Comment Number: OL-10501113
Received: 2/23/2005 4:02:53 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:

1. Within the paragraphs "The Case for Action", at one point reference is made to "low performers" yet at another reference is made to DoD civilian "professionalism and dedication". Which are we? Does higher authority view DoD civilians as just a necessary evil to be dealt with, or are we viewed as a reliable asset that should be protected? The double-speak is not appreciated. 2. Within the paragraphs "The Case for Action", the overview of salaries is interested and disconcerting. The US Gov't is always trying to save money. The NSPS is an obvious attempt to save taxpayer dollars. When dealing with DoD civilians, there are only two ways to save money - reduce staff or reduce pay. The goal is either to get rid of people or pay them less - or both. Why isn't this made explicit? 3. Within the paragraphs "Relationship to the Department of Homeland Security", it is amazing that the experiences of a short, two-year period from a brand new organization are being considered comparable to the well-established DoD organization. That seems like a poor data set from which to draw conclusions. 4. Under Subpart C (Pay & Pay Admin), the statement is made that the money within a pay pool will be the money for within-grade increases, quality step increases, promotions, across-the-board pay raises, performance and incentive awards. Since the new system purports to allow the DoD to compete for people in the market place, why aren't the dollars assocated with "pay comparability" also part of the pay pool? Year after year, calculations reveal that the DoD personnel are paid less than their private-sector counterparts. Yet, President after President has found pretext for ignoring the comparability so the gap widens. If the NSPS wants to truly compete for people, shouldn't the "pay comparabilty" dollars also be part of the pay pool? 5. Under Subpart D, the statement is made (and later reinforced in Subpart F) that "One of the main objectives of the pay-for-performance system is to replace the culture of pay-for-longevity with pay-for-results-driven performance." Where is the new system's recognition of the employees who have sacrificed much for their country? The NSPS seems to be asking, "what have you done for me, lately?" Why does the NSPS want to ignore longevity? 6. On page 7555 (Process - Working Groups), a list of the participants in the working groups is given. Why weren't rank-and-file DoD civilians included rather than just DoD managers? 7. On page 7573 (EO 12866 - Regulatory Review) that statement is made that the "costs and benefits of the proposed HR system...is presented below." The costs are estimated and quantified. Why aren't the benefits quantified? Is the assumption being made that the benefits exceed the costs? Where is the analysis? Where is the proof? 8. Overall, a search of the document never reveals the use of the word "compassion" once. Shouldn't that be part of any HR system? 9. Overall, this system gives more authority to supervisors without a commensurate off-set. Private sector systems that are patterned like this have the counter-balance that the employees may organize and go on strike. DoD employees have no such counter-balance, so where are the protections against supervisors who use the system to reward their friends and/or abuse their enemies - both without merit?