| Comment Number: | EM-022994 |
| Received: | 3/16/2005 1:42:20 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: General: As an AFGE local situated at Selfridge ANGB Mi. certified in 1963 we find the proposed new regulationsto be a slap in the face of all Unions, and in particular all of the fully dedicated employees that we represent. To be called by the Secretary of Defense a security risk is unimaginable and absurd. Most of our members are Veterans from back as far as the second world war, Korea, Vietnam, and both Gulf wars and have dedicated themselves to the defense of this country. Not only through their military service, but also in their civilian work capacities. Most of our employees dedication and loyalty to the country will NEVER be matched by the contract employees that this new system will attract. This new system was NOT developed as provided for in the law that allowed it, by not collaborating with the DOD Unions that were to be an equitable partner in the design process. Subpart B/C: You will be creating a spoils system of pay that will rob the country of the loyalty that it has enjoyed by having employees loyalties change to their individual gain, or worse yet, only loyal to the supervisor who rates them and designates whether they will get a raise each year. By allowing a supervisor complete control with no challengeable aspects to his determination of an employees rating and raises each year will decimate the morale of all and do the exact opposite of the desired outcome that this regulation is supposed to have. Subpart D: Again we are setting this system up to fail before it gets a chance. By retaining the same supervisors that could not administer the current system fairly and equitably we are now going to require that they be given a couple of hours of cursory training and sent back out to try and learn for themselves the new system that is much more elaborate. In the past, we have been to challenge the ratings of a bad supervisor to make sure they are doing things according to the law. Now with the new system you are saying we no longer can hold bad management accountable for their actions. (How ridiculous). In any fair and equitable system there is a mechanism to hold people accountable to the agency as well as the employees that they supervise. Subpart E: Why could the DOD not correct the bad system they claim they have now? Because we still have the same people not doing the proper paperwork to make it work. And we will have these same people screwing up the new system because of being too lazy or untrained to do the job properly. All we are doing here is creating a system where no-one will be held accountable for their actions. Why would we go to a system that assigns probationary terms at different lengths for all? Because then when a supervisor screws up the paperwork to get rid of bad probationary employees in a timely fashion, now they will be able to come back with impunity and fire them at some later date without answering to anyone. Subpart F: Job security has always been a cornerstone to keeping a well trained and efficient workforce. If you now start retaining people solely on their latest rating of record instead of fair and equitable use of longevity and veterans preference. Subpart G: Creation of some new system of MRO's without even outlining them here is ridiculous, and at best disengenuous on DOD's part. And not allowing a person due process by the possibility of not allowing them a representative at these meetings is insane. Wall mart has a better system of adjudicating disputes than this affords Federal Employees. For the agency to be allowed to say whether a representative of the employees choosing can be their representative is ludicrous. Subpart H: To allow the agency to overturn a MSPB decision is (an independent authority) is completely out of the realm of common fairness. Subpart L: Overriding current negotiated labor agreements with new laws rules or regulations without negotiation is only one thing. UNION BUSTING, to the point of being open and blatant and usurping the time honored and respected tradition of legal negotiations. To exclude more and more provisions from bargaining is the same as above. Plus taking away the rights of employees to have Unions looking after their good and welfare flies in the face of the American way of life.Taking away the rights of employees during examinations will only serve to put more fear into employees and thereby weakening the rock solid workforce we have today. Creation of a NSLRB in concept could be an ok thing, if the people were jointly appointed by management and the Union. But to have them totally appointed by the Secretary of Defense will NEVER be seen as fair and impartial. Which is exactly what I see as the point of the secretary's demand that he solely be the appointing authority. In summation, this is a useless and conceptually flawed design for a new system that is doomed to oblivion when the same supervisors are charged with the implementation of the new program that could not administer an easier and just as capable system that is now in place. With only one minor change, NOW THERE WILL BE NO ACCOUNTABILITY FOR ANY ACTIONS TAKEN AGAINST ANY EMPLOYEE AT ANY TIME. Maybe we should just throw out the new system and think about the quality of the supervision that we hire to administer our programs. Thereby saving the American taxpayer the billions of dollars to implement a system that is not needed and is by design doomed to failure. Sincerely, AFGE Local 2077