| Comment Number: | OL-10505609 |
| Received: | 3/10/2005 7:17:58 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:
As a member of the International Organization of Masters, Mates and Pilots (MMP), I am writing to voice my concern about the proposed imposition of the National Security Personnel System (NSPS) on MMP civil service mariners (CivMars) employed by the Department of Defense (DoD) on ships of the Military Sealift Command (MSC) and the US Army Corps of Engineers (USACE). MMP also represents civil service harbor pilots who guide US Navy vessels in and out of our nation's ports. The current CivMars system operates in the best interests of national security and should not be altered by the proposed NSPS. NSPS is not appropriate for managing CivMars and civil service pilots employed by DoD due to the unique nature of shipboard employment and the role these mariners play during national emergencies. Unlike almost all other federal civilian service employees, CivMars working on government ships perform under conditions that more closely resemble those on board ships manned by the U.S. military - they go where they are ordered to go when they are ordered to go; they often are away from home for lengthy periods and do not go home at the end of each day to see their families; and they daily perform dangerous tasks in support of the U.S. military. CivMars are also considered legally excepted service employees, as opposed to competitive service employees, and are prevailing wage rate employees not covered by performance management systems. The bottom line is that CivMars are part of a time-tested system that works and, because of its uniqueness, should remain subject only to 5 USC 71. As history has demonstrated, CivMars play an integral role in supplying US troops and citizens of war torn nations with necessary supplies, reconstruction and humanitarian aid, including most recently in Operation Iraqi Freedom I (OIF I), OIF II, OIF 04/06 and in the Tsunami relief effort. In fact, the current CivMars structure has fostered a partnership with DoD that has enhanced the vitality and viability of military sealift and of the U.S. Merchant Marine. The contribution that MMP makes to the maritime community and the development of a pool of qualified mariners available to DoD in times of war cannot be duplicated by any government agency. Weakening the ability of MMP to provide training and to recruit CivMars and pilots into membership will have the effect of reducing the pool of qualified mariners and pilots available to DoD during times of war. Therefore, the service MMP provides to DoD and to the nation is an important component of national security. The specialized knowledge and skills required of CivMars and harbor pilots make seafarers unique assets to DoD. MMP contributes to the DoD mission by providing the means for DoD CivMars and pilots to continually upgrade their skills and perform to the high standards set by the international maritime community. CivMars have successfully answered the call time and time again under the existing system. It is a proven system that works. The proposed NSPS system would only undermine that system, decreasing our military sealift capabilities and the pool of qualified mariners needed to crew those ships. NSPS would also reduce MMP's ability to attract, develop and retain a robust pool of mariners to the detriment of national security and the degradation of DoD's missions. Therefore, based on the uniqueness of CivMars, and the critical role they play in national security, they should be specifically excluded from the requirements of the NSPS.