Comment Number: OL-10501637
Received: 2/27/2005 1:59:24 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 7574: "The marginal cost of the accelerated payment of earned WGIs is difficult to estimate, but is not a significant factor in the benefit cost analysis for regulatory review purposes." Since there are over 700,000 DoD employees and the cost of a single WGI will be roughly $1500, the cost of this will run over $1billion. If that is not significant, please tell us what is. "DoD estimates the overall costs associated with implementing the new DoD HR system--including the development and implementation of a new human resources management system and the creation of the NSLRB-- will be approximately $158M through FY 2008. Less than $100 million will be spent in any 12-month period." Yes of course this will be the real price tag for NSPS. See above and remember the Medicare Rx estimates from the same administration. "The primary benefit to the public of this new system resides in the HR flexibilities that will enable DoD to attract, build, and retain a high-performing workforce focused on effective and efficient mission accomplishment. A performance-based pay system that rewards excellent performance will result in a more qualified and proficient workforce and will generate a greater return on investment in terms of productivity and effectiveness." Do not punish employees for DoD managements' problem. The claim to possess a high-performing workforce will solve the problem is nothing more than rubbish. The workforce will be useless because management can not or will not provide nor communicate a clear direction or plan of action it wishes to seek to its employees. Were DoD management to get its collective act together, this farce would not be necessary. If you think this arguement is not true, you need only to look at the motivations claimed for the war in Iraq. If DoD management can not tell the truth on something so basic and important, what makes you think they will do right by its civilian employees? Or do you think DoD management will treat its civilian employees any better that wounded Guard troops taken off active duty with loss of pay, housing, and oh yes, hospitalization benefits. Lastly, DoD management has to pay this high-performing workforce (see above for the partial costs of NSPS). "It is also expected that new flexibilities and improved processes in labor management relations, adverse actions, and appeals will result in more efficient and faster resolution of workplace and labor disputes, timelier and less costly bargaining processes, and quicker implementation of workplace changes needed to carry out the national security mission of the Department, while preserving basic employee rights." These assertions only mask that there is an equitable system. The claim to faster resolution of disputes, etc. is however true because there is no appeal from management decrees by fiat. "DoD and OPM have determined that these regulations would not have a significant economic impact on a substantial number of small entities because they would apply only to Federal agencies and employees." There will be a tremendous economic impact. Running and maintaining the DoD civilian workforce. The complaint that this costs too much will be replaced with the call for contracting out these function which will cost many times more because of poorly written contracts, the lack of competition, and no oversight by DoD for the civilian functions. "This proposed regulation is consistent with the requirements of E.O. 12988. The regulation clearly specifies the effects on existing Federal law or regulation; provides clear legal standards; has no retroactive effects; specifies procedures for administrative and court actions; defines key terms; and is drafted clearl