| Comment Number: | EM-019843 |
| Received: | 3/11/2005 3:20:21 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: The National Security Personnel System (NSPS) is being rushed into place in DoD with little solid information disseminated. We had one open meeting, but most of our questions were answered by saying that what we asked had not yet been determined. Now that I see the information in the Federal Register, I find the wording both complex and vague. I get the feeling that they can do most anything they want under this system as it is described. When I came to work for the Federal Government, I did so to help ensure our liberty. This document does the exact opposite for those who work hard to defend our freedom. I may sound like I am talking about the military. I examined 3 of the 4 services before joining Civil Service, including undergoing Army ROTC boot camp. It was an Air Force Recruiter who helped convince me that my talents could be best utilized for my country in Civil Service. I am convinced they were. My choice of Civil Service was a patriotic choice. I write to express my deep 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. The NSPS provisions will make it difficult, if not impossible, to get and retain good talent for the Civil Service without a substantial increase in pay. The new rules strip away our rights to redress if treated unfairly. They leave us vulnerable to capriciousness of managers if we do not see eye-to-eye on any issue. Now if, in my engineering judgment, my chain of command is following a policy I consider to put the life of our servicemen at risk, I speak up. Under NSPS, I would hesitate to put my future in jeopardy. My managers would control my pay, my job assignments, and my hours and I would have little recourse. Remember the Challenger disaster. The engineers considered the chance of loss of life to be about 1 in 100 launches. Managers considered it to be 1 in 10,000. The managers did not listen to the engineers, with dire consequences. Under NSPS, engineers would be afraid to express unpopular opinions. Their rights against reprisals will be too greatly weakened. I have worked for DoD for nearly 36 years. My current assignment is to ensure that the equipment that attaches carrier aircraft to the catapult system works every time. It?s a challenging and serious business. My Father worked for Civil Service before me, as well as being a WW II veteran, retiring with the rank of Lt. Colonel. I am extremely concerned that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the 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 serving the civil concerns of the American people. I have seen several instances of favoritism under the old system. One engineer was repeatedly kept back to a near entry-level rate by his immediate supervisor. The engineer was one of the sharpest I have known at design calculations, but he did not dress as the supervisor would have liked him to. He since went to work at another agency and rose to a position above the supervisor who held him back. Under NSPS, the Government would have lost his talents. 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. DoD 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? Who wants to work for a company that can change your salary at a whim? ?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 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. I have seen the damage that can be done when employees try to look good to the boss and grab credit. I have also seen the advantages of employees who work as a team to get the job done. NSPS will reward the former. 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. I had a supervisor who would have used denying reasonable leave as a weapon against those he did not like. Under the current rules, he had to abide by existing rules, not ones he made up as he wished. We also had recourse to redress, if he acted arbitrarily. 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 but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today?s volunteer system works well. I was asked to go to a war zone and was willing to do so. A friend of mine had to retire from the Air Force because he has a special needs child who would not survive if he left the hospital care available in this area. I value having a say in where I work. America is at war. We are fighting for democracy abroad. But the 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. Sincerely,