| Comment Number: | EM-023248 |
| Received: | 3/15/2005 1:44:59 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. I have worked for DoD for more than twenty years. I am incensed that these proposals seem to treat the employees who help defend our country as the enemy, discarding years of dedicated service in favor of who can most effectively suck up to the chain of command at any given time. 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, promoting cronyism and factionalizing the work environment rather than serving the civil concerns of the American people. The proposed rules as published in the Federal Register are filled with nebulous phrases -- "will implement", "will determine", "may establish", "may set", "may issue" -- that demonstrate that what is presented here is _not_ a new pay system, but the outline for implementing a new pay system. DoD employees are being told that they will be converted to this new employment system without knowing what the actual regulations governing their employment will be; we are shown a general outline of a plan whose details depend on future determinations that could be used to implement an employment system ranging from the current civil service system to a dictatorial, crony-ridden regime where even _keeping_ your job, much less receiving raises and promotions, depends on remaining continually sucked up to your supervisors. Until the actual procedures are laid out in detail, describing the actual procedures that will be followed, instead of vague statements that Dod 'will' or 'may' establish these procedures, the NSPS proposal remains too vulnerable to abuse; if we cannot see and evaluate the actual regulations and procedures by which our service will be governed, then I cannot support the adoption of those regulations and procedures. 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, reward short-term outcomes, and encourage supervisors to play their subordinates off against each other rather than managing efficiently. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive, and a highly competent and efficient employee can be denied raises or have their salary reduced for no better reason than that their supervisor doesn't like their attitude, even though their actual work performance exceeds that of all other employees under that supervisor. 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,