| Comment Number: | OL-10503794 |
| Received: | 3/7/2005 3:46:58 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:
This NSPS is wrong to do and this is the wrong time to do it; there is absolutely nothing wrong with the old personnel system. The DOD should put its resources to help fight the war on terror and support our troops abroad and not change a personnel system that is not broken. The millions of dollars and man-hours involved in this unproven personnel system could be better used in other areas to help protect the USA; changing the civilian personnel system is not something that is going to help in the war on terror. The current personnel system and the civilian employees that work under are not a threat to the US security. A threat to our national security is government contractors with employees that have not had background checks and security clearances. The current civilian employees of DOD should continue to receive the same annual pay across-the-board adjustment that other GS/FWS workers receive; the cost of living adjustment (COLA) should never be affected. It is a well-known fact that the cost-of-living is not idle nor is it going down. To have a system that would give a first level supervisor the ability to use favoritism for any public employee position and keep a employee from getting a COLA is absolutely wrong. There should be no agency appointed labor relations board as proposed, the FSIP should continue to handle impasse issues and the FLRA should continue to handle the unfair labor practices; DOD employees should not lose their recognition under chapter 71 of title 5 of the US code. That labor management law that has governed employee’s right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most the collective bargaining right or grievance rights; employee rights should not go backwards. The MSPB should continue to handle adverse action appeals with no changes. There must be third party oversight to protect the interests of the public; such as that already provided by the MSPB. If an agency is found to have committed an error with an adverse action then reasonable attorney fees should be paid to an aggrieved persons attorney along with any other related losses allowed by the current laws. DOD should not change the current RIF rules and procedures that give balanced credit to performance and employees valuable years of committed service to DOD. Employee years of service and seniority should continue to be a determining factor to rank employees for a RIF or any other situation that requires the ranking of employees. It is wrong to remove veterans’ preference in any manner. I write to appose any and all changes proposed, if there is to be any changes it should not affect any of the current DOD employees, it should only affect the new hires that were hired after the implementation date of any new system, like was done when the retirement system changed for civil service employees (CSRS to FERS). The current DOD employees did not accept their respective positions under such circumstances as those proposed in the NSPS. A large group of the current DOD employees are veterans and got out of the service for a life of stability to take care of their family, there should be no reason to deploy a DOD civilian employee that did not accept a position that called for any type of deployment, especially to send a civilian into a hostile or combat area. There is no reason to take away any employees rights under title 5, change their pay system, and take away their rights to a basic COLA and within grade increase(s) unless the respective DOD civilian employee accepted their position under those circumstances. I ask you to do the right thing and withdraw these proposed changes, if changes need to be done, wait until the country is at peace and only change the conditions of employment for new employees, hired after the personnel system is implemented, with the complete understanding of the system in which they are to be hired under.