| Comment Number: | OL-10504951 |
| Received: | 3/10/2005 2:06:00 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:
General Comment: There is a significant difference between the skeletal authorities that Congress approved and the sweeping new authorities that Secretary of Defense is now requesting. During congressional hearings on this issue, the Secretary asserted that the Pentagon's broad mission requires greater "flexibility" in hiring, disciplining, compensating and assigning civilian personnel. Neither the Secretary nor his subordinates offered any concrete examples to explain how union rights might have impinged on the Pentagon's mission in the past. Congress attached certain strict conditions--including a specific requirements that DOD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. Although DOD has convened a dozen or more meetings to "brief stakeholders, DOD gave absolutely no response to repeated union requests for specific information as to what problems management wishes to address with NSPS. The current proposed regulations still do not provide the specifics required for adequate comment. One of the Pentagon's objectives in advancing NSPS is to construct a so-called "pay for performance" system. Various government agencies have been testing performance pay systems for more than 20 years and invariably, the results have been that the majority of workers feel cheated regarding advancement, promotion and pay decisions. The process typically reduces salaries and morale. It eliminates any redress for decisions made on the basis of considerations other than merit. For these reasons, I oppose the implementation of NSPS and I urge you to instruct the Secretary of Defense to stop any further development of NSPS until the Pentagon is willing to substantively address the issues raised by the United DOD Workers Coalition and to provide the specific regulations and instructions to allow adequate review of the new personnel system.