| Comment Number: | OL-10509608 |
| Received: | 3/15/2005 4:36:45 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:
Subpart A: General Provisions Section 9901.104 is misleading. It states that only the specific chapters of title 5 of the U.S. Code listed there may be waived by NSPS regulations. Doesn't the NSPS law, 5 USC 9902(b)(5), state the NSPS “shall not be limited by any specific law or authority under this title [title 5, U.S. Code], or by any rule or regulation prescribed under this title. . . “ So, are more laws and regulations on DOD’s chopping block other than the laws listed in section 9901.104? Are among them the laws on hours of work and alternative work schedules (5 USC Ch. 61), the laws on annual leave, sick leave and family and medical leave (5 USC Ch. 63), the workers compensation laws (5 USC Ch. 81), the retirement laws (5 USC Chs. 83 and 84) and the laws on life insurance and health insurance (5 USC Chs. 87 and 89)? The proposed regulation lists 5 USC Chapters 33 and 35 as waivable. Doesn't this include veterans preference in hiring and veterans preference in reductions in force? Within the regulations that DOD may waive are the regulations on promotions (5 CFR Part 335) and reductions in force (5 CFR Part 351). Congress really needs to take a second look at these portions of the NSPS law. How does "waiving" veterans preference provide any benefit to the DoD? With the current strains on the uniformed side of DoD, now is the wrong time to allienate and endanger the future DoD civillian workforce. NSPS is perfect if you want a transient non-dedicated cadre of folks just "trying out a job",looking for something they like doing. But will they feel the loyalty that the current rules promote? Loyalty to the workforce promotes loyalty to the job. Current civil service rules promote a stable dedicated, loyal and most importantly, an experienced, workforce. Those rules were a main reason I chose my current career path. After NSPS , current career employees will simply feel betrayed. 10 years from now, when most current employees are gone, will be the wrong time to find that a transient, temporary workforce is a bad idea when the soldiers need stable support. It'll come to light just as the shortcomings of supplementation of the active force with Guardsmen and Reservists has, it looks good on paper........till there's a war. That said, I personally expect to benefit financially from NSPS, possibly greatly. The big change will likely be in job satisfaction. My motivation will shift from any mission focus and patriotism and will instead be driven by possible monetary gain. I currently lead a group of focused, engaged, individuals, but in the future I expect to see much less teamwork and much more individual "one-up-manship", back-stabbing and parochialism.