| Comment Number: | OL-10506046 |
| Received: | 3/11/2005 10:46:47 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:
Subpart B Classification - Section 9901.201 to 99901.231 NSPS will replace the current government job classifications by grouping them into a few occupational categories with pay being set in bands with the new categories. Individual employees will be unable to appeal these newly classified positions or the broad range of duties under Subpart C Pay, Sections 9901.301 to 9901.373 Defense Department employees should continue to receive the same annual pay and across-the-board adjustment that other GS/FWS workers receive. The individual pay increases for performance in the regulations should include guaranteed percentages so employees will understand the pay system and what their pay increase will be depending on their performance. Subpart C Pay, Sections 9901.301 to 9901.373 Defense Department employees should continue to receive the same annual pay and across-the-board adjustment that other GS/FWS workers receive.The individual pay increases for performance in the regulations should include guaranteed percentages so employees will understand the pay system and what their pay increase will be depending on their performance. Subpart F Workforce Shaping - 9901.6012 to 9901.611 The Defense Department should not change the current layoff/RIF rules, which give balanced credit to performance and the employees' valuable years of committed service. Moreover, under he proposed regulations employment disputes over such matters would be unfairly limited to the Merit Systems Protection Board. Subpart H Appeals - Section 9901.801 to 9901.810 Over 25 years worth of case law will be discarded, where those precedents conflict with NSPS. This will eliminate the use of the Douglas factors, which third parties used to mitigate or overturn agency-imposed penalties. Subpart I Labor-Management Relations - 9901.901 to 9901.929 The labor-management law that has governed the employees' right 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. The Defense Department should not create a company-dominated dispute board. Any dispute board must be jointly selected by management and the union.