| Comment Number: | OL-10509316 |
| Received: | 3/15/2005 2:27:09 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:
In reviewing the Pay and Pay Administration - Subpart C portion of the Proposed Rules, I am very concerned with the new pay system proposed for DOD civilian employees. I came to DOD from the Department of Agriculture. I know other DOD employees who have come from other federal agencies outside of DOD. As well, I know many former DOD employees who transferred to non-DOD federal agencies. My concern is that with this new pay system for DOD, it will be much more difficult to transition across agency lines in the future. Under the current GS pay system, which is common among all federal agencies, it is easy to compete at a certain pay level because a GS-11 with DOD is comparable to a GS-11 with the Bureau of Land Management. Once the new DOD pay system is in place, will the other agencies know that someone applying for a GS-11 position is qualified (and has performed at a similar level) when they are in this other system (that might not be understood by the other agencies)? As DOD civilians, we are an integrated, flexible, and responsive part of the team. Not only part of the DOD team, but of the federal team. We want to be able to compete across agency lines, because we have much expertise to offer for our Nation (and all of the agencies serving this Nation). Additionally, under the proposed performance-based pay system, how will performance evaluations be comparable from rater to rater (supervisor to supervisor)? One supervisor will judge his employees differently than another supervisor will. Some sort of consistency between raters must be established prior to implementation. Impartial judgement is a difficult trait for humans to develop. It must be realized that many DOD civilian positions are inherently non-military in nature, such as foresters with the Air Force, engineers dealing with navigation on waterways, Corps of Engineers park rangers providing recreation opportunities at flood control resevoirs, etc. Perhaps this plan would be a better fit for DOD if these non-military civilians remained under the current GS system. That would eliminate my first concern noted above. Finally, please don't forget that the many dedicated civilian employees of DOD have lives outside of work. We have families, we are involved with our communities where we live, we have hobbies and friendships outside of the work place, and although we remain dedicated, many of us leave work at work when we go home and forget about it until we return to the office the next day. We are happy to serve where we are and do not desire to be treated as an object to complete the mission. We are human and must be treated as such. Thank you for allowing me to provide my comments. Please consider them, as well as every comment you have received, prior to directing the implemention of this new program.