| Comment Number: | OL-10501622 |
| Received: | 2/27/2005 1:43:08 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 7559: "The new classification system for DoD will result in a streamlined method of classifying positions that no longer relies on lengthy classification standards and position descriptions. The new system does not require artificial distinctions between closely related levels of work, as currently required under the GS and Federal Wage System (FWS) classification systems." The reason there are distinctions between closely related levels of work is detailed below. I am a Physical Scientist with a master's degree in Marine Geology. I have worked in my field to increase my understanding for over twenty (20) years. My specialty is making charts of the ocean floor, or in other words, bathymetry. I am not a hydrographer, nor a geophysicist, nor an oceanographer, all of which are closely allied fields. But, within these proposed regulations, I can be detailed job duties where I have little or no expertise. "The system described here, together with the new pay system described below, will provide DoD with greater flexibility to adapt the Department's job and pay structure to meet present and future mission requirements." These provisions will limit employees' high end pay, even for higher than excellent performance. Furthermore, in private industry, an employee is given as much responsibility as possible and is rewarded for performance. In DoD, there are technical GS-13s, -14s, and -15s, that is non-managerial or -supervisory higher graded employees. They are there to provide management with technical expertise that would not otherwise be available. Under the proposed pay-banding system of NSPS, these positions could not exist. How does DoD propose to reward the very highest level performers, such as these people? "This subpart contains proposed regulations establishing pay structures and pay administration rules for covered DoD employees to replace the pay structures and pay administration rules established under 5 U.S.C. chapter 53 and 5 U.S.C. chapter 55, subchapter V. This new system links pay to employees' performance ratings and is designed to promote a high-performance culture within DoD." This is designed to limit transparency as it concerns employees' pay. Presently, one can see if another employee is paid the same for the same work. Under NSPS, there is no longer this transparancy which is an opportunity of cronyism and other forms of corruption. "In accordance with the NSPS law, to the maximum extent practicable, ...." These are waffle words. This implies, "Maybe we'll do it or maybe we won't." Management has an obligation to say what is going to do. Is this the vaunted transpancy so widely promoted in NSPS?