Comment Number: OL-10502223
Received: 3/1/2005 12:05:42 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:

General: I believe the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD employees, their morals, and also will hurt the local economy. Subpart C Pay, Sections 9901.301 to 9901.373: The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other GS/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 increase will be depending on their performance. Subpart D Performance Management Sections 9901.401 to 9901.409: In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an impendent grievance and arbitration process like they can do now. Subpart F Workforce Shaping Sections 9901.6012 to 9901.611: DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. Subpart G Adverse Actions Sections 9901.701 to 9901.810: Due process and fairness demand that the independent body reviewing a major suspension as 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 Sections 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. Michael Putnam