Comment Number: OL-10501237
Received: 2/24/2005 11:44:56 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:

Bargaining: Collective bargaining is the cornerstone of the United States. The Jamestown Pact, the declaration of Independence and The Constitution are all collective bargaining agreements. DoD has never suffered a loss of mission accomplishment due to union bargaining. You currently have the ability to implement mission demands and do post implementing bargaining. Unions are not opposed with national level bargaining but must have installation level bargaining to address local concerns. Four tiers of bargaining at the following levels, each bargaining only on that matter specific to that level of concerns. DoD, agency, command and installation levels. This permits the appropriate control at the appropriate level, addresses the unique concerns at each level and allows your most valuable assets, the employees, to have some legitmate avenue of input. i.e., DEFAS would have DoD agency and installation level because they cover all commands in all agencies while Navy would have all fourbecause Naval commands are varied and numerous. i.e. NAVSEA, CICLANT, CICPAC, NACAIR, ect. Classification: Current position descriptions are designed to outline the qualifications and skills required to perform those duties. How can you generalize the skills for a tank mechanic, airframe mechanic, fire control technician or nuclear power plant refueling technician. The pursit of liberalized job assignment is already available. I have yet see a position description that does not include the phrase and other duties as assigned. How much more flexibility do you need? Defined classifications ensure qualified personnel are performing the required duties. Hiring: The only impediments to hiring are due to suitability and security investigations. Are you inferring that we reduce security investigations? You indicate that "market-sensitive compenstaion" will be used to set pay and attract new employees. You already ignore the current systems (GS locality and WG wage surveys) and refuse to honor congressional direction and fully fund the difference between private and public sector pay. Pay: The only reason poor performers receive the same pay is poor supervisors and manages. The current system addresses this problem but if the supervisors/managers do not apply it properly it will not work. Despite your assertion that objective criteria will be applied it wll not happen because objective criteria already exists and it's not being used. Nothing will change except the suffering of the employees will increase. Government wide pay set by this program is below the civilian market rates. If you are ignoring this now why should we believe you will honor the same program under a new name. Basing pay on assignments provides employeeson high visibility task greater recognition than those on lesser tasks even when they are high-level performers. There are currently several ways to reward employees. Special act or achievement awards, on the spot awarsds, group achievement awards and quality step increases. The only bar to receiving one of the above is poor performing supervisors/managers. There are currently several ways to deal with poor performers. Poor performance ratings automatically trigger improvement programs, time off, reduction in step and/or grade and termination. Veterans' Preference: You indicated in several places that veterans' preference would not be changed.However in RIF(you specifcally indicated no change here) veterans' pereference is changed from a vet gets preference so they only get it within the performance-rating group they are place. i.e., When a vet with 30 years of service, 28 of those years they received the highest rating, the last two years they received the second highest rating and new employee with two years of service and two highest level rating are in a RIF the vet loses their job! General Comments: There is nothing wrong with the current system other than mismanagement. Minorities will suffer.