| Comment Number: | EM-019758 |
| Received: | 3/9/2005 9:48:35 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 9, 2005 DoD NSPS Comments , DoD NSPS Comments: I am writing to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. To say I am disgusted and angry with the way these proposals will treat the employees who help defend our country is an understatement. DoD employees work hard and are committed to this country or they would never have decided to work at DoD to begin with. I believe that mistreating the employees will hurt the agency?s mission and weaken this country's defenses. 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 serving the civil concerns of the American people. These rules come right out of the 18th century and they show we have not learned from history. It is well known that those who do not know history are bound to repeat it. I am sorry to say this is what is being done here. Annual Pay Raises 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 and uncertainty will make it more difficult to attract and retain valuable employees. 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 their salaries and bonuses will be funded in the future? ?Friend of the Supervisor? Pay System 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 supervisors. Evaluation systems based upon employee "attitudes, appearance, behavior, etc." fell into disfavor years ago, and this is the system being proposed as "new and improved." Please. This system will force workers to compete with one another and in turn 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. It 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. This will undermine the security of the United States, not increase it. Employees will who question the rationale of decisions can either quit or be fired. This does not enhance this country's security. Schedules and Overtime 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. The need for short notice overtime, even in the military, should be rare. For it to be otherwise is an indication of poor planning by those in charge. If civilian employees are going to be repeatedly subjected to short term schedule changes, it will be difficult to recruit and retain the best workers and a diverse work force. Civilian Deployment Civilian employees could be assigned anywhere in the world, even into a war zone, with little or no notice. Public employees are proud to serve our country, but they are also responsible for caring for their families and personal obligations. They had a choice to serve DoD in a civilian or military capacity, and they chose a civilian capacity. They should not be treated as unmarried buck privates who have been drafted into the service. We don't even treat our volunteer army so poorly. America is not at war in the traditional sense of the word. However, DoD has chosen to whip up a war hysteria to advance an anti-union anti-employee agenda to the deteriment of national security. We are fighting for democracy abroad, yet DoD is attempting to create a fascist bureaucray here at home. DoD's regulations are an attack on workers? basic rights, human rights, and all this country has ever proudly stood for. Your efforts will divert the attention of defense workers from our 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. Sincerely,