Comment Number: OL-10508686
Received: 3/15/2005 10:02:10 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:

Docket number NSPS 2005-001 and/or Regulatiory Information Number (RIN) 3206-AK76 /0790AH82 and the following subparts. Classification (Subpart B) 9901.201 to .231: Union's have never been afforded the opportunity to negotiate classifications. Management does not need this in order to have flexibility. They have the right to assign work and detail employees to different functions currently. You are going to end up with a ggeneralized workforce and no one will be a specialist in anything. You can simplify job descriptions without NSPS. I have not seen nor read any rationale from DOD of why you need these changes. I cannot understand how my classification or pay has affected national security. Performance Management (Subpart D) 9901.401 to .409: Our pay has always been based on our performance. If my performance is not up to expectations, step increases could always be held back. Management has always had the option of not promoting me if I was not doing what was expected of me. Management has always been able to rewward high performers with a monetary award, time off award, QSI, etc. We don't need NSPS for this! There will only be so much money to go around that will be placed into the pay pool. The end result could be that even the high performers will not be compensated. This will do nothing to help with the credibility of the system. It will only make it worse. I can only imagine how much this concept will cost the taxpayer for this design and the administration of it. The money would be better spent on wquipping the soldiers. How much overhead is going to be created since nobody has figured out all the details of it? Staffing & Employment (Subpart E, 9901.501 to .515) Workforce Shaping (Subpart F, .6012 to .611): I agree the hiring process is slow and cumbersoome but we do not need NSPS to figure out a solution to that problem. I disagree with the idea that if I get promoted to a different position that I will have to serve another probationary period. That does not give me much incentive to better myself. There will always be workload fluctuations. Our agency has been hiring a lot of term and temp employees which gives you the flexibilities needed for "rightsizing." Adverse Actions (Subpart G., 9901.701 to .721) Appeals (Subpart H, 9901.801 to .810): DOD will be the prosecutor, judge, and jury without allowing a neutral third party review. The current system should remain in effect. The system is already in place so that management can take the necessary actions against a poor performer or misconduct. If managers are not doing their job with dealing with those employees now, why would you want to enable them with unvetted power to make wise decisions when they have proven that they are the problem. The managers should be dealt with. I am not the enemy! I am providing a service to the warfighter (soldier) and would like to be able to concentrate on that. Instead of doing that, I will have spend my time worrying about my job. This will reduce the burden of proof - standards - for management in adverse actions against any employee. Labor-Management Relations (Subpart I, 9901.901 to .929): The Union and the employees have always done what had to be accomplished to order to support the soldiers. I cannot ever remember a time when the Negotiated Agreement or the Union has been a hindrance. The concept of the National Security Labor Relations Board (NSLRB) is not going to be fair nor impartial. DOD will be the prosecutor, judge and jury. The Secretary of Defense will appoint three members to the panel, so I cannot ever foresee where they will rule against hteir boss. DOD has not allowed the Unions to be an active participant in this process. These proposals are all DOD's and none of it is input from the Unions. If I am going to have an investigatory examination placed upon me, I want my Union representative there. Your proposals are unacceptable and contrary to law. DOD is not above the law.