| Comment Number: | OL-10506758 |
| Received: | 3/12/2005 9:59:06 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:
From reading 5CFR Chapter XCIX and Part 9901 (the proposed NSPS) it is clear that implementation of such a policy will have the very un-merit like principles of creating both a DISPARATE IMPACT by treating Department of Defense (DOD) employees differently than other Federal Employees (taking away many rights and protections of DOD employees that have long been the hallmark of Federal Employment); as well as DISPARATE TREATMENT as employees under the NSPS will be left to the subjective whims of a performance management system that provides little in the way of safeguards against cronyism and the arbitrary and capricious whims of management. I realize that every individual concern (how it will impact their unique situation) can’t be addressed in the body of any sweeping policy proposal (such as the NSPS). However, it is clear that there are many areas of proposed change that are so grievously lacking in explanation in terms of scope and procedural implementation as to provide no guarantee at all of any real merit protection to employees. When Congress granted the DOD the authority to develop a new personnel system I do not believe their intent in doing so was to allow DOD to circumvent the rights, protected by merit principles, of Department of Defense Employees. I urge Congress not to allow implementation of the NSPS until the core issues regarding pay, discipline and employee rights are addressed in a more definitive manner and in a way that truly incorporates true merit principles in its design and implementation (and not those defined by the NSPS which seem to be more administration/managerial self-interests than anything else).