Comment Number: OL-10508241
Received: 3/14/2005 9:58:29 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

I wish to submit the following comments concerning the NPRS rules: 9901.313(b): This section stipulates that civilian pay budgeted under the current regulations through 2008 will be allocated to NSPS. However, after 2008 civilian pay will be free to be increased (or cut) to “the maximum extent practical.” I have worked in DoD over 27 years, during this period I have seen budgets which relentlessly go up year in and year out for contracts, military pay, utilities, services, supplies and equipment. Under the NSPS, I am puzzled that of all these costs only civilian salaries is targeted for optional increases “as practical.” Since I started my career my salary, due to promotions (GS-11 to GS-14), cost of living adjustments, and step increases, my pay has increased about 350%. However, when I look at the cost of housing, automobiles, food, health insurance, taxes, utilities, and everything else during this same period has all increased by about the same amount. I believe the result of all my pay increases over my career has been just to barely keep even with inflation. In my career I have had the pleasure of working with many hard working civil service and military personnel. I have very seldom seen instances of poor performance. With rare exception, poor performance was a direct result of poor management. NSPS does nothing to cure poor management. I believe that the real object of the NSPS is to save DoD expenditures by limiting employee protection from inflation. Was this really Congress’ intent in passing the NSPS legislation? 9901.910(2) This section reserves the right of DoD to assign employees to meet any operational need. DoD has pushed to concept of the total force Military (active & reserve), civil service, and contractor to be able to respond to mission requirements. Does this absolute right for mission assignment effectively make civil service employees essentially unofficial reservists, eligible for global deployment to meet the needs of the Global War Against Terrorism? How does this square with the requirement for absolute flexibility while at the same time stripping employees of pay protections under the existing Civil Service system. This contrasts with the active military pay system of providing annual cost of living adjustments, automatic within grade pay increases, and a host of other generous compensation benefits. In Iraq over 1,500 military have lost their lives, and about 320 contractors and civil service employees have lost their lives. Why are civilian sacrifices worthy of so much less recognition? Unaddressed: (a) DoD regulations currently allow US Military personnel to contribute a portion of their special pay, and re-enlistment bonuses into TSP. Recommend that civilian employees be allowed to contribute a portion of pay bonuses into TSP. If DoD relies on bonuses as a cost saving alternative to pay increases, FERS employees will need to be able to save more of their bonus pay in TSP to augment their paltry FERS retirement benefit.