| Comment Number: | EM-022935 |
| Received: | 3/16/2005 4:02:41 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: Keep the old system but properly administer it. SECT. 9901.101(b ) 2. Correct the failure of management to correctly manage the current pay system, which allow for compensation to be linked to performance. SECT. 9901.103. 3. If management would correctly apply existing provisions now in place there would be no need to apply a new process to correct thes problem. SECT.9901.101(b). 4.NSPS is using the guise of national security to change current law relating to pay raises for federal employeea. SECT.9901.917a 5. National Security should not be used as justification to vastly modify the existing federal labor laws which protect the rights of federal workers.SECT.9901.101 5.The NSPS proposal would allow supervisors to give raises to favorite employees whether they deserved them or not. SECT. 9901.212(c) 6. Using my own personal experience with supervisors it will take tight internal controls and oversight to insure that they do not use the new pay system to reward their friends. Awards are handled in this manner and if pay banding is allowed, wages will be controlled in the same manner. SECT.9901.212(d) 7. I don't see how national security requires our current system of pay raises to be tampered with. NSPS would allow pay banding. No justified reason has been given to explain why the current system is not working, except grossly misleading statements. SECT. 9901.212(a) 8.The civil service act of 1978 mandated the establishment of performance standards and the periodic evaluation of performance. If NSPS is now proposing that this process needs to be changed, what evidence do they have that the current system, if used correctly, is not up to the task of providing for proper performance evaluations?SECT,9901.342(a) 9.I understand that the NSPS proposal will not include any union representatives in a newly created Nationsl Security Relations Board.SECT.9901.907 10. I don't like the idea of DoD removing the union's institutional right to be present during EEO proceedings.SECT. 9901.914(b) 11. I understand that the intent of Congress to allow for meaningful discussions concerning the development of the NSPS has not been followed and rather DoD is attempting to put NSPS in place without these discussions. SECT.9901.101(a) 12.The current civil service system has been used in all of the wars dating back to WWII. What is different about the current war that precludes continuing to use civil service? Is civil service broken, and if so why did it work so well for so many years? SECT 9901.101(a) 13.I have beren told that DoD wants to reduce or eliminate the collective bargaining rights of the union. If NSPS will in fact do this, then I strongly object to using the excuse of fighting terrorism to limit my union's bargaining rights.SECT. 9901.917(a). 14. DoD seems to feel that they are forced to use military personnel or contractors when federal civilian employees would be more appropreate. Because of thisDoD feels that NSPS will provide relief. Mismanagement of personnel by supervision and management should not be the reason to create NSPS and effectively eliminate the protections afforded under civil serviceSECT.9901.513 17.Just as the current administration was unable to find any weapons of mass destruction . Sincerely,