| Comment Number: | EM-023202 |
| Received: | 3/15/2005 9:03:44 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 am writing to discuss my concerns about the National Security Personnel System (NSPS). I am very much opposed to the system and I am curious as to why and how it is being implemented. I have thoroughly read the NSPS Proposal on the Federal Register and took diligent notes so I could address my comments as requested. Due to the repetition of my concerns and after typing my sixth page I chose to shorten my comments without making specific references to subpart or page number. My comments refer to the entire document. I believe it will be detrimental to implement the system as it stands now. It is an extremely idealistic proposal and would only function as intended under perfect conditions. It sounds wonderful on paper, highly admirable and respectable in its aspirations for a supreme workforce. But that is not the situation the DoD is currently in. No, the current DoD system is not perfect, but this NSPS proposal is not the answer. The implementation of this system now, with so many procedures forthcoming, is dangerous and reckless. The proposal itself is totally neglectful of the very people it is supposed to benefit and motivate. There is neither protection nor viable recourse for the employee. The procedures rely on a totally autocratic system and the unions would be rendered ineffective. I understand that unions are sometimes cumbersome and occasionally abusive. But lets face it; management can be so as well. It appears to me there is a new branch of military is being constructed using a preexisting workforce. The problem is we were hired, we did not enlist. I do not believe this was the intent of the Defense Authorization Act. I understand the need for a highly flexible workforce to support the military. That workforce is the support elements in place within the military, not civilian personnel. I believe the purpose of the civilian workforce within the DoD is to provide continuity and support to our military counterparts in the capacity we were hired under. Not to be deployed or reassigned to meet the needs of the military or the whim of management. These are some of the reasons I left the military over two years ago. The Pay-for-Performance and Performance Management proposals would function well dealing with highly knowledgeable and honorable professionals in managerial positions. Drawing on my own experience not all managers? posses these qualities. What is the motivation for them to act admirably? What are the consequences if they do not? The managers I work for do not understand the purpose or function of my job, nor do they possess the desire to understand it. It frightens me to think that I will have to depend on them for my livelihood. My peers and I are understaffed, underpaid and continually told to break federal regulations to accomplish their agenda. Our management believes we are overstaffed, overpaid and do not like being informed of regulations we are required to work under. Our pay would be based solely on management?s biased and ignorant opinion. Additionally, my profession now is receiving Premium pay, Sunday premium pay, Nighttime differential, and Overtime pay, this accounts for approximately 20% of our pay. With the new NSPS system we would no longer be receiving any of this pay. So much for our pay not being impacted, ?to the maximum extent possible,? for the first few years of implementation. Most of the DoD civilian employees are former military, and I do believe we are the right people for the job. We have an intricate knowledge of the workings and needs of the military and possess the ability to meet those needs. We have chosen the civilian sector of the DoD as a career for various reasons. With NSPS our future will be uncertain and undependable. This does not seem to me to be what was intended for the future of the civilian workforce within the DoD, and is defiantly not why I chose to leave the military. For these reasons, I oppose the implementation of NSPS and I urge you to act to instruct the Secretary of Defense to halt any further development of NSPS unless and until the Pentagon is willing to substantively address the issues raised by the United DOD Workers Coalition. 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. I have worked for DoD for years. I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed. I believe that mistreating the employees will hurt the agency?s mission. I am very upset by NSPS. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which federal managers are influenced by favoritism rather than serving the civil concerns of the American people. Annual Pay Raises Under the General Schedule and FWS, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past ? as recently as just last year ? DoD did not fund its awards program. Given the agency?s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? ?Friend of the Supervisor? Pay System With the new patronage pay system, which DoD calls ?pay for performance,? the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Schedules and Overtime NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. Civilian Deployment Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today?s volunteer system works well. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers? basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers? welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely,