| Comment Number: | EM-023101 |
| Received: | 3/15/2005 4:01:27 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 15, 2005 DoD NSPS Comments , DoD NSPS Comments: I write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. This message will be sent to both DoD and my representatives in Congress. With the Department of Defense proposing a drastic overhaul of its personnel system. I am concerned about the Department stripping rights and protections from its employees. But they are doing this at a time when the nation is embroiled in the war on terrorism. it is reported that our troops lack needed equipment such as body armor, armored trucks and armored Humvees yet the Department has decided to spend hundreds of millions of dollars changing its personnel system. I believe the Department will spend more than the $178 million implementing this system. I think the estimate is low and fails to state the cost of establishing new branches within the Department of Defense to handle employee appeals and labor relations issues. Adding these two new branches makes little sense and takes away from the Department?s budget for other priorities. In addition two other agencies already exist for those purposes. The Federal Labor Relations Authority and the Merit Systems Protection Board will continue to operate for the rest of the government. The Defense Department plans to utilize them to some extent but intends to create its own National Security Labor Board. This Board will become its own bureaucracy requiring the hiring of administrative judges, investigators, Lawyers, administrative and computer support, and whatever else it needs to make the Board functional. This is a duplication of effort if ever one existed. The Labor Board will oversee procedures contained in the new personnel system that are more complex than those already in place. The new pay system is also very complicated and will necessitate the hiring of administrators to oversee it. The so called new pay for performance system does nothing more than destroy a simple yet less costly GS pay system that has served the public well. You will get little in return for the money being spent on this massive change. Although the Department has named this new system the National Security Personnel System it has nothing to do with national security. Except that under these new rules the Department has granted itself the authority to deploy civilian workers to combat areas with little notice or their consent. It is something of a draft. We got here because the Congress passed legislation that enabled the Department to make these broad changes. The legislation itself is vague but one thing is clear the Defense Department has made itself judge, jury and executioner over it own system . We are now going to be saddled with an expensive system that is a throw back to the days of political favors and corruption. This waste of resources is not limited to just the Defense Department. Recently the Department of Homeland Security implemented an almost identical system for their employees. The cost to implement the DHS system was estimated to be in the hundreds of millions of dollars. The Department contends it needs these changes to more effectively combat the terror threat to this nation. How can a pay system or an employee appeals system affect the outcome of this war? According to the Administration and the Defense Department we are making great strides if not winning the war on terror. Federal employees have helped achieve any success to date and done so under the existing rules. If there is a case for a change it does not exist on the basis of national security. Sincerely, Sincerely,