Received: | 3/10/2005 7:04:56 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'm writing to express my concerns about the proposed changes to the working conditions for civilian federal employees. The proposed regulations pushed forward by the Department of Defense (DoD), known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. These new regulations threaten to eliminate a lot of the rights and benefits of workers currently employed by the DoD. I have worked for the DoD for over four years as a traditional guardsman and more recently became a member of the title 32 technician work force. I'm assigned as an avionics technician for F-15 aircraft. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed to the defense of this country. I believe that mistreating these employees will hurt the agency's mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than by the performance of there employees. 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. DoD will be funding salaries and bonuses. In the past - as recently as just last year - DoD did not fund its awards program. Given the agency's miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? One of the biggest draws to the technician work force was the stability of knowing that you and your family's income was secure. This security helped you look past the frequent deployments, long nights with no extra pay and the other hazards associated with maintaining military aircraft. Without this security some employees might think twice about staying in the system for 20 or 30 years. With the new patronage pay system, which DoD calls "pay for performance," the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Under the current system people aren't afraid to report mistakes made during maintenance, because there isn't a fear that there income will suffer. If this new system is allowed to be implemented people will no longer want to report there mistakes because of fear that there income will be negatively impacted. This could cause severe safety problems that will impact the mission in a very real way. Consider a technician who works a jet and forgets a wrench on the aircraft. Later during a foreign object damage check he discovers that he is missing a wrench from his toolbox, but doesn't report it because he is worried about the repercussions. The jet takes off and that wrench causes an engine to shut down maybe causing a crash, which could result in the loss of life or millions of dollars in damage. NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. As a guard technician I am dual slotted in both a technician and military slot. What does the DoD plan to gain from this new system? If they need more people to fill vacancies over seas for the global war on terrorism why don't they do some partial mobilizations of guard units? All of the title 32 guard technicians are required to hold slots militarily so if were needed we can be activated and sent over seas. It seems as though the DoD is trying to reduce the amount of guard units that are mobilized by sending the same guardsmen in a different status. This looks like an attempt to mislead the American public into thinking that less guard unit are being mobilized while in fact there is no change. Today's volunteer system works well. When there is a need for manpower to put towards a contingence people step up and are activated for deployment. America is at war. We are fighting for democracy abroad. But these regulations are an attack on workers' basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers' welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. I would appreciate to hear your position on this topic. Sincerely, Customer Survey - Help us to help you. Link is: http://www.cpms.osd.mil/survey/index.asp