| Comment Number: | EM-022895 |
| Received: | 3/16/2005 6:25:25 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: 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. I believe the first line of defense concerning our Homeland Security and our national military are DoD employees. Having trained and professional federal DoD employees are critical to our national security. I believe the proposed NSPS will undermine our Civil Service. My objections concern but are not limited to: Subpart C Pay, Sections 9901.301 to 9901.373 The employees in the DoD should continue to receive the same annual pay across the board adjustment that other GS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Mangement, Sections 9901.401 to 9901.409 In order to ensure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. Subpart F Workforce Shaping Sections 9901.6012 to 9901.611 The DoD should not change the current layoff/RIF rules which give balance credit to performance and the employees valuable years committed to service to DoD. Subpart G Adverse Actions, Sections 9901.701-9901.810 Due process and fairness demand that the independent body reviewing a major suspension as termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should contnue to be used. Subpart I Labor-Mangement Relations Sections 9901.901 to 9901.929 The labor mangement law that has governed the employees' right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most f the collective bargaining rights or grievance rights. The DoD should not create a "company dominated dispute board." Any dispute board should be jointly selected by mangement and employee representatives. A strong civil service enables strength for our Homeland. Please do not implement the propsed rules of the NSPS. If it is deemed necessary to implement the proposed rules, please do so with great modification. Respectfully,