| Comment Number: | OL-10503092 |
| Received: | 3/4/2005 6:43:43 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:
1st I Would like to say that this is truley un-american, something our forefathers would be ashamed of, boarders on communism. This ideal will reduce creativity and advancement due to the fear of taking calculated risks. This will quickly further injure the recruitment capability of qualified applicants to the DoD workforce and promote the recruitment of non-qualified applicants. The reason being, people in position to hire and fire for the citizens of our country will have the option to hire and promote friends, family v the people who deserve the deed On Page 10 of the Federal Register, in the section entitled “Performance Pay Pools”, it says that the amount of money in the pay pool is based on money that would have been available for within-grade increases, quality step increases, promotions between grades that have been banded in the NSPS pay system, and applicable across-the-board pay increases. The only applicable across-the-board pay increases that employees now receive would be the annual COLA (cost of living adjustment) normally given every January. Since this COLA money is not performance based like the other sources of money, it should not be mixed into the performance pay pool. The net effects of mixing COLA money into the performance pay pool could be devastating to employee morale. NSPS employees who are performing at an acceptable level, even if minimally acceptable, should receive at least the across-the-board pay increase (COLA) that Congress appropriates for all federal employees. This is necessary to counteract normal inflation and cost of living increases in their daily lives (health insurance, auto insurance, taxes, utilities, etc). Otherwise, a satisfactory employee’s pay could be frozen under NSPS, equivalent to a pay cut year after year. What is the purpose of replacing the existing government-wide locality pay system with another type of locality pay called "local market supplement" that is specific only to the DoD? Since no details are provided on this new locality pay system, it appears suspicious. The very short comment period, in and of itself, signifies a serious problem with the intentions of the creators of the proposed NSPS regulations. The NSPS creators have claimed this will be the biggest change in 50 years, affecting 700,000 workers in a critical agency of government, yet only 30 days are given to comment. I will be on travel for a significant portion of these 30 days, as will many other DoD civil servants. There is no nexus between the proposed NSPS system and "national security". The overall tone of the Federal Register document is that DoD is full of poor performing civil servants, and that more methods of punishment are necessary. Note: According to a study by OPM in 1999, their best objective estimate of poor performers in Government was 3.7%. Furthermore, this is an irresponsible use of the term "national security". The Federal Register indicates that a lot of hiring, firing, and salary fluctuation will occur under NSPS, which will create a "revolving door" civil service system that is susceptible to politicization. Furthermore, NSPS presumes that the rank-and-file civil servants and their unions are the root cause of these undocumented performance problems, and that supervisory/management personnel are without fault. The public cannot provide meaningful comments to the NSPS proposal because it is too vague. The NSPS Federal register proposal is full of ideology and devoid of crucial details. The Federal Register proposal appears incomplete, as if it were either rushed by its developers to meet some deadline, or as if its developers have a hidden agenda and purposely are holding back details. These are not proposed regulations but rather philosophies. September 11th, on January 10, 2001. The paper is posted on the Heritage Foundation website. Not only does the Nesterczuk paper provide insight into the ideology behind the proposed NSPS and DHS personn