| Comment Number: | OL-10509340 |
| Received: | 3/15/2005 2:38:55 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: I believe the proposed NSPS will undermine the Civil Service and hurt the mission of the DoD employees. Subpart C Pay, Sections 9901.301 to .373: The employees in DoD should continue to receive the same annual pay across-the-board adjustment that other FS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending on their performance. Subpart D Performance Management-.401 to .409: In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. Subpart F Workforce Shaping .6012. to .611: DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employees valuable years of committed service to DoD. Subpart G Adverse Actions-.701 to .810: Due process and fairness demand that the independent body reviewing a major suspension as termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor/Management Relations .901 to .929: The labor management law that has governed the employees’ right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a “company dominated dispute board.” Any dispute board must be “jointly selected” by management and the Union. Subpart B-Classification-9901.201 to .203-I have not seen or read anything that supports why these NSPS changes are needed in such drastic measures. This appears to be out and out union busting. I really can't see or understand how my job classification or pay has anything to do with national security. This seems to be an attempt to expand my duties and responsibilities for the same or less pay. I suppose every job description will have the words deployable asset in their content. Adverse Action-Subpart C-9901.701 to .721-This new NSPS system will destroy due process and any fairness in treatment and representation that DoD employees are now entitled to. I believe that mission requirements are important, but the principles of just cuase are just as important. If these proposals are implemented as they are written, I will become a second class citizen because all my rights will be stripped away.Labor/Management Relations-Subpart I-9901.901 to 929-This entire section is out and out union busting. I cannot think of one instance where DoD employees and unions have not worked together to provide support to our war fighters. I cannot think of any instance where a negotiated agreement or union has been a hindrance to national security. This might seem odd, but this entire NSPS concept was drafted up by one political party (Republican) with no unions being allowed to actively participate in this process. I believe that unions should be able to bargain and negotiate matters concerning appropriate arrangement of affected employees. I feel very strongly that unions should retain the right to bargain and not be reduced to a consultation with management. Sincerely, Bill Olsen Sincerely,