| Comment Number: | OL-10502810 |
| Received: | 3/3/2005 2:44:41 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:
There is, however, a significant difference between the skeletal authorities that Congress approved and the sweeping new authorities that Secretary of Defense Donald Rumsfeld is now claiming. During congressional hearings on this issue, the Secretary asserted that the Pentagon's broad mission requires greater flexibility in hiring, disciplining, compensating and assigning civilian personnel. In short, the Secretary wanted the same chain of command authority over civilian personnel as he enjoys over uniformed military personnel. Neither the Secretary nor his subordinates offered any concrete examples to explain how union rights might have impinged on the Pentagon's mission in the past. Although Congress acceded to the broad requests lodged by the DOD, it attached certain strict conditions--including a specific requirements that DOD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. The Pentagon has done neither. Although DOD has convened a dozen or more meetings to brief stakeholders and to solicit the views of unions, there has been no information sharing from DOD and absolutely no response to repeated union requests for specific information as to exactly what problems management wishes to address with the adoption of NSPS. I am certain that one of the Pentagon's objectives in advancing NSPS is to construct a so-called pay for performance system. This is another case of deceptive labeling. Various government agencies have been testing performance pay systems for more than 20 years and invariably, the results have been that the majority of workers feel cheated when advancement, promotion and pay decisions are given over to the sole discretion of a supervisor. The process typically reduces salaries and morale. It is too autocratic and eliminates any redress for decisions made on the basis of considerations other than merit. For these reasons, I oppose the implementation of NSPS and I urge you to act to instruct the Secretary of Defense to halt any further development of NSPS unless and until the Pentagon is willing to substantively address the issues raised by the United DOD Workers Coalition. As a 30-year retired Air Force member and current GS employee I do have significant concerns about the doubts raised by the DoD of my support to the military. I continue to support the USAF as a loyal, dedicated and hard-working civil servant. What ever has been asked of me in the performance of my job I have done without question. Briefings provided to me on pending NSPS implementation have left many more questions than answers. I do find it odd that NSPC is linked to the DoD in its ability to provide national security--from my understanding in working with civilian members during my 30-year active duty career civilians have always been a steady-state cornerstone in providing national security. I believe we still need to have provisions for collective barganing that is afforded to all members of this great nation. I find it shallow that membership in a union or collective barganing somehow is linked as a negative aspect of national security. I am concerned with how my future supervisors will determine my pay as a GS employee. Who will perform as a check and balance to ensure they are not trying to harm any employee with adverse pay decisions made by a bad supervisor? How can we implement a new system in July 2005, when we don't know how it is going to work? Can someone explain to me what pay bands are and how this will effect my pay 1, 5 or 10 years down the road? I am also concerned on how often the DoD/supervisors will need to change or revise performance expectations--will a supervisor change expectations on a whim? I recommend the NSPS be returned back to Congress for re-engineering before it becomes permanent. Thank you for affording me this opportunity to comment!