Comment Number: OL-10509539
Received: 3/15/2005 4:06:16 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:

This is simply a bad idea. The premise is that we civilians are NLCs - No Load Civilians, who contribute little to the missions of the agencies within DoD that we serve. The emphasis is on the word "serve." I would note that we "serve" side-by-side our military counterparts. I would further note that while indeed, some military are deployable in direct combat and indirect combat support; not all are. Those positions have always been subject to being civilianized or A-76. Yet, the impression and implication of the NSPS is that inorder to enhance the "flexibility" of the Department we no load civilians must be put under a "performance based" appraisal system that has all the trappings of a "controlled OER" system from the military. I do not need to wear a blue suite to be patriotic. All this does is create a pure patronage system whereby individuals are tied personally to the supervisor to ensure they receive a good rating - which ensures they get a pay increase. Meanwhile the military members working side-by-side still have an inflated system that credits them with "maximum performance". Have you ever critically examined a military OER? We "serve" with honor. Please do not install a patronage system that gives too much authority to the Department!