| Comment Number: | EM-023233 |
| Received: | 3/16/2005 12:55:24 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 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. Over the years I have seen managers write position descriptions to fit the profile of a single person; the person they wanted to hire and inevitably did hire. Welcome the ?good old boys club!? 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 Ever here of the 20/80 rule? That is where 20 percent of the people do 80 percent of the work! Imagine, it?s appraisal time again and all your hard work is about to be impartially judged. Or is it? I have seen the worst workers get the best performance ratings and the highest bonuses, while the hard worker who pulls 80 percent of the weight gets the lowest appraisal. In my first years with DOD at McClellan AFB I received my first taste of Supervisory justice. As I sat with my supervisor his exact words were ?you aren?t gong to like this appraisal.? He told me that since I was new I would receive a low rating even though I out produced almost every technician in the shop. Imagine what it will be like with all the stops pulled out! If you aren?t a ?good old boy? and part of the empire of power you will pay dearly for this. I have yet to find a supervisor that hasn?t been able to keep his personal feelings separate from his profession objectives. If you speak up for what is right and just, and it is in conflict with his goals you will not be forgotten. I am currently engaged in issues with my supervisor concerning the job description for our shop. I complete all tasks that are assigned to me but a large number of tasks have conveniently been left out of the job description. I am sure this event will not be forgotten. His actions are a blatant disregard for the system that is currently in place. What will he do when NSPS puts even more power in his hands. Before NSPS was announced I had 2 co-workers willing to sit in on the discussion concerning the issues with our job description. When I was ready to address my supervisor with these outright omissions from the position description the 2 co-workers backed out of the discussions. There reason for withdrawing was ?he (the supervisor) is the one that will be in charge of giving us our raise, and while we agree that you are correct in your pursuit of the truth we cannot stand by you because he will look on this with disfavor and it would jeopardize our raise.? Even before NSPS is implemented there is intimidation. Would you look forward to coming to work knowing that with each day there will be more and more intimidation without any means of recourse? What do they call that kind of a regime? ?A dictatorship?? 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. In the past I have had forced overtime to a point. That point stopped when the boundaries were reached. Boundaries set by law. With NSPS you will remove those boundaries. 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. Layoffs Under NSPS there is no seniority. One of the most valuable commodities in the work force is experience. It cannot be forgotten or underestimated. The worker that has given countless years to his profession has been loyal and devoted to outstanding workmanship safety is suddenly cast to the side. The last time I have heard of that was Nazi Germany when the elderly were euthanized! Pushing the elderly experienced worker to the side is not the answer. Time in grade should mean a secure future for the experienced worker not a handshake and the door. They have given so much and been so loyal, is this how they are to be repaid? 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,