| Comment Number: | EM-023049 |
| Received: | 3/16/2005 7:30:02 AM |
| 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: Comments: If democracy still applies, please review the comments of the people you will be affecting before implementing this new policy. General: I believe the proposed NSPS is not acceptable in its entirety. I feel that it is deceptive and will create more problems than it will solve. When I signed up for active duty, I agreed to forgo certain rights as an American citizen so that all Americans would have rights, including our civilian counterparts. The Civil Service is necessary to continue base operations while we are deployed. They have worked hard for the rights they are employed under and cannot be treated like the military. If we ask them to follow our rules, the majority would probably quit once they realize what they have gotten themselves into. I have sworn to protect this country from enemies foreign and within and this proposal definitely goes against what America stands for. We are not a third world country. Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive unless, of course, inflation doesn?t occur everywhere. 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. It?s an incentive that should not be purely left up to a ?human?s emotion-driven opinion?. If the job requires a certain pay grade or experience, then I don?t want to rely on anything less to prep things I may need in the field. If an employee is not doing the job, the appropriate measures should be taken to remove that employee from their position. Subpart D Performance Management - 9901.401 to 9901.409 The new system is assuming all supervisors are fair and take into consideration an employee?s total performance during an evaluation period. We must keep in mind the ?human? factor, which places more importance on recent events as well as deals with emotions that can hinder judgments. Employees should be able to protect themselves by being allowed to appeal unfair performance ratings to an independent third party, like they can now. The new system would take away the checks and balances of this process and does not hold the supervisors accountable. Subpart F Workforce Shaping - 9901.6012 to 9901.611 DoD puts a lot of emphasis and funding into training their employees to a proficient level. Knowledge and experience is a process. If we start laying-off employees based on their most recent job evaluation (in which several variables could come into play) versus knowledge and experience, we might be left with an ambitious yet inexperienced work force that would cost more money in the long run. Seniority needs to be weighed. Along the same line, if there is no job security for our employees, why should they be loyal to DoD? Once we?ve invested the time and money on an individual, it would be in our best interest to keep that employee on staff. We should not change the current layoff/RIF rules, which give balanced credit to performance and the employees valuable years of committed service to DoD. Subpart G Adverse Actions - 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension or 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 continue to be used. Subpart I Labor-Management Relations - 9901.901 to 9901.929 The labor management 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 of the collective bargaining rights or grievance rights. DoD should not create a ?company dominated dispute board.? Any dispute board must be ?jointly selected? by management and the Union. Even the court system allows a jury to be made up of peers. Sincerely,