| Comment Number: | OL-10507989 |
| Received: | 3/14/2005 4:17:29 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:
It is quite apparent that the Department of Defense (DOD) and the Office of Civilian Personnel (OPM) have the full intent to implement the NSPS regulation regardless of any comments or suggestions received from the AFGE or federal employees. If that was not the case, DOD/OPM would have solicited comments from the AFGE and the governments employees prior to announcing the implementation of the NSPS. Based upon a breifing given by a head of DOD/DLA Humane Resources, regarding pay banding the implementation of the NSPS is a done deal. It is also quite clear that the intent of DOD/OPM in implementing these regulations is only to further weaken the bargaining power of the AGFE and to subject government employees to unfair labor practices. As a government employee with 23 years service and who also believes in a strong National Security, I am against the implementation of the NSPS, since it appears to give DOD/OPM full discretionary power over government employees' pay,retention rights,evaluation,promotion, work schedules and overall treatment of goverment employees. Given the short notice (3 weeks) and limited space, I have provided the following comments regarding the proposed regulation: 1. Within pay bands such as GS 5-11 nothing identifies what expertise, kownledge, duties or level of responsibility would be required for a specific salary within the pay band. It appears to be completely arbitrary. That why GS grade series are currently used. 2.Giving a new employee 20, 15. 10 years toward their job retention rights is unfair to employees with more service time. It would be possible for an emplyee with 15 years with exemplary service to lose their job in a RIF action if they were to receive a lower rating in their 16th year if the newer employee received a higher rating that year. Does DOD/OPN consider that to be fair treatment ? 3. A GS 5-11 pay band is considered to be at the journeyman level whereas the GS 12-13 is a subject matter expert. I my 23 years as a government employee, I can say that most persons promoted to a GS 12-13 are not promoted because they are subject matter experts. 4. There is no langauge that guarantees that the established pay pool will be funded to ensure that all employees will receive fair raise based upon their performance rating. Funding of the pay pool is at the sole discretion of DOD/OPM/Agency management. 5.There is no justifiable rationale for giving DOD the authority to send government employees overseas,war zone or eslsewhere. 6. I have seen nothing on what the pay scale would be for each pay band. Is this a secret ? 7. The performance rating are based on not how good an employee performs their job but what they contribute to the agency. Their rating is based totally on subjective evaluation criteria. Is DOD/DLA going to do a better job at rating personnel ? The DOD/DLA management is always saying what a great job the DLA employees are doing and that DOD/DLA is attempting to improve the communication between management and government employees through making changes in DLA climate and culture. It would appear to me that implemention of the NSPS regulations would be a step in the wrong direction. Is there somebody within DOD/DLA, who has the honesty and integrity to tell the goverment employees the truth. DOD/OPM already has a personnel system that would work efficiently and be fair to both party involved if management would took the time to implement it properly. What is DOD/OPM management going to do different to make the NSPS fair and unbias ? The truth will surface in the End !!!