| Comment Number: | OL-10508904 |
| Received: | 3/15/2005 11:22:36 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:
General comments: 1. Full evaluation of the proposed NSPS system would require examination of the pay bands including a description of what jobs will be included in each band. Will this be available for comment before implementation? 2. I am concerned that pay increases will be reduced or eliminated due to budgetary constraints under the proposed system. The Corps of Engineers is funded based on projects, not personnel, and in lean years management may opt to reduce or eliminate pay increases in order to stretch their dollars. I agree with basing increases on performance but the proposed NSPS system runs the risk of NO increases regardless of performance. Performance appraisals are subjective and, as such, are subject to manipulation by management. 3. The NSPS system relies heavily on supervisor evaluations. In my opinion this will result in an unfair system. Supervisors run the gamut from being good, honest, and impartial to being poor, uninterested, and biased. Under the Corps's current fiscal constraints, supervisors are being chosen to minimize cost, not to maximize ability. Supervisor training will do little to rectify this situation. 4. The NSPS proposed regulations mentions enhanced mobility of civilian employees to better support military operations. What checks and limits will be placed on such mobility? It will be hard to hire and retain good civilian employees if there are no limits on mobility. One or two location changes during a career is to be expected these days but more leads to a loss of experienced employees. Also, mobilizing civilians into hazardous areas puts them in situations they are not trained to deal with and may not be capable of dealing with. Mentally and physically, military employees are rigorously screened and subject to years of intensive training. Forcing untrained and possibly unsuitable civilians to serve in this way puts them and those around them at risk.