Comment Number: OL-10507474
Received: 3/14/2005 11:27:35 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:

Thank you for this opportunity to comment. I have two primary concerns based on reading the proposed regulation and other fact sheets associated with this regulation. The first deals with the amount of time a supervisor will now have to put into personnel management, documentation, counseling, etc. Through this proposed regulation, a much more formal process of performance measurment will be necessary, which may or may not be able to be tied to metrics or some from of "fuzzy metrics." This will necessitate a shift from leadership to personnel management - that is, senior management will now be much more resourced to personnel management documentation, dispute settlements, etc. such that strategic planning and leadership will be a lower priority. In a bureaucracy already saddled with significant regluations and processes taking time away from leadership and organizational strategy, adding one more burden will continue to whittle away any competitive advantage/leading edge type of process that may be possible within the government. As the government's leading edge experiences have historically been to the benefit of society in general (IE - consider NASA), deterioriation of leadership hours toward personnel management will result in a negative impact on society at large. The second concern is the lack of consistancy between different functions within the DoD. Under this system, it appears that top management in a given function has the power to dictate parameters such that there will be inequities within the DoD between civilians in different functions under different management. This inequity will lead to lower morale, more disputes, lower productivity, and even further the criticism of bureaucrats. I think there are some lessons learned through previous similar personnel experiements that need to be considered in this light.