Comment Number: OL-10509151
Received: 3/15/2005 1:22:33 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:

We need to prevent the DoD from implementing the new NSPS in its present form, especially the Labor-Management Relations (subpart I) portion later this year, which will establish another regulatory board (National Security Labor Relations Board), which will prescribe its own rules (and publish them in the Federal Register). We do NOT need more growth in government. The DAWIA Act is responsible for changing many Navy agencies into multilayered legislative organizations which devour more and more of the budget for it’s internal operations, leaving less and less for producing tangible results (you remember those $500 hammers, when all the internal (budget and metric) costs mandated as a result of DAWIA are added in, I bet their true cost to the user is over $100,000 today. That is not what Congress intended. I have little faith that it will not happen again with the ambiguous provisions of NSPS.). Also, there is a significant difference between the skeletal authorities that Congress approved and the sweeping new authorities that Secretary of Defense Donald Rumsfeld is now claiming. Although congress acceded to the broad requests lodged by the DoD, it attached certain strict conditions – including a specific requirement that DoD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. The Pentagon has done neither. I am outraged by Secretary Rumsfeld’s blatant disregard for congressional intent in connection with the NSPS law. I agree that some changes are necessary with the changing war-fighting environment, but, I am angry that these proposals seem to treat the employees who help defend our country as the enemy. Most DoD employees work hard and are committed to their tasks. This system will change the way workers are paid, evaluated, promoted, fired, scheduled, and treated. These rules would create a system in which managers are influenced by favoritism rather than serving the civil concerns of the American people. The job will be to keep the supervisor happy, rather than doing the job. “Friend of the Supervisor” Pay System: With the new patronage pay system, which DoD calls “pay for performance,” the amount of a worker's salary will depend almost completely on the personal judgment of his or her manager. When NSPS has been completely implemented across all levels of supervision, I see this patronage system cutting the experienced, hard chargers, from consideration for advancement because they do not conform to the current “vision” of how we should do our tasks. Remember the old saying: “What would a horse look like if developed by a committee?” Answer: “A Camel.” NSPS will cement this system in place by regulation! Any chance of original or “out of the box” thinking will be completely eliminated. This new patronage system will further destroy teamwork, increase conflict among employees, and reward short-term outcomes. There is no guarantee that even the best workers will receive a pay raise or that the pay offered will be fair or competitive. This system will create a situation in which workers are in conflict with one another and afraid to speak out about harassment, violations of the law, and workplace safety problems. Furthermore, there will be no impartial appeal system to assure that everyone is treated fairly. Many of us are content to do our jobs, stay put and become an expert in our area, with no ambition to manage (Frowned on by DAWIA, which recommends rotation every three years. The “experts” are retiring, and there are only unknowledgeable “managers” to replace them.). This situation is stacked against the war-fighter now. The NSPS system will further erode their support. We are heading toward the old political patronage system with this change!