| Comment Number: | OL-10504467 |
| Received: | 3/9/2005 1:54:58 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:
Program Executive Office National Security Personnel System Attn: Bradley Bunn Arlington, VA 22209-5144 23 February 2005 SUBJECT: DoD USAF (RIN- 3206-AK76) NSPS I write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14,2005. This message will be sent to both DoD and my representatives in Congress. General: I believe the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD employees. Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to receive the same annual pay acrossthe-board adjustment that other GS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Mana2ement - 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. Subpart F Workforce Shapin2 - 9901.6012' to 9901.611 DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. SubJ!art G Adverse Actions - 9901.701 to 9901.810 Due process and fairness demand that the independent body reviewing a major suspension as 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-Management 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 since 1978. There is no compelling reason to take away 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 the Union. America is at war. We are fighting for democracy abroad. But the regulations are an attack on workers' basic rights. Furthermore, NSPS will divert the attention of defense workers from the soldiers' welfare to protecting themselves from abuse on the job. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers.