| Comment Number: | EM-022942 |
| Received: | 3/16/2005 3:35:56 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: BY: Lew S. Jeter The National Security Personnel Systems (NSPS) guidance is so vague whereby it is difficult to respond to. I believe this was done intentionally where things can be added at a later date and it will be too late to respond to these. The NSPS is written for total control by the Department (Secretary of Defense or Department of Army or Department of Defense). NSPS is written to do away with the Federal employees and replace them with contractors. It is also written to do away with Federal Civil Service Unions. NSPS goes back to the ?spoil system? in that everything has the potential to be done by favoritism. This includes performance appraisals, transfers, and reduction-in force (RIF) to name a few. Good Performance Appraisals may be given to the personal favorites of the supervisor in order to protect the individuals in a RIF and to ensure promotion and monetary awards. The open ended ness of NSPS that gives sole discretion to the Secretary of Defense in so many avenues of labor relations, pay, performance, and removal, has taken away the employee?s due process and the effectiveness of Labor Unions. The grievance and appeal routes are all in house with no outside due process. The Secretary has sole discretion in deciding the fate of the Federal worker. This includes disciplinary and adverse actions. With the Agencies having so many reorganizations, the employees can lose money or be RIF?d through no fault of their own. If an employee is transferred voluntarily or involuntarily, he/she may lose money (in a comparable pay band). If the function where the employee is assigned, is not adding to the overall mission, the function is cut off (business base action) and the employee could be RIF?d even though this employee is an excellent employee and has longevity. The plan for NSPS was thought out very thoroughly by the writers. This was why it was added to the end of the Appropriation Bill that Congress passed. In order for Congress to pass the Appropriation Bill, they had to vote yes on NSPS. I do not believe that Congress realized how devastating NSPS would be to the Federal Civil Service Worker, the Federal Labor Unions, and eventually to all Americans. With NSPS, there will be no Federal civil service employees. Eventually, all of the civil service employees will be contracted out. This will affect military installations and the economy of American cities. Contractors can move at will. They don?t have to stay in the same cities as the military installations. Sincerely,