| Comment Number: | OL-10509482 |
| Received: | 3/15/2005 3:41:53 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:
The following are comments that I feel affect myself and others as civil service employees. I feel our rights are being taken away from us and unfair finance decisions are being made! 1. NSPS changes and limits the core principles of federal employment law and regulations. 2. NSPS trial used only 4% of federal employees. 3. NSPS did not post the results of the limited trials. 4. Two years of testing with Department of Homeland Security results were not disclosed. 5. NSPS will severely limit employee ability to organize and bargain collectively. 6. NSPS will not ensure that all affected DOD employees are afforded due process protections. 7. DOD has usurped authority from OPM and congress in creating NSPS. 8. DOD has not followed the 30/30/30 process. 9. NSPS does not clearly identify the classification system to be used and how it will be implemented to treat current employees fairly. 10. Pay band salary data is missing from Table 1. 11. Correlation of NSPS Bands to GS pay schedules are not shown. 12. NSPS does not identify “artificial distinctions between closely related levels of work”. 13. NSPS allows employees to “request” reconsideration of classifications, but does not guarantee a fair review by impartial personnel. 14. No funding increases for implementing NSPS. (Training costs will be horrendous and unfunded) 15. NSPS does not have additional funds for implementing pay adjustments without taking pay from some employees and giving it to other employees. 16. Methods or means for changing pay bands is missing. 17. Total disregard for implied employment contract under CSRS and FERS between employee and Government. 18. Employee competition pools seem to be gigantic and may include many USACE districts or divisions, 19. Upward mobility employees who are due within grade increase have been ignored. 20. Within grade increases for upward mobility people are not identified. 21. Severely limited employee rights to collective bargaining. 22. Eliminated the due process rights that enable employees to speak with confidence when they see wrongdoing or mismanagement. 23. NSPS asks the employees to TRUST DOD Secretary and senior staff to ensure that their best interest is represented. 24. NSPS, without additional funding, will not have equitable raises for highest performing employees without downgrading or removing average performing employees. 25. Current system budget constraints severely limits first line supervisors ability to make performance award. NSPS will magnify the negative aspects of first line supervisors ability to get high performing employees raises. 26. Senior Army Office told us that the lack of details was intentional in an effort to thwart unions. 27. NSPS will expand the “good ole boys” network. Supervisors will be able get rid of questioning employees and hire “good ole boys” without the current open and equitable consideration constraints. 28. NSPS states longevity will no longer be a key factor in determining employees to be removed during a RIF. Older employees typically are receiving higher salaries and this could be a factor in their being selected during a RIF process even though they are quality performers. 29. NSPS states that no one will lose money during the conversion. However, at the FAA, where pay banding has been in place for a few years, 47,000 employees were “capped out” at their current salaries and are not allowed cost of living raises until such time as cost of living raises catch up to their current salaries. 30. Grading performance is never objective. 31. Having all potential for salary increase riding on your performance appraisal will create adversarial relationships between co-workers. 32. NSPS does nothing to help with national security 33. Under NSPS, DoD civilians can be assigned anywhere in the world, even to a war zone, with little or no notice. 34. I will lose my benefits under NSPS. 35. Seniority will no longer count in the event of a red