| Comment Number: | EM-019936 |
| Received: | 3/11/2005 4:46:53 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: I wish to express my comments about the drastic changes to civilian employee work rules in the Department of Defense (DoD). The proposed regulations [i.e., National Security Personnel System (NSPS)] were printed in the Federal Register on February 14, 2005. I am also forwarding these comments to my representatives in Congress. I have worked for DoD for over 25 years. I believe these rules will treat the employees who help defend our country as the enemy. The overwhelming majority of DoD employees work hard and are committed to public service and National security. I believe that mistreating the employees will severely hurt the agency?s mission. NSPS will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules will create a system in which Federal managers are influenced by politics and favoritism rather than serving the concerns of the American people. Annual Pay Raises. Under the existing General Schedule, employee pay is clear. It is funded by Congress and cannot be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past ? as recently as 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? How can we plan for 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 only short-term production. 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 families. NSPS is not family-friendly. It will also allow abusive managers to 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. Civilian DoD 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. NSPS establishes a ?backdoor draft.? Today?s volunteer system works well and has created the finest warfighters in the world. America is at war. Ostensibly, we are fighting for democracy abroad. But the NSPS regulations are an attack on workers? basic rights here at home. Furthermore, NSPS will divert the attention of Defense workers from the soldiers? welfare to protecting themselves from abuse on the job. I urge DoD to reconsider this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Department of Defense workers. Sincerely,