| Comment Number: | EM-023255 |
| Received: | 3/16/2005 9:53:50 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 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 sadden that the DOD employee is being treated as a terrorist organization.Since the National Defense Authorization Act(Pub. l. 108-136) (NDAA) was tied in with the Defense appropriations bill that was passed by congress in Nov. of 2004. An incomplete and very vague portion of the nsps is posted to the federal register for a thirty(30) day comment period, the only comment period allowed on this proposed system . Since when did the average worker for DOD become such a security risk. We have proven over may years to be up to whatever came our way. NSPS will not make managers more accountable. At least nothing in the proposal gives any assurance other than the claim that they will, and takes the laws concerning nepotism, favortism, The old boy network and the political spoils system all back into the realm of legalism. All with out anyone outside the DOD to answer to. As early as the second page of the document under "The Case In Action" it is stated that the present system has prevented managers from using civilian employees effectively. Military is using military personnel or contractors where civilians could be used. Case in point there are civilians in my area right now that have been turned down for deployment (these people volunteered to go and they were not allowed to).We also have returning tradesmen that had been over there getting the job done and they have been replaced by contractors. As a homeowner I would not have been able to go into court with the elements that appear under "Workforce Shaping-Subpart F" - 2. "Mandatory removal Offenses"- I quote- DoD has not yet identified a propsed list of such offenses.However, it is important to preserve the Secretary's flexibility to carefully and narrowly determine the offenses that will fall into this category and to make changes over time. " The Mandatory Removal Offenses(MRO) are so vague. We already have the Table of Penalties which is used to decide the type and duration of punishment. 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,