Comment Number: OL-10509297
Received: 3/15/2005 2:21:09 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:

Please bear with me, my comments are detailed and fall into four areas: 1) The Civil Service is just that service: service to country, the public trust, and to the community. Nothing in NSPS ensures that civil servants will maintain the necessary independence to serve the public good. If it's pay-for-performance and political appointees define performance, who will protect the public's interest? Remember it was a civil servant who brought an end to the illegal placement of contracts by political appointees during the Reagan Administration - Operation Ill Wind. 2) If DoD managers are having problems implementing the current performance system, why give them a new and more complex, that is nuanced, system to execute? A family member worked for the INS out of college and was put in charge of all hiring and firing when he reached the GS-11 level. All his recommendations for hiring and firing stuck because he DOCUMENTED everything; this was not a lot of writing, it was merely listing his actions, time and date, and the reasons. This family member was hired by the INS when the majority of the Civil Service was filled by the best performers on the PACE exam. From my experience, it appears that the decline in supervisory-know-how to implement the current Civil Service performance system has been concurrent with hiring by grade point average (GPA) as an indication of ability rather than the reasoning and computational abilities previously sought by exam for the Civil Service. 3) When I came to the Civil Service, there was a glass ceiling for women at my DoD agency at the GS-12 level. The phrase "we promote in our own image" became relevant to me in watching how no women advanced in my agency. There were few to no women in upper management and they weren't generally viewed as in the running. If the more complicated NSPS is implemented, it will be more difficult to see the glass ceiling and get through it. 4) One of the major proponents of DoD currently, is Michael Wynne, a former CEO (or President?) of General Dynamics Land Systems. I view his proponency as a conflict of interest. It was reasonable and independent Civil Servants who negotiated with him to price the Abrams Tank. It was reasonable Civil Servants looking out for the taxpayer who said, "No," to him when he wanted the Government to pay for higher cost office space. A strong Civil Service looking out for the "every-man" is not consistent with the interests of large corporations and the men who head them. Unless Mr. Wynne has agreed to stay in the public sector, he should recuse himself from advocating for the NSPS. Civil Servants' performance will be able to be unduly influenced by those with more money, power, and political connections under NSPS. NSPS will totally undermine a Government for the people and by the people.