| Comment Number: | OL-10504715 |
| Received: | 3/10/2005 9:07:59 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:
In reviewing *The Case for Action* (pg 7553, FR), there are a lot of buzzword, logical fallacies. For example, DoD maintains that the current system is *ultimately, risky.* That is not necessarily so. Same page: the proponents of NSPS say that this will be a *mission-driven system*. My observation in reading all of the rest of the proposed rules and background is that it will be a LOYALTY-driven system. Don't rock the boat, don't challenge your supervisor. That may be OK in the private sector, but we owe it to the taxpayers to stop aggregious behavior. Sure, the rules allow an individual to challenge their rating to a higher authority; but that only puts the employee into an adversarial cycle for future performance ratings that may not be able to be overcome without someone leaving. Same page, bottom of the first column: The reference to 9/11 is inflammatory and an emotional plea not related to the task at hand. I really challenge the developers to show me how 9/11 itself made clear that change was needed. Perhaps trying to prosecute the GWOT made it clear that change was necessary, but not 9/11.