| Comment Number: | OL-10503281 |
| Received: | 3/4/2005 3:20:39 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:
Subject: Comments on Proposed NSPS Regulations--RIN 3206-AK76/0790-AH82 General: I believe the proposed NSPS will undermine the Civil Service and damage the mission of the DoD employees. Civil Service rules were designed to avoid the "good old boy" process to this system will likely bring back. This proposed regulation has absolutely nothing to do with the security of the United States of America. Subpard C Pay, Sections 9901.301 to 9901.373 Employees in DoD should continue to receive the same annual pay cost-of-living adjustment that other government workers receive. There should not be separate rules for separate government agencies. The individual pay increases for performance should include guaranteed percentages in the regulations so employees will understand the pay system and what their pay increase will be...depending on their performance. DoD employees are not different than those in any other government agency. Subpart D Performance Management- 9901.401 to 9901.409 To insure fairness and accuracy, DoD employees should be able to appeal any performance rating through an independent grievance and arbitration process as is available now. Subpart F Workforce Shaping- 9901.6012 to 9901.611 DoD should not change the current layoff/RIF rules which give balance credit to prformance and the employees' valuable years of committed service to DoD. Subpart G Adverse Actions- 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension or 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-Managment Relations-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. There is no compelling reason to remove 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 Union.