| Comment Number: | OL-10508256 |
| Received: | 3/14/2005 10:52:03 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:
Having read the NSPS my comments are as follows: 1. This system appears to be 10% developed with the remaining 90% to be developed by DOD some time in the future if and when they get to it. 2. The NSPS should be implemented immediately as written for a three year test period and apply only to personnel from Mr. Rumsfeld thru all GS-15 level employees. This will allow them time to first hand work out and correct all flaws prior to affecting the entire workforce. 3. Almost every paragraph begins with DOD will establish, document, develop, designate, assign, etc. Has DOD done anything to prepare for the implementation of NSPS? 4. 9901.222 No procedure outlined. How are they requested? What are the time frames? Is this “classified” information being withheld from the workforce? 5. 322 At what point do we find out if DOD will or will not establish, set and/or adjust rate ranges, and what will they be? 6. 323 What procedure is to be used to compute this rate range adjustment? IAW what implementing issuances. 7. 409 Why are we reverting to an evaluation system that was scrapped as a failure? What is “appropriate rating official”? What are “appropriate reviews, by whom? What DOD implementing issuance? When will they be established and published? What is the difference between “supervisor” and “other rating official”? 8. 511 This sounds like a sanctioned and blessed return to the spoils system of old. 9. 608 Define “undue interruption”. 10. 712 Offenses will be identified in advance of what? When will departmental regs be published? 11. 808 This is a violation of the U. S. Constitution. It makes double jeopardy legal within DOD. 12. 907 All the “authority” has to do is nothing to affirm the decision of the “Board”. “Good ole Boys” in action, again NO justice. 13. 908 This is a return to indentured servitude, pure and simple. What happened to our basic human, civil and legal rights? 14. 914 This is allowing and condoning the return to the spot light and rubber hose method of interrogation; no witness-no restrictions. From the beginning of this reg it is another of the SecDef’s “do as I say, not as I do” programs. He has again totally removed him and his overpaid “cronies’ from the effects of NSPS. Again his “screw the worker” philosophy comes out. The NSPS is a return to a totalitarian form of rule in DOD. It places complete and total power in the SecDef with his “sole, exclusive and unreviewable discretion”. This is entirely too much power to put in the hands of one person. Especially without any or other checks and balances within the system. What is the proposed name for this new kingdom?