| Comment Number: | OL-10508432 |
| Received: | 3/15/2005 8:34:37 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:
Thank you for the opportunity to comment on the proposed rule regarding the National Security Personnel System. I support the NSPS in its overall goals. I have worked for DoD for more than twenty two years, and I applaud the creation of a pay for performance system. My one concern is a general one relating to continuing collaboration. According to my personnel office, I am not covered by a union. This holds true for many of my colleagues within my office and across my installation. As explained on page 7557, last paragraph of the proposed rule, DoD will issue implementing issuances that will contain the detailed procedures for implementing the NSPS. These implementing issuances will not be published in the Federal Register nor is there any indication that they will otherwise be made available for comment. The only opportunity for comment will be through the continuing collaboration process with selected union representatives. Since I am not covered by a union, I have neither an opportunity to comment directly nor an opportunity to be represented by someone who could comment on my behalf. This would appear to conflict with standard practice within the federal civil service system. It also appears to conflict with standard procedures within OPM. I believe that civil servants ought to have the opportunity to comment on Part 9901, Subpart 9901.1211 Career groups, Subpart 9901.212, Pay schedules and pay bands, and Subpart 9901.221, Classification requirements. Those of us who are in job series that are relatively rare within DoD, but are common within the entire federal civil service system are placed at a potential disadvantage under the proposed NSPS system. I ask that public review of these subparts be reconsidered. Thank you.