Comment Number: OL-10507728
Received: 3/14/2005 2:28:01 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:

I completed my graduate studies in business administration during the time when the U.S. economy was being threatened by imports, particularly in the automotive industry. There was a tremendous impetus for the industry to change and business literature articles with titles such as "Change or die!" were very much in vogue. I am therefore an avid proponent of continuous change to keep up with the changing environment and it was with much interest that I reviewed the proposed changes to the federal civil service system. While I applaud the efforts being made to improve the civil service, I am somewhat concerned with the seeming elimination of some of the basic core features that are essential to the survival of a public service system. The information that we have received seems to indicate that the decision has already been made to implement the Spiral 1 for DoD in its present form, so I'm not sure how much effect these comments will have. In case there is still room to make changes I would like you to consider the following. To me the core of the civil service system is that it offers employment security with a certain minimum level of annual salary increase to offset the inevitable annual inflation. In return, the employee is expected to serve the country with unfailing loyalty and with integrity, safeguarding the public trust. Reading the proposed regulations, it seems obvious that these minimum features of the system will be eliminated and the entire progress of the employee will be in the hands of the supervisor. While this works very well in the private sector, where top performers are appropriately rewarded and deadwood is eliminated, it has obvious drawbacks when applied indiscriminately to the civil service. In the private sector the prime objective is to maximize profits (shareholder value), in the public service it is to safeguard the public trust (hence the term service as opposed to employment). I'm sure you will agree that these are very divergent objectives and therefore need different systems that address the unique requirements of each system. This subject has been widely debated in the business environment and there is a plethora of literature available on this subject. As a loyal citizen, I am concerned that if the regulations are implemented in their current form, they will have a negative impact on the morale and the loyalty of the workforce to the extent that our country will suffer for generations to come. So I respectfully request that you at least retain the basic core features of the civil service system, and make improvements that build on these features rather than eliminating them. Thank you for your consideration.