| Comment Number: | OL-10505782 |
| Received: | 3/11/2005 8:19:46 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:
As the G8 (Resource Manager) for 1st Armored Division and a former Budget Officer at 3rd US Army, I had and have significant manpower and personnel responsibilities. I can attest that the inflexibility and extremely slow recruiting process of the current civilian management system has significantly impacted 1AD’s and 3rd US Army’s ability to deploy the number of civilians required to properly support both OEF and OIF. I fully and enthusiastically support DOD’s National Security Personnel System proposals. NSPS is an essential and long over due restructuring of our current broken DOD & DA civilian personnel system. At the tactical and operational level, Emergency Essential Civilians (EECs) are a critical part of accomplishing the training and war-time mission. Request that the role of EECs in NSPS be clearly identified. DOD & DA Civilians must play a more important deployment role on the battlefield. Even under NSPS an EEC-type capability must be maintained. This EEC-type capability must be more robust and legally binding than in the current civilian management system so that DOD civilians can be counted on to deploy and support maneuver forces in combat. NSPS must establish special EEC recruiting agreements, benefits, deployment bonuses, deployment tax exemption, professional development opportunities and retention incentives for EEC-type personnel. 1AD’s OIF deployment experience is instructive: - The only G8 Emergency Essential Civilian (GS-12) transferred out of 1AD prior to deployment. - The unexpected departure and the extreme difficulty in hiring EECs left a 14-month gap in this critical billet. - The position was finally filled 8 months after deployment. - Three lower-grade non-EEC 1AD budget Civilians ‘volunteered’ to deploy, but only 1 actually deployed. - Upon arrival in Iraq, 1AD received permission to over-hire 4 EEC personnel. Only 1 actually deployed and then only remained 90 days. During and since our OIF 1 deployment, 1AD has gone to the extreme measure of designating all GS-9 and above DA Civilian positions as EEC. All newly hired personnel and those that want to extend their overseas tour, must now agree to become EEC for employment with 1AD. However, designating a position as EEC significantly delays the recruitment process, does not guarantee that the person will actually accept the job at the end of the recruitment period, or guarantee that after arrival at the unit, they will be around for the deployment. EECs are not locked into any period of employment and can move to other jobs at any time (unless already alerted to deploy). The 1AD GS-12 departed unexpectedly due to this lack of employment lock-in and created a long-term vacancy prior to and during most of the deployment. 1AD had 3 people accept the GS-12 EEC position, sign the EEC agreement and then decline the job before completing all supporting EEC medical, security clearance and administrative requirements. One person actually completed all recruiting actions and only days before PCS to Germany, found another non-EEC job in Germany. As a result, it took 14 months to fill this one position. As presented earlier, if DOD & DA Civilians are to play a more important role on the battlefield, more positions must be designated as EEC and we have to be able to depend on them to actually deploy. EECs should sign special recruiting agreements that lock them into the hiring organization for a specific period of time (2-3 years). Once a person signs the EEC agreement (recommended at the beginning of the recruitment), they should not be allowed to seek other employment until such time as it is determined that they do not qualify medically or administratively as an EEC. Should a person withdraw from consideration once the EEC agreement is signed (recommended at the beginning of the recruitment), that person should not be allowed to seek other employment for a year and not qualify for a higher grade for a period of two years. In exchange for their dedicated and potentially dangerous service, EECs should receive special benefits, deployment bonuses, deployment tax free income, professional development and retention incentives. DA Civilians, especially EECs, are an important part of the Army Team. They deserve better management. SUMMARY: - NSPS is a much needed improvement! - NSPS must also address a critical Emergency Essential Civilian (EEC) type capability to ensure civilians play a more important role on the battlefield: - More positions designated as EEC. - Must prevent job-shopping once agreeing to take an EEC position. - Disqualification on job-shopping & promotion for failure to live up to EEC agreement. - Locked into the hiring organization for a specific period of time. - In exchange for dedicated and potentially dangerous service, special benefits, deployment bonuses, deployment tax free income, professional development and retention incentives must be established.