| Comment Number: | EM-019757 |
| Received: | 3/10/2005 3:31:12 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 10, 2005 DoD NSPS Comments , DoD NSPS Comments: I am writing this letter to protest the replacement of the current tried and true personell sytement with the new untested NSPS system. The wholesale replacement of the old but reliable civil service system with the new untested NSPS is a huge mistake. Even if I thought that NSPS was a great new system, which I do not, it would still be a mistake not to test this system on a very small scale before bringing it to the entire DoD system. Until the goals and objectives of NSPS are defined and a mechanism is established to measure these, this system should be put on hold. The testing and refining of a new civil service system will take a lot of resources, time and money but if done right will be worth the effort. The current civil service system has been in place for about 50 years. Any new system set to replace it should be well tested and have a track record before it is even considered. Before a car company introduces a new model, the car is tested and retested, refined and retested again. The DoD is asking Congress to accept their new model NSPS without any testing or refinements and on top of that to ignore all the critics and to ignore Congress? own intent in writing the law authorizing NSPS. The rational for changing to NSPS was the terrorist?s attack on September 11. The civil service system had nothing to do with the attack and should not be blamed for it. Furthermore, changing to NSPS will not stop any future attacks. I would agree with one point of NSPS and that is our civil service system does need a change. However, facts show that our civil service system changes every year just like our government changes. Our government passes new laws, courts decide how new and old laws are to be applied to ever changing circumstances and new technologies, and new government officials are elected. The changes in our government are reflected in the changes to our civil service system which has adapted to new technologies, new threats and new duties and responsible. We do not rewrite the Bill of Rights and throw out the Constitution each time we have a crisis. We should not be throwing out our current civil service system because Donald Rumsfeld finds it too difficult for him to manage. For about two decades the US Military has been working on fixing their problems concerning sexual misconduct and sexual assault. These are problems that have been identified by many different sources inside and outside the DoD yet no positive action have taken place that corrects these matters. Why would Congress now allow the DoD to invent their own personal system given this abysmal track record when it comes to correct personal matters? Allowing the DoD to change to NSPS is rewarding them for their passed stonewalling, and avoidance in dealing with unacceptable criminal behavior. Given the DoD track record of attaching the victim and not prosecuting the perpetrator it would be wrong to allow NSPS to go into effect as written since this personal system shifts the burden of proof on the victims of abuse. At a time when we need to strength worker protections the DoD is insisting that we do the exact opposite. One of the worse parts of the NSPS system is the pay for performance proposal. Pay for performance is a trick that cuts cost of annual pay increase normal given to federal workers. The tradition of tying civilian pay increase to military increases can be maintained, however under pay for performance only a small fraction of the civilian work force will actually receive the entire increase, thus holding down the real cost. If the military receives a 5% pay increase and only 20% of the civilian work for receives the same military increase the entire federal work force only averages a 1% increase. Pay for performance has nothing to do with increasing performance but everything to do with holding down costs. At Pearl Harbor Naval Shipyard the performance system has been simplified to pass/fail. This program has been resounding success. Employees work together as team members on project and not as individuals. Under NSPS we will return to the bad old days where people would game the system in order to make themselves look better than others rather then the current system of cooperation. When pay raises are tied to performance evaluations an employee has to ensure that their performance is better than someone else is. The pay for performance system does not promote cooperation and team building nor does in promote the sharing of knowledge and information. The NSPS? intentions are quite obvious; water down workers rights, silence any dissenting ideas, and spread fear and intimidation in the work place and hold down annual pay raise costs. How Mr. Rumsfeld expects us to believe that this will protect us from future terrorist?s attacks is beyond me. Please do what you can to stop the implementation of NSPS. Sincerely Sincerely,