| Comment Number: | OL-10506823 |
| Received: | 3/13/2005 1:07:17 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:
Subpart A- (Sections 9901.101-108) was not developed in collaboration with the unions. It was dictated to the unions on a take it or leave it basis. It was provided with a broad outline of NSPS with no specific details on pay, appeal rights and RIFs. Subpart B- Classification No job qualifications, requirements and duties are not defined. Pay ranges, schedules, bands and career groups are not defined. Subpart C- Pay and Pay Administration (sections9901.201-204) By not having congress provide pay increases to federal workers on an annual basis it will provide a bias type system of pay for performance were the employee is at the mercy of a supervisor to receive his or her pay raise. Another question to ask is Pay for Performance system a legitimate system? no it is not, Because an outstanding employee can have his or her pay frozen because of lack of pay funds, arbitrary ceilings, and minimum freezes. Subpart D- Performance management (sections 9901.601-611) The employee is going to be held to a standard which is going to be imposed by the interpretation of his or her supervisor. The supervsior is going to determine which is good or bad behavior. once again leaving the employee to the mercy of their supervisor. Subpart F- WorkForce Shaping (sections 9901.601-611) DOD will have the option to lay off employees at will, eliminating current RIF procedures. Subpart I- Labor -management Relations (Sections 9901.901-928) This section is the most disturbing throughout the entire document. This is nothing more than legalized Union busting. The current administration is well know on their stand concerning organized labor. It is a way to destroy all the collective bargaining rights of a federal employee. It compromises the rights of an employee to be represented by his or her union at the discretion of the DOD. It takes away any authority of the FLRA and places it in the control of a internal labor relations board consisting of members chosen by the secretary. This is not only bias but unfair to the employee. I honestly don't know of any Union that would agree to that. I also challenge the statement that DOD has not been able to carry out their mission swiftly and authoritatvely because it has to adhere to labor-management regulations and that maintaining the status quo would not provide DOD with a workforce that is flexible enough to execute the current and future national security mission.This is simply, Not True.