| Comment Number: | OL-10501879 |
| Received: | 2/28/2005 11:21:22 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:
Program Executive Office National Security Personnel System Attn: Bradley B. Bunn Mr. Bunn I believe that the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD and its employees. Subpart C Pay, Sections 9901.301 to 9901373 The employees in DoD should continue to receive the same annual pay across the board adjustment that other GA/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increases will be, depending on their performance. Subpart D Performance Management 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating through an independent grievance and arbitration process like they can do now. Subpart F Workforce Shaping 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give balance credit to performance and the valuable years of committed service to DoD. Veterans Preference should not be changed. Subpart G Adverse Actions 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension or termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor Management Relations 9901.901 to 9901.929 The labor management law that has governed the employees’ right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a “company dominated dispute board.’ Any dispute board must be “jointly selected” by management and the union. Sincerely, Wayne Isham