| Comment Number: | OL-10500493 |
| Received: | 2/17/2005 12:50:10 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:
OPERATIONAL REQUIREMENTS .............. Under Agile and Responsive -- How can a Civilian (whose basic premise is Non-military) be considered for deployment, to meet changing mission requirements ? PERFORMANCE MANAGEMENT ............. I don't see a plan to Critique Performance based metrics for their True value-- Would "the numbers" accurately portray efficiency for the sake of metrics efficiency, rather than effectiveness for productivity? It appears that New qualification standards and assignments would be established with NO regard for existing shortages of manpower (retirees, resignees, etc) and Already resultant work overload conditions. Present such a scenario, combined with "intense training" seems unrealistic at best ! LABOR RELATIONS ............. Pertaining to workforce flexibility, but in this section it speaks of "Non-negotiable" management rights - - are we headed for a "Unilateral" agreement ? OTHER REGULATORY PROVISIONS: I notice repeated verbage, i.e., provide "opportunity" for unions to review and comment, to discuss their views, to participate in the process, etc. -- but NO mention of negotiating With unions, toward a mutually beneficial conclusioon - - Not looking for Mary Poppins, but what's happening to fair/two-way bargaining ?? Pertaining to Pay/Compensation it states "May be set and adjusted", based on market factors - - Concerned as to whether or not this Vague verbage would permit decreases, or only increases ?? ***IN SUMMARY: The above comments are being respectfully submitted for close consideration and critiqueing, Prior To finalization of the Proposed National Security Personnel System...................... Thank You