| Comment Number: | EM-022891 |
| Received: | 3/16/2005 8:33:11 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 16, 2005 DoD NSPS Comments , DoD NSPS Comments: COMMENTS TO THE NATIONAL SECURITY PERSONNEL SYSTEM (NSPS) My real concern is that the NSPS will not further national security nor improve the much needed support to our over-extended troops. Mandatory mobility and deployments for all (combined with the upcoming BRAC 2005) will force an early exit of mid-career and senior employees with the most logistics experience. Many will be ineligible to deploy for medical reasons. Others can?t or won?t move. At the same time the BRAC will eliminate many employees, both old and new. The logistics base will be decimated!!! Many newer employees, who hire on with full knowledge of the deployment and mobility requirements of the job, will quickly tire of unending deployments. They don?t have the personnel support structure the military have for home and family. They will be forced to choose between the job and having a ?life?. You will have high turnover, just as the reserve forces are facing as a result of their multiple deployments. The real losers will be the troops on the front lines. Yes, some in-theatre civilian support is needed. But remember, a major logistics support mission is done at the major commands, major subordinate commands, depots, and other CONUS logistics activities. Most of these support personnel need not be deployable or fully mobile. In fact, consistent stable logistic support is best served by experienced personnel in those jobs for the log haul. Mandatory deployment and mobility for all is not necessary and will degrade logistics support!!! As DOD does away with logistic support elements within the force structure, loses the highly trained civilian technical specialists (as a result of NSPS), and relies more and more on contractors; they will have to depend on whoever the contractor can get. At first, there may be an adequate pool of high quality logistics experts to draw from. That may suffice to support the low-intensity actions the forces are engaged in now. What happens, though, if one or two other hot-spots erupt? Contractors may be forced to take on ?go-anywhere, do-anything-for-a-buck? adventurers, mercenaries, misfits, and foreign nationals with less than adequate logistic support qualifications. This is already happening in Iraq with the contract security forces being hired to supplement our troops! Heaven forbid an unexpected high-intensity conflict arises against a major world player! The services would have no time to reconstitute corps logistic support structure or replace lost civilian expertise. Don?t think it can?t happen!!! Recruiting of new replacements may be easier under NSPS, but the knowledge and experience can not be reacquired for some time to come. The organic know-how is often the only expertise available to support systems or sub-systems (based on obsolete technology) that have been in the field for years. With rapid advances in technology, even the original manufacturer(s) may refuse to support systems fielded only a few years ago. If DOD is looking to supplement losses to the civil service corps with contractors, they will do so at great expense. Whatever the cost avoidance in long term benefits to civil servants (retirement, health insurance, etc.) will be more than offset by high contractor charges to support the troops and their sophisticated equipment in a high risk environment. In a prolonged war against one or more large, well-equipped armies, you may not be able to buy contractor support at any price. For this type of high intensity conflict, an integrated imbedded support corps is required within the force itself. This is just the capability DOD is doing away with within the military and intending to replace with continuously deployed civilians and high cost contractors. This is a sure recipe for disaster!!! Even our personnel people (in briefings to management) are telling us this is one of the most ill conceived, poorly planned, rushed endeavors DOD has ever contrived. They admit there are no details available how it is to be implemented. It?s based on a ?trust-me? approach! But where are the job descriptions, list of duties, performance standards, pay bands, etc.? We?re told the pay bands are coming and maybe the other things aren?t needed. You?ll ?just do what your boss tells you?. This may change from day to day, and if not documented, how can anyone know how a person is performing. They also say the employee may have weekly or monthly evaluations and it will be up to the employees to prove they are performing adequately or beyond expectation. WHAT EXPECTATIONS!!! These unknowns, an undefined/shifting compensation plan, and the potential for abuse and cronyism, will be more than enough incentive for many experienced civil service people to leave......and that may be just what DOD wants, so they can shift to an all contractor-support logistics system. A risky and dangerous option!!! Our personnel people also tell us extensive training for all will be needed if NSPS is to work. Also they tell us extensive automation support will be required. Much of this will be via off-the-shelf commercial software adapted to NSPS needs. Given DOD?s less than stellar success in adapting commercial software (SAP, etc.), this is risky at best, disastrous at worst!!! The SECDEF wants NSPS implemented ASAP. Our personnel experts tell us it will take ?yeaaaaaaaarrrs? to implement properly. Or the consequences will be catastrophic!!! The total cost to convert to NSPS is estimated at $850 Million+ (probably very heavy on the plus). Couldn?t DOD fine tune the current system for far less??? The error of NSPS is that it assumes DOD can be run like a business. Our mission is to protect the United States of America at all cost......not at lowest cost! The defense of our country is not cheep......because our freedom is priceless! Yes, prudent, economical use of resources and efficient methods are very important. However, this poorly planned effort to enact so-called ?much needed reforms? is doomed to failure at the very time our troops need stability in the logistics support infrastructure. Our forces are currently stretched to the limit in Iraq, Afghanistan, and around the world. One more crisis hot spot and we?ll be in danger of encouraging potential enemies to strike where and when they know we can?t support a proper response. And right now we?ve already got several lined up to pick a fight with us!!! Within DOD and the existing personnel system we already have the mechanisms to recruit and retain high quality people willing to go to the ?hot spots? and support the troops. For years the Quality Assurance Specialists Ammunition Surveillance (QASAS), Logistics Assistance Representatives (LARs), and similar specialists throughout DOD, have been co-located and deployed with the troops to supplement their ammunition and weapon system logistics support. There is no shortage of high quality candidates applying to train for these positions. Such special programs could easily be expanded to supplement most in-theatre logistic support requirements. We need to fine-tune the current personnel system rather than pitch it for a nebulous plan during a time when we can ill afford instability in the troops? logistic support structure!!! Sincerely,