Comment Number: OL-10505592
Received: 3/10/2005 6:37:27 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:

I believe the proposed NSPS will undermine the civil Service and hurt the mission of DOD employees because of the following: Subpart C Pay, Sec. 9901.301-.373 :- DOD employees should continue to receive the same annual pay accross the board adjustment that other Govt workers receive The individual pay increase for performance should include percentage in the Reg so that workers will understand the pay system and what the pay increase will be depending on their performance. Subpart D Performance Management, Sec 9901.401-.409 :- For the sake of Fairness and Democratic Freedom DOD worker should also be able to appeal any performance rating through an independent process like workers can do now. This Reg is taking away workers fairness and democratic freedom right. Subpart F Workforce Shaping, Sec 9901.601-.611 :- Current Layoff/RIF rules should not be changed. The current rules give balanced credit to performance and and workers valuable years of commited and dedicated service to DOD. This proposal will encourage discrimination against older workers. Subpart G Adverse Actions, Sec 9901.701-.810 :- Democratic Freedom and due process demand that the independent review of a major suspension or termination be allowed to alter if it was unreasonable . The current standards approved by the courts to guide such process should continue to be used. The new Reg will encourage management arrogance, favourtism and injustice. Subpart I Labor-Management Relations, Sec 9901.901-.929 :- For the Fairness and Democratic Freedom the labor management law that has governed the workers' reght 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. This will not be a Democratic Freedom. DoD should not create a "company dominated dispute board". Any dispute board must be jointly selected by management and the Union. Sicerely Lokesh