| Comment Number: | OL-10509328 |
| Received: | 3/15/2005 2:33:21 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:
General comment: As an employee of the US Army Corps of Engineers I am concerned about several aspects of the proposed system. The Corps is a cost reimbursable organization, we receive funds from various customers for services performed. In this regard; 1. Our budget for performance awards is tied directly to the funds generated for our services. Other agencies within DoD are not restricted to this type of funding constraint. In the great scheme of things, won't the Corps employees be penalized with a reduced pot of available funds to cover performance awards like we are currenly being penalized with no time off awards? 2. The fear exists, that based on the reality of reduced funds within the Corps for performance awards, performance evaluations will be artificially limited to meet the available funds budgeted for awards. When applying for other DoD positions, the usual request is to provide your most recent performance appraisal with your resume. This doesn't relate to a level playing field across the DoD. 3. I am getting mixed signals from the narrative "The Case for Action." I'm looking for an example of how the current system failed in response to the 9/11 attacks? I'm also getting mixed signals when civil servants are under constant barrage to privatize as many activities as possible but the narrative intimates that "civilian employees could have and should have been the right answer vs active duty military and contract employees". What is the reasoning behind these contradictions, are there specific examples available? 4. Under Guiding Principles the first one mentioned is "Put mission first" and in the KPPs "Agile and Responsive: Workforce can be easily sized, shaped and deployed to meet changing mission requirements;" Is this intended to make future deployments mandatory? 5. Also under the KPPs it mentions Fiscally Sound: Aggregate increases in civilian payroll, at the appropriations level, how does this relate to the Coprs employees? 6. When the dust settles and the "pay bands" are in place, are there any assurances that a particular Corps of Engineers band for, as an example, journeyman engineer, translates well to an Air Force pay band for the same discipline? I guess I am wondering if the pay bands will be standardized across the DoD? Standardized across agency boundaries? How would DoD bands compare to those established by DHS? 7. 9901.361General. This section addresses the ability to waive or limit "Premium Pay requirments. Does the DoD currently have this authority? What situations would DoD consider serious or urgent enough to require the waiver of premium pay?