| Comment Number: | OL-10509647 |
| Received: | 3/15/2005 4:51:30 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:
I am a career member of the U.S. Civil Service with 28 years of service, 25 of them in DOD. My comments center around 2 major concerns. 1. Politicization of the civilian workforce. (Staffing and Employment - Subpart E, and Workforce Shaping - Subpart F.) The current political leadership in DOD (and they are deep within the management structure) seemed unable to trust the career staff when they first came on board, unaware, perhaps, that some of use have faithfully served a number of Presidents and their administrations. a. It appears one intention of NSPS is to be able to change out the civilian workforce each time a new administration comes to power. Will this be an (un)intended consequence? b. Page 7553 of the draft proposed rule in the Federal Register states, “The Department sometimes uses military personnel or contractors when civilian employees could have and should have been the right answer.” Such as? And whose fault was that? If the new political senior management doesn’t want to use the staff in place (inherited from previous administrations) what are we to do? 2. Assignments. (Subparts E & F.) a. The new rules propose a more flexile hiring, firing, and reassignment structure. Some of the workforce has spent considerable time and education developing a specific expertise (e.g., proliferation). What will serve as checks and balances to management in reassigning people to jobs for which they may not be trained or educated or which they do not want? How much choice will a civilian have if he or she does not wish to be reassigned to a particular job? b. Will civilians be forced to choose between leaving government employment or being forced to move out of a specific locality? Will people be assigned to jobs they may not want with the expectation that this will cause them to resign? Should civilians expect to be assigned to combat zones or other unsafe areas of the world?