Comment Number: OL-10509022
Received: 3/15/2005 12:06:12 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:

I am writing in objection to the proposed National Security Personnel System regulations. These regulations, as issued by the Department of Defense and the Office of Personnel Management, will severely impact civilian workers in the Department of Defense. I feel these regulations go beyond, in fact even are counter to, the intent of Congress in granting the NSPS statute. I am a DODDS teacher and have been for twenty years. I thoroughly enjoy the challenges and benefits of teaching the children of our military members who are stationed overseas. During my 20 years I have been supervised directly or indirectly by over 20 administrators, both principals and assistant principals. Some of them have been fantastic educational leaders. Some have already been ROAD (Retired on Active Duty) when I worked for them. Some I was personal friends with, some I respected as my administrator but did not have a personal relationship with, and some I had no respect for as a professional and no relationship personally. Whatever my relationship with my administrators however, I always knew that their personal opinion of me was of no consequence with regard to my job and my pay as long as I did my job satisfactorily. Under the proposed NSPS regulations this may no longer be the case. My pay could be directly controlled by my superior. If my principal and I do not see eye to eye on each and every issue he/she will have the power to hurt me financially. THIS IS NOT RIGHT. There is a system for bonus pay in DoDDS, or at least there has been for some years. Even this system is not fool-proof and those teachers who cater to the whims of the principals are often the ones who are given bonuses. But at least the basic pay of each teacher is determined by a set formula and each teacher knows what he/she will receive yearly. Our pay is determined by years experience and education. As I stated, I have 20 years experience with DoDDS and I have attained my master’s degree and over 15 teaching certifications. My pay should reflect the years of hard work I have given DoDDS and the equally hard work I have done to keep my teaching credentials current and, beyond that, to obtain further teaching certifications and my master’s degree. Within the present system, and following labor guidelines, there are provisions and legal methods to get rid of poor teachers, and I firmly believe in the right of administration to do so. I don’t want to be teaching next to a colleague who is not doing his/her part of the job. It is my understanding that under the new NSPS proposal it will be much simpler to fire an employee and there will be no recourse for that employee. Talk about no job security! Again, I am at the whim of the principal. If for some reason he/she does not like me I could be fired. After giving 20 years, and loving it, I could be out, high and dry, and no way to grieve or question the firing or even to have anyone ensure it was done equitably. The teacher’s union of which I am a long time member would also become obsolete. Again, without any consideration, conferencing, or arbitration, the collective bargaining agreement which my union has worked hard to build so that it protects me and my colleagues could be overturned. Management will have the right “to take whatever other actions necessary to carry out the Department’s mission.” This is in effect carte blanche to destroy the collective bargaining agreement and the union. My working conditions could be changed with no input from me or any of my co-workers. Even the requirements for my job could be changed, perhaps making me “unfit” for the job, without any input from me or recourse as to what to do now that I don’t “fit”. There are many other areas where the proposed NSPS regulations are unfair, and perhaps even illegal. I chose not to copy and paste a form letter provided as an objection to this proposal. I want those people in charge of reviewing it and accepting it to know that real people are going to be hurt by this proposal. I am not only talking about the teachers who can/will be hurt. The children we teach will suffer. If teachers are unsure of the status of their jobs with DoDDS they could very well decide to return to the States to teach. DoDDS has a wonderful pool of experienced, caring, resourceful teachers. We enjoy many benefits working overseas for the Department of Defense, and we make many sacrifices. This pool could quickly be drained as those dedicated individuals look to other arenas for work; arenas where their expertise, hard work, and dedication are valued and where they know they are secure in their jobs as long as they continue to do those jobs satisfactorily. And in my experience most DoDDS teachers do MUCH more than just a satisfactory job! Thank you for the time you took to look at my feelings on this matter. I urge you to scrap the proposed NSPS regulations.