| Comment Number: | EM-022922 |
| Received: | 3/16/2005 4:47:15 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:
Mr. Bunn, The DOD proposed NSPS has already had and in the future will continue to have a demoralizing effect on the workforce. Some representative of DoD reported that 1000's of NSPS commenters are anonymous. Why? Because they are afraid and believe me they have something to fear under this system. You have basically decided to cut out meaningful input from your workers by diminishing their protections and you might wonder why you get anonymous responses to something like this. Using the fear, you suggest because of terrorism our workplace needs to become a national security issue. All the while you DoD puts forth an NSPS that will operate basically by keeping employees fearful of what management might do to them. Pay: Congress and the President in the past worked out the federal salaries. However, NSPS will take that away. Salaries and bonuses are to be a part of DoD's budget. 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? Section 9901.313 for compatibility you say nothing but at a minimum you have to allow for step increases and rates of promotion. Here and later in 9901.3_ _ I don't see where there is any commitment to a yearly evaluation for adjustment of pay bands. It is discretionally. So how do we not loose out as employees on what would have been the yearly pay raise portion that was not locality pay. We should get factored in for comparability anything that the military gets for an annual raise plus all that you indicated for step increases and rates of promotion. Section 9901.342 Since union full time positions do not get a rating under this system they should get the average increase or raise of those at their grade or band where they are permanently assigned. DoD will determine when there will be an increase in basic pay. Will there ever be one. I DoD contemplating more than annual? I think not. Are they contemplating less than annual? Maybe it will cut costs and pay people less. Section 9901.401 If DoD's strategic plan is to do more for less then NSPS will help. DoD doesn't have to do yearly raises (its their discretion) and they don't have to do yearly local market adjustments (its their discretion) and they don't have to use experts at Dept of Labor or elsewhere to determine the amounts they pay they do so that themselves. They certainly should be able to reach a strategic goal of more for less. However, how are they going to check the costs of contractors? Ban any dealings with contractors that have unions as there may be a national security issue? Will that do it? In short I object to this control by DoD and there should be mandatory yearly evaluations for pay raises and market supplements and an already existing department of government should calculate the amounts they should be. Section 9901.405 Generally once a year performance reviews proposed in NSPS falls in line with discretionary timing of raises in NSPS. I object to this as it seems to say no performance appraisal- no raise. If you are out of sequence it may be awhile before you ever do get consideration for a raise. DoD can't make its management get performance appraisals done yearly now, granted there is reason for a few exceptions. This is wrong what has DoD done about it. The focus here should be on management doing its job.