Comment Number: OL-10503765
Received: 3/7/2005 2:52:20 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:

Subpart C Pay, Sections 9901.301 to 9901.373 Defense Dept. employees should continue to receive the same annual pay and across-the-board adjustment that other GS/FWS workers receive. The individual pay increases for performance in the regulations should include guaranteed percentages so employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Management - 9901.401 to 9901-409 To ensure fairness and accuracy, Defense Dept. employees should be able to appeal any performance rating to an independent grievance and arbitration process as they can do now. Subpart E Staffing and Employment - 9901.501 - 9901.516 The proposed regulations would replace longstanding provisions on hiring found in 5 U.S.C. Chapters 31 and 33 with unpublished prodedures that will be prescribed at some future date through implementing issuances. Using this approach will allow the Defense Dept. to arbitrarily develop and administer new rules on staffing and employment that have not been available for public comment. this is especially troubling, given the proposal to engate in non-citizen hiring to positions within NSPS. Our national security would surely be put at risk if Defense Dept. manager were able to exercise such hiring flexibilities.