| Comment Number: | EM-022838 |
| Received: | 3/16/2005 1:55:29 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:
The following is my comments on the proposed NSPS. I currently have 32 years of combined military and civil service to this great country. 1. pg 7559-7560 Locality pay allows me to more adequately compete with other wage earners, The NSPS does away with the current system and considers things like availability of funds, mission requirements and other things such as DOD may determine local market areas and timing of these pay adjustments. Why should my income depend on things of this nature and other federal employees not have to bear this? This gives the Secretary and the Director an opportunity to use the DOD civilian work force as a budgetary pawn which is unfair. This canalso impact states because of increased or decreased buying power. Which can be federalism. 2. pg 7560 Performance ratings are ambigous at best and detremental to workers. Supervisors that will not write or chose not to will rate thier employees at the least effort required by them. I have seen these through out my military and civilian career. One of the situations that happens is seeing past military bosses in postions of civil service shortly after they retire and they get perferential treatment. Expertise is one thing but favoritisim is entirely something else. 3. pg 7561 reduction in pay band or rate is very grey at this point and can be done voluntarily or involuntarily. Again budgetary pawn can be in effect. Also this can havean impact on federalism, which will impact states and the proposed rule says it will not. If a person is pay reduce it affects thier buying power and can be done voluntarily or involuntarily. 4. pg 7562 Pay for performance is only as good as the management and supervisors make it. This gives the opportunity for "good ole boy club" and persons that perform poorly but play the boss's favorite the oportunity to excel. Past experience with this by OPM should be a good indication as to why the current pass fail rating was established. 5. pg 7563 hiring employees and giving them immediate career status is wrong. This puts new employees on the same level as employees that have performed at a high level and new ones the same footing. Again friends and the like get same or better treatment then some one that has performed for years and years. 6. pg 7565 Reducing the appeals period is unfair at best. Obtaining representation in the greater Washington DC area might be realitivily easy but in rural Nevada will most likely be difficult at best or impossible and now a new system that applies only to select federal employees and most likely new case law. Are lawyers going to get training on the NSPS also? 7. pg 7567 Also dealing with time frames same comment as 6 above 8. pg 7567 penalty review. This gives way too much power to the Secretary and less power to the MSPB 9. pg 7570 The items are close to Union busting techniques particularly contracting out and dealing with clerical duties. 10. pg 7574 Impact on states Federalism Any thing that canaffect pay of residents can and does affect states. 11. pg7575 The time frame for sucess as listed is misleading. Pilot or Demonstration projects have been in existents for many years with out some of the elements listed above such as eleminating locality pay. Some organizations that have been on some of these prior programs are exmpt from this system kind of makes me wonder why. China Lake, California for one. 12 pg 7577 Reduction in band. This gives the DOD the opportunity to fund this on the backs of hard working civil service employees. An employee currently covered by a non-NSPS federal system to a postion determined to be at a lower level of work in NSPS. 13. pg 7578 Onceagain this gives the Secretary too much power in the systemand smacks of Union Busting. To the extent the Secretary deems nessecary and Secretary to determine 14. pg 7579 How can one endorse a program that does not spell out hwat it really means in black and white. DoD will develop a methodology and DoD will make available to employees. This is like asking one to buy a house with out knowing if it has running water. 15. pg 7582 Performance payout. Same comments as 14 above 16. pg 7589 where it refernces no undue interuption would take place. This statement is entirely too ambigous and gives too much discretion to management as to what that means instead of to a displaced employee. In closing let me state that this is a very good system and that it just needs some fine tuning. --------------------------------- Do you Yahoo!? Yahoo! Small Business - Try our new resources site!