Comment Number: EM-019845
Received: 3/11/2005 10:18:42 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 11, 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. This message will be sent to both DoD and my representatives in Congress. I have worked for DoD for years. 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. 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. 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. Salaries and bonuses are funded by DoD. 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? ?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. 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. 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. 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. I am writing to express my concern with the proposed National Security Personnel System that the Department of Defense is adopting. My concerns are as follows: Pay bands- 1. If one is in the upper steps for the top step being driven into the payband, the room for a raise, no matter how well one performs, will be restricted. 2. Tying the whole amount of a salary to the regional prevailing wage was a poor system under the Wage Grade program, and would have the same affect on GS salaries. Personal history indicated that under WG we were receiving about 70 to 75% of the wages for like jobs just across the runway. They had great overtime opportunities to further enhance their paychecks, and we had very little opportunity for it. Current national GS wage schedule with locality adjustments is a much more fair program. 3. Forcing several professions with different education requirements into one payband would seriously prejudice ranking of individuals according to the band allocation. For instance: an Aircraft Engineer with a master?s degree competing with a Quality Assurance Specialist with 15 years practical experience and an associate?s degree in Airframe and Powerplant education would compete within the same payband. If 50% were of each discipline, who will receive annual raises to stay competitive in the region? They are both critical to the product, but the system would be weighted against the QAS automatically. Union Representation- 1. DoD is trying to legislate the rights of each employee out of the regulations. Without any semblance of combined representation, each will be required to fend for himself against the management organization. That is an unfair position in which to be placed, when one is being impacted by a management decision without recourse. 2. DoD proposed changes assault the concepts of collective bargaining and grievance procedures. This NSPS proposal changes the principles of collective bargaining to ?Management?s Rights?, without negotiations or arbitration. Workforce Shaping- 1. New reduction in force procedures allow biased ratings from supervision to outweigh time an employee has spent with the government. The whole idea of vested service is replaced by subjective opinions. Veteran?s preference points concept is reduced to an afterthought. 2. Forced relocation will be detrimental to workforce morale and family values in many instances. I have worked overseas and enjoyed it, and work a substantial distance from family, but not everyone desires to move away from the family environment. DoD wants to have the right to relocate an employee as management desires, regardless of other options. Stated NSPS goals:  Put the mission first;  Respect the individual and protect rights guaranteed by law;  Value talent, performance, leadership, and commitment to public service;  Be flexible, understandable, credible, responsive, and executable;  Ensure accountability at all levels;  Balance human resource system interoperability with unique mission requirements; and,  Be competitive and cost effective. DoD has the right policy in the proposed NSPS to meet the first goal, but the rest fall far short in this proposal.