| Comment Number: | EM-019830 |
| Received: | 3/13/2005 12:42:34 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 13, 2005 DoD NSPS Comments , DoD NSPS Comments: I write 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. The proposed rules are so vague and subjective in application based on biased opinion and will be destructive rather then purposeful, the designed protections for employees as this country supports worldwide, will be missing. Furthermore, the proposed rules of the NSPS virtually eliminate checks and balances, as provided by Federal Unions, which were designed and determined by Congress to be in the best interest of serving the public taxpayer. To provide the DOD, or Homeland Security, this free reign of self-arbitrating employee treatment would be similar to providing the White House carte blanche authority thereby eliminating congressional oversight. NSPS is a ludicrous proposal, as it stands. I have worked for DOD for 25 years and as a Federal Civil Service Title 32 dual status employee for a total of 18 years with 7 years active duty. As a condition of employment I must maintain my enlistment with the Air National Guard. I am angry that these proposals seem to treat the employees, who help defend our country, as the enemy of management. Most Federal employees work hard and are committed. Those few who manipulate the system generally do so through a lack of quality leadership by federal managers/supervisors. I believe that mistreating the employees will be destructive to the overall efficiency of the agency's mission; a disgruntled workforce is not a productive one. I am very upset by this proposal and the potential impact that NSPS will have on future federal employment. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and generally treated. The proposed NSPS rules will not enhance, but deter the retention of quality employees. As NSPS tries to make the rest of DOD look like Title 32 employees, which includes deployable and flexible to mission support it is becoming hard to identify the difference between Active Duty and Title 32. We are a captured audience that is losing what may still appeal to young soldiers and airman to join this particular program. Although we lack the tax free housing and food allowances and don?t have Active Duty base facilities as our counter parts do, we do have our identity and pride that is slowly being striped. These rules would create a system in which federal managers are more influenced by favoritism rather than serving the civil concerns of the American people, which happens to be the most prevalent flaw in the current system. Biased treatment is not being attempted to be corrected, but instead is expanded on by NSPS. NSPS effectively promotes an increase of corruption in the management of the federal workforce. The greatest disadvantage of the current personnel system is the poor training and lack of accountability of supervisory and managerial staff. NSPS will provide increased authority to those same individuals in management who currently unfairly and inappropriately exercise their power over their subordinates. Annual Pay Raises Under the General Schedule and Federal Wage System (FWS), Employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. DOD now funds 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? " Pay for Performance " Pay System: With the new patronage pay system, or Friend of the Supervisor System, 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. We do not ask for commissions on our work like most private industries! If we did this country would be deeper in debt. 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. As an employee in the trenches it is my opinion that managers and supervisors are consistently permitted to treat employees unfairly. When found to have done so, through the current review system, managers and supervisors are not held accountable for their inappropriate actions. NSPS increases the ability for managers to inappropriately punish and reward employees based on personal biases instead of "performance". 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. Currently Title 32 employees do not get overtime pay and for years have lost out in monetary gains. Time spent in differential pay areas as covered by law: i.e. Hazardous Duty, Night Shifts are often only compensated as hour for hour. Civilian Deployment: Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country and do so by accepting dual status Title 32 employment. However my brothers and sisters within DOD may not have the depended care programs as designed to accommodate responsible caring for family and personal obligations at home. They signed up for a civilian job not to be enlisted in the military. 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 and cause them to focus on 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. The proposed NSPS personnel system will take the federal workforce and public service back in history to a time preceding the development of the Federal Civil Service. The proposed plan will reinstate an empire enterprise system that empowers a few to reward employees who personally benefit the supervisor in power and punish those who challenge or otherwise fail to reward their superior(s). NSPS, as it is proposed, will degrade the federal service and increase the potential for corruption through elimination of checks and balances of power. Therefore, the proposed NSPS is NOT in the best interest of the American, taxpaying, public. Sincerely,