| Comment Number: | OL-10504062 |
| Received: | 3/8/2005 11:18:45 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:
The information provided in the FR provides little in way of "new" flexibility and agility which has been marketed as a requirement to combat the GWOT. The most disturbing aspect of NSPS is the reliance on our leadership within DoD to execute the enabling regulations with integrity. DoD leadership has never displayed the ability to operate in a corporate environment, with any degree of consistency. The response provided by DoD to employee concerns states that "The supervisors will also be held accountable under NSPS" for their execution of the program...this does not relate to the military members that supervise and rate civilians. The justification for new rules to provide flexibility and agility in the GWOT implies that the old system did not accomodate the same. In fact, it is not a failure of our current system that requires attention, it is the failure of DoD to hold managers and employees responsible for 'doing the right thing'. Another area of concern is the provision for the local market adjustment which may be different for various occuapations within the same geographic area. It is shameful that DoD has justified NSPS by invoking the terrorist actions of 9/11 that killed so many of our citizens. DoD has been working on this transisition for 25 years in isolated test markets with varying success, and to use the deaths of so many Americans on 9/11 as the justification of NSPS is a disgrace. I beleive that DoD is taking a step back to the early 1900 when government operated under a spoils system, and they have forgotten that the regulations and laws in place today were developed because of human failures and inequitable treatment of all Americans. Will we see the same need to implement restrictions due to poor management, after employees and applicants are treated unfairly, or paid inappropriately, by managers?