| Comment Number: | OL-10502701 |
| Received: | 3/2/2005 4:15:20 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:
Ref 5CFR Ch XCIX and part 9901. I have 26 yrs of federal service; 8yrs Active Duty AF, 16 yrs as a GS 13/LtCol Air Reserve Technician (ART), 2 yrs civil service at a Command HQ. NSPS is a bad idea. It’s founded on the assumption that all DOD sectors need to be shaped like Homeland Defense. False. That is a weak rationalization used by senior management to radically change civil service. Also, consider this; NSPS is a top down initiative, when is the last time you saw any top down initiative that worked? No one asked for a radical overhaul of civil service, nor is it necessary. CS evolved into what it is today for very good reasons, don’t ignore them. Please consider the following; 1. The vast majority of DOD civilians have no direct connection to national security, yet 911 events and Homeland Defense structure are being used as rational to overhaul the entire civil service system. Bad reason, please don’t do it. Homeland defense needed quick hiring and classification, and procedures are currently in place for both. 2. NSPS puts too much power in the hands of the supervisor. CS is not a Fortune 500 company and managing in the manner suggested will hurt morale and decrease long term commitment. Young employees will not look forward to a career under these rules. 3. Tenure and time in grade is important, but NSPS de-emphasizes both and puts the employees pay and job security at the mercy of a supervisors subjectivity. Most CS supervisors will not be able to manage the power inherent in NSPS. 4. Given 2 above, NSPS creates a system that thrives on patronage and relationships instead of performance, and it ties pay and job security to both. Bad idea. Sounds like the 1930's. 5. The proposal lacks checks and balances that insure tenure and time in grade are protected. Young employees will have less incentive to remain in CS under NSPS. The benefits of time in grade and tenure are long proven in most occupations, CS is no exception. 6. Typically the civilian pay budget at each organization is capped as is the number of billets allocated. We constantly live on both caps. Once the budget is expended, how will pay raises be given? How can individual performance be rewarded by moving to the next band when the dollar limit for civilian salaries at that location has been reached? Are COLAs going to continue? 7. The two reasons I am civil service are job security and retirement security. I had the opportunity to go to the private sector to make more money, but that is not as important as job security and retirement. NSPS removes job security and lessens the probability of reaching retirement. Recommendation: Change the culture of the present system slowly but predictably through a series of phased in improvements. Preserve the importance of time in grade and objective performance appraisals that require a second endorsement prior to approval. I am a consistent producer with very high performance ratings, but I consider NSPS a threat to my job security. Please reconsider.