Comment Number: OL-10501619
Received: 2/27/2005 1:39:38 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:

Comments concerning - Federal Register: February 14, 2005 (Volume 70, Number 29) Proposed Rules: FR Document 05-2582/NSPS (National Security Personnel System) Page 7556: "In April 2004, the PEO developed and implemented a communications strategy. The objectives of DoD's communications strategy are to (1) demonstrate the rationale for and benefits of NSPS; (2) demonstrate openness and transparency in the design and process of converting to NSPS; (3) express DoD's commitment to ensuring NSPS is applied fairly and equitably; and (4) address potential criticism of NSPS." Since NSPS was not released until 14 FEB 2005, how could any information be given? This was an exercise in PR and damage control after Congress reminded SECDEF that PL108-136 must be followed. "The PEO identified channels for disseminating relevant, timely, and consistent information, including a wide variety of print and electronic media, e-mail, town hall meetings, focus groups, speeches, and briefings, and developed an action plan for communicating with each stakeholder. " I am a stakeholder and I was not told anything. Period. Until I read this Federal Register release, I did not know a thing about NSPS. Any claim otherwise is less than the truth. As for consistency, the message was to "sell" NSPS. It was just a PR campaign without substance as there was nothing to tell until the proposed regulations were released. "Outreach to Employee Representatives" " Beginning in the spring of 2004 and continuing over the course of several months, the PEO sponsored a series of meetings with union leadership to discuss design elements of NSPS. Officials from DoD and OPM met throughout the summer and fall with union officials representing many of the DoD civilians who are bargaining unit employees. These sessions provided the opportunity to discuss the design elements, options, and proposals under consideration for NSPS and solicit union feedback. To date, DoD and OPM have conducted 10 joint meetings with officials of the 41 unions that represent DoD employees, including the 9 unions that currently have national consultation rights. These union officials represent some 1,500 separate bargaining units covering about 445,000 employees. These meetings involved as many as 80 union leaders from the national and local level at any one time, and addressed a variety of topics, including: the reasons change is needed and the Department's interests; the results of Department-wide focus group sessions held with a broad cross-section of DoD employees; the proposed NSPS implementation schedule; employee communications; and proposed design options in the areas of labor relations and collective bargaining, adverse actions and appeals, and pay and performance management." Dictation to the unions and other employee representatives as to what NSPS may be is not consultation. In no case did DoD answer questions or be forthcoming in details about NSPS. "Outreach to Employees In keeping with DoD's commitment to provide employees and managers an opportunity to participate in the development of NSPS, the PEO sponsored a number of Focus Group sessions and town hall meetings at various sites across DoD. Focus Group sessions began in mid-July 2004, and continued for approximately 3 weeks. ...." Three weeks to contact and receive input from over 700,000 employees. As for the "Town Hall" meetings, there were by special invitation and with a very short fuse warning. The DoD's commitment to transparency, etc. is an assertion disproved by the unwillingness to release details of NSPS to Congress or anyother group.