Comment Number: OL-10506190
Received: 3/11/2005 12:23:06 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:

Sub part C-As a supervisory Firefighter (GS-0081-08) I do not understand how this system will or can be applied to the GS-0081 series.Our pay, work week and duties are completely different from that of the rest of Civil Service.We work 72 hours per week, our perfromance plans contain unusal objectives and sticking us in the other group along with other misc. occupations makes no sense.All of the performance objectives in our series are subjective in nature and the day to day performance of our duties does not allow a set standard method of evaluation.For example one of the objectives is “be a team player” there is no OBJECTIVE way to measure this and therefore a quota system as proposed by NSPS means that I as a supervisor know at the beginning of the year that if I have 6 employees that I will have to place 1-2 in the top band, 3-4 will be in the middle band and 1 will be in the low band.I don’t see how this system is fair or just.Also I do not see in the proposal what happens if you transfer supervisors and last year I was in the top band and this year my new supervisor places me in the low band, do I lose pay?This system is NOT an improvement it is a return to the bad old days of the good-ole-boy system.The Secretary can say whatever he wants to about modernization but under this “new” system if your supervisor likes you you’re in if not you’re done for and that’s not the way to run a business.I also take serious issue will giving the current administration the flexibility to change my duty assignment and/or location at will.I was hired to be a Supervisory Firefighter on Kirtland AFB; I am a civilian,not a GI; the government and I have a contract if they want to change that contract then they should have to negotiate it not just change it at will and on the fly.When I went to work for Kirtland AFB I did not agree to deploy overseas,I did my time in the military and don’t wish to return to it.If the US Government doesn’t have enough GI’s to meet our worldwide commitments then recruit more, don’t resort to a stealth draft of the Civil Service workforce to cover those shortfalls in the Active Duty Force.Subpart G/H - Giving DoD the ability to keep all complaints in house through an internal appeals process is the same thing as having the fox guard the hen house,I am a supervisor and I think that the proposed system is begging for abuse.The unfairness of the current system of discipline concerns me but the proposed new system scares the living hell out of me.There are plenty of ways now to correct and/or remove poor performers; management just needs to use the tools available to us;“fixing” this area is a manufactured problem that exists in the Secretary’s mind and not in the real world.Subpart F- The Secretary SHOULD NOT have the ability to remove veterans status as a prime consideration for RIF or other personnel actions.Subpart I – Cutting the Unions out of the picture is just this Administration’s anti-Union/anti-employee, pro business attitude.If what DoD wants to do is within the employees position description/contract and allowed by OPM regulations then implementation is not a problem. DoD and the Secretary have a problem because what they want to do is have the ability to use the civilian workforce like a component of the Active Duty Military and not have to answer to anyone.The question that should be asked is why is the Secretary so afraid to come out and explain why a change is necessary and work with the employee groups to see that it is done fairly and equally.Several of my co-workers have expressed that this plan is bad for moral and retention and I agree, I believe that this plan is President Bush’s and the Secretary’s back door plan to make federal civilians quit so that they have an excuse to give more cooperate welfare to KBR, Halliburton, etc.It’s a hell of a choice to have to do whatever/go wherever DoD wants at their whim or give up your career.I am pround of my service and I don't want to have to choose.