| Comment Number: | OL-10508328 |
| Received: | 3/15/2005 3:14:18 AM |
| 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:
Summary under The Case for Action pages 7552, 7553 If DoD civilians are unique in government and an integral part of an organization, why is DoD creating a super bureaucracy at a projected cost of $158 million dollars, plus $100 million? As tax payers, we are already overburdened. NSPS does not follow its own logic, nor promote efficiency or cost effectiveness. Assessing and rewarding performance under NSPS is at the whim of the supervisor. Page 7562 Performance and Behavior Accountability - High performers will continue to perform irrespective of systems. If employees were treated fairly, there would be no need for EEO/unions. NSPS will make federal employees political appointees. NSPS will result in a no holds barred free for all allowing supervisors unequivocal authority to remove, demote, reassign, and deploy employees anywhere in the world at their whim. It will also open the door for nepotism to increase exponentially. Per Marilyn vos Savant, …”it is unethical to hire relatives in a public company. In government I would not hire one even if he or she had stellar qualifications. Public companies and governments are everybody’s business, and all should get a fair chance to participate. Hiring a relative is not fair…”. Government and private industry are not interchangeable. NSPS will force federal workers in to servitude with no voice. We will be the new draftees. Monitoring Performance and Providing Feedback – Longevity comes in with regard to earning and taking leave i.e., senority. Page 7563 Staffing and Employment – Subpart E – DoD does not recognize the high quality workforce it already has. NSPS is union busting. Federal employees have now been relegated to “subjects” instead of citizens. E.O. 12866 Regulatory Review page 7573 – market sensitive pay may be fine inside the beltway and in large metropolitan areas; however, what about DoD employees who live in Right to Work states and who also have high unemployment rates and lower wages? Outlays for NSPS are projections. DoD admits they have no idea how much it really costs. This is not good stewardship of tax payer money, nor fiscal accountability. Setting pay upon reassignment page 7583 – DoD may set pay anywhere within the assigned pay band when an employee is reassigned, either voluntarily or involuntarily..” again at the whim of the supervisor. 9901.409 Rating and rewarding performance – (e) DoD will transfer ratings of record between subordinate organizations and to other Federal departments or agencies in accordance with DoD implementing issuances. If an employee receives an unfair rating, it will be transferred to the next organization and the employee has no way to seek relief. That is not fair to the employee. 9901.514 Non-citizen hiring. This is an outrage. Federal employment should only be allowed to American citizens born here or naturalized citizens only. This does not pass the common sense test with regards to “national security.” 9901.604 Coverage (7) page 7589 - …”reclassification of an employee’s position due to erosion of duties…” it is the supervisor’s responsibility to ensure this does not happen.