Comment Number: OL-10507843
Received: 3/14/2005 3:30:20 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:

The National Security Labor Relations Board, whose members are appointed by the Secretary of Defense, has little or no congressional oversight. Without congressional oversight, the threat of unbridled political partisanship is all too real because: “Members may be removed by the Secretary only for inefficiency, neglect of duty, or malfeasance in office.” The current system already provides supervisors with numerous methods of disciplining “for personnel actions based on either misconduct or performance that fails to meet expectations.” Poor managers are unable or unwilling to use the tools they have today; why would anybody expect poor managers to do any better with the NSPS? There is no definition of what “aggregate pay” means. There is no uniform method of determining which GS series will go into which Pay Band. The example shows engineers and scientists, but there is no indication of how it will work with any other occupation or skill. Overall, the NSPS seems geared toward reducing the fixed costs of the government, i.e. payrolls and retirement benefits. Considering the recent article in Air Force Times (14 March 2005) about how the USAF is approaching the deficit by cutting costs, the direction this program is heading DoD seems all too clear. Pay Banding offers a great way to reduce payrolls, and thereby, future retirement benefits. Justifying the NSPS under the name of national security is a thinly veiled lie, and anything built upon a lie is bound to bring a multitude of abuses. The proposed rules in the Federal Register uses a comment made by President Bush in May 2001 to justify the transformation, but then, the argument swings to September 11th. Clearly, these changes were already in the works before September 11th, but that blanket excuse is being used by ideologues or “business” people to justify attacks on the rights and pay of federal employees. These attacks have been ongoing since President Reagan successfully depersonalized federal employees by labeled us all as “bureaucrats.” The world saw how the labor force was treated with the firing of the Air Traffic Controllers. The recent unwillingness of the Administration to support equal pay raises for military and civil service indicates a clear distain for federal employees We federal employees can look forward to the same joys experienced by the Air Traffic Controllers but on a daily and more personal level. We had better get used to answering a number of questions: How much did you contribute to the CFC? Are you a member of the Officers’ Club? Can you work late today? Can you help with the squadron’s car wash this weekend? What church do you attend? Are you going to the prayer breakfast? What do you think about the last election? Don’t you think it would help unit morale if you started wearing tighter sweaters? Don’t you think wearing a white shirt and tie looks more professional? Our pay and continued employment may depend upon how we answer these and many other questions. We must always keep in mind that: “An employee’s rate of basic pay may be reduced based on a determination of unacceptable performance and/or conduct.”