Comment Number: OL-10503161
Received: 3/4/2005 10:08:30 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:

I have several concerns regarding the proposed NSPS guidelines: 1. I am an Air Reserve Technician at an Air Reserve Base. During the week, I am a GS-6 and do not supervise anyone. While in military status, I am an E-7 and supervise three reserve personnel. My CPO could take the stance that since I supervise military personnel, I am not entitled to be a bargaining unit employee. My reservists all work someplace else during the week - the fact that I am their military supervisor two days a month should not exclude me from being able to join a labor organization. This issues needs to be written more clearly or excluded all together since one does not necessarily have anything to do with the other in most reserve units and we should not be penalized for something that is evidently intended for active duty installations. 2. Under the General Schedule, employee pay was clear. It was funded by Congress and could not be taken away. However, NSPS will take away this certainty. Salaries and bonuses are funded by DoD. In the past – as recently as just last year – DoD did not fund its awards program. Given the agency’s miserable record on this issue, how can employees feel confident that our salaries and bonuses will be funded in the future? 3. With the new patronage pay system, which DoD calls “pay for performance,” the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. This system will force workers to compete with one another for pay raises, which will destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. It gives the supervisor too much latitude in the employees future and doesn't provide enough oversight for supervisors' personal discretion. 4. NSPS will allow managers to schedule employees to work without sufficient advance notice of schedule changes. This will make it extremely difficult for working parents to care for their children and family. It will also mean that abusive managers could harass employees with bad schedules or short notice. Overtime rotations can be canceled, which means that employees may not be able to plan adequately for childcare and other important responsibilities. 5. Federal employees could be assigned anywhere in the world, even into a war zone, with little or no notice. I am proud to serve my country but I am also responsible for caring for my family and my personal obligations at home. We signed up for a civilian job. We did not enlist in the military. Today’s volunteer system works well.