| Comment Number: | EM-023212 |
| Received: | 3/15/2005 7:33:32 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: Recently in China I have been conducting research on conserving biological and cultural diversity through free markets. China's economy is rapidly advancing through market reforms, but corruption and inefficiency in governments is a major brake on sustainable growth and social progress. As in too many developing countries, and even in some highly developed industrial nations, govenment work based on patronage and political favoratism retards real economic growth and restricts individual liberty. America's current Cival Service System has evolved through progressive congressional and labor interaction into a merit system that eschews political patronage and personal favoritism. The reforms being propsed for DOD, soon to be exported to other agencies, is a huge step backward, toward the very problems that developing nations are striving to eject. These emerging market economies not only are our trading partners and economic competitors, but they also look toward the U.S. for direction in the world's markets for hope and individual liberty. When America weakens its unique system of checks and balances in search of corporate style efficiency, and compromises collective bargaining in the public sector in pursuit of flexibility, it retreats toward centralized command and control that impairs, not strengenthens long - term national security. America not only forfits its greatest comparative economic and political advantage among nations, but it also obscures the democratic star by which aspiring free societies steer. The proposed NSPS regulations for DOD would 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. Under the existing General Schedule and FWS, employee pay is clear. It is funded by Congress and can 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. Under 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. THE NEW SYSTEM RETREATS FROM MODERN BUSINESS THEORY AND PRACTICE WHERE THE MOST SUCCESSFUL FIRMS MANAGE WITH QUALITY TEAMS, NOT SUPERVISORY DOMINATION AND FAVORITISM. Workers would be 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 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 notices. Overtime rotations could 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. Public employees are proud to serve our country, but they are also responsible for caring for their families and personal obligations. America is at war. We are fighting for democracy abroad. But these regulations are an attack on workers? basic rights, and a regression toward a spoils system for political pyrmids. NSPS would 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,