Comment Number: EM-023206
Received: 3/16/2005 12:35:37 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: I am believed the proposed National Security Personnel System (NSPS) public noticed on February 14, 2005 in the Federal Register will be counter productive to the mission of the Department of Defense (DoD). I have worked for DoD for 26 years and intend to for another 10 to 12 years in my position as a professional scientist; I can be considered a journeymen level non-supervisory. Nearly every year I have received performance awards and/or been recognized for the accomplishments of the programs I administer. Since the new rewards performance you may expect I would welcome the new NSPS system, but I do not. During my first 12 years I work directly for 2 civilian supervisors in a DoD agency that was predominantly staffed by civilians. In the past 14 years I have worked directly for 9 different supervisors at one installation while I have done the same job. I will focus on this period where I have worked directly for military. All of my supervisors have all been young military officers, usually O-3 rank. These men and women become our middle management, then the best advance to the executive level as our commanders. All these officers are rarely in their position for more than 2 years. In addition to accomplishing my duties I am obviously important for the institutional memory and introducing my direct supervisor to the complexities of my academic specialty and the regulatory requirements to keep our mission on track and out of legal trouble. For most supervisors I and my co-workers are an easy group to supervise, all specialists from different academic and applied areas. We are more of an interdisciplinary team. We are the hard working DoD employees committed to our mission and playing an important role in the development of our supervisor for the next position as they become leaders. I am disappointed by NSPS and urge those in a position to change to include many features of the civil service system in DoD. The NSPS will have me competing against co-workers for raises who are not doing the same work as I. Though almost every officer that has been my supervisors have been excellent and gave us independence, a few tried to be micro-managers of our work. It is my fear they if my co-workers did not have the protection under the civil service system these insecure (immature) supervisors would have fired us or used a reduction in force (RIF) to remove us. Ultimately this would have been at the expense of our unit?s mission and would have penalized their successors. An inexperienced gun hoe younger worker may have been used to replace us who looked like good performer to the micro-manager supervisor, but that inexperienced replacement would lack the ability to integrate the complexities of our respective specialties. The seniority system is a must for most specialties. Though I am not a member I agree with the positions of the American Federation of Government Employees that the NSPS system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. Paraphrasing the union I believe the NSPS rules would create a system in which federal managers will be influenced by favoritism rather than serving the concerns of the American people. I am agreeing the following information available from the union. Under the General Schedule, 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. Last year DoD did not fund its awards program. Given the agency?s record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? 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. 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. 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. Most importantly many civilians are not in the condition of military personnel and could not perform in many deployments. 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. I am providing this message via e-mail to both DoD and my representatives in Congress. Sincerely,