Comment Number: OL-10500290
Received: 2/16/2005 9:19:31 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:

I read all pages of the proposal. It cannot be addressed solely by specific reference to appropriate sections. My comments should nonetheless be accepted for review. 1. This is another example of the Bush-Rumsfeld "rush to war" syndrome. How can a 1 year study come up with a detailed plan to replace a 50 yr. old system? There is no evidence the current system is inferior to the proposed, or puts the nation at "risk" in terms of supporting national security. (Summary section: "The Case for Action") 2. There is much rhetoric and fluff in the proposal and very little substance. Substance is buried in the creation of future "DoD issuances" as stated throughout the document. 3. The system will be no better than the one it will replace, but may be worse: a. Supervisor "favorites (i.e., not necessarily outstanding performers) will win out. b. Rivalries will be created, potentially to the detriment of mission and morale. c. Position descriptions will be too loosely and too briefly defined. d. Performance criteria will not be better defined, just differently defined. e. People doing equal work within the same command should have the same performance criteria, but will they? f. Military supervisors are the worst supervisors because they come in for a couple of years, don't know about the system, don't care about it, and do whatever they want to do that won't rock the boat on their watch. Education will not correct this. And besides, education will have to be continual. g. Supervisors themselves differ from strong and aggressive to meek & conservative. 4. The current system has the ability to achieve much of what NSPS purports to deliver. Promotions and step increases are not automatic; they require approval by a supervisor and/or management. Performance appraisals are required. 5. NSPS will be totally subjective, and that will be cause for inequity throughout. At least the current system is both objective and subjective. 6. How will the pools be established & managed, and how will they be equitably applied to activities within the same local market? Will my activity unwisely apply their budget, and employees get short-changed, while an activity across the street manages their budget very wisely, and employees get well-compensated? 7. How is the system monitored, and who will have access to the monitoring results? All civilians should. 8. Every activity, no, all of DoD, should be required to publicly disclose any and all compensation increases to its personnel. Give civilians an opportunity to see what is going on right underneath their noses, and don't give management a chance to disguise the goings on. 9. The NSPS proposal comes across as very unsupportive of civilian personnel. We do not want to be equal to contractors. AND WE DON'T WANT TO BE REPLACED BY CONTRACTORS --- ANOTHER BUSH-RUMSFELD GOAL. (Pay contractors big dollars; force civil servants out --- and, oh, by the way, there's little monitoring of the dollars spent on contractors.) 10. The NSPS proposal is very clearly unsupportive of unions and bargaining. 11. Pay bands exist in the current system. Going to 3 or 4 pay bands to cover everyone is not a better system. 12. NSPS pay structure is built to stifle incentive because the same people will be getting the big dollars all the time. Other acceptable performers will give little more than an 8-hour day. 13. The creation and administration of many local market supplements will be a bureaucratic nightmare and require a whole new organization to wrap its arms around it. 14. Overcoming cultural change is hard enough, but NSPS represents unspecified culture shock. It will take years to adjust to this system (and years to get the kinks out and issued as "issuances"). It will be a nightmare for all. 15. Better off to adjust the current system, 16. 4000 characters not enough. TheEnd