| Comment Number: | EM-023285 |
| Received: | 3/16/2005 12:07:40 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 writing 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 25 years. I am disgusted with these proposals, which seeks to treat the civilian employees who help defend our country, as if we were lazy, undependable, and generally of little value. Most DoD employees work hard and are committed. I know that mistreating employees can only hurt the agency?s mission. I have considerable direct personal experience about prohibited personnel actions, because of my having been victimized by management. 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. There is already too much subjective input about those categories, and providing management with dictatorial powers, can only aggravate the labor-unfriendly system, which already exists. 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. And, during some years when funding was available, rewards were not distributed in a equitable manner. Given the agency?s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be fairly distributed or even properly 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. I have personally been subjected to intimidation and retaliation, and that was when some protection was available, through Civil Service. Under the NSPS system, there will be no impartial appeal system to assure that everyone is treated fairly, and no protections against intimidation and retaliation. 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. I signed up for a civilian job. I have already served in the military, and now my local commitments will not allow me to just drop everything and go somewhere else, on short notice. Today?s volunteer system works well, and I can see no advantage to giving management a blanket tool, to intimidate and retaliate against the workforce. 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, respect's the rights of Defense Department workers, and provides some protecton against managerial abuse. Sincerely,