| Comment Number: | OL-10509680 |
| Received: | 3/15/2005 4:58:36 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:
Topic: Regulatory Review Reference E.O. 12866 Comment/Requested Clarification of Intent: Referenced Executive Order reads that it is estimated that the cost of developing and implementing the Human Resources system and the creation of the National Security Labor Relations Board (NSLRB) is 158 million through FY 2008. References are made without any amplification of the intent “Less that 100 million spent in any 12 month period”. What does this mean? Are these monies appropriated for FY 05 to begin system design and implementation? Does this figure simply include paper regulation, how many personnel to run this system, at what levels, what is the budget proposal for beyond 2008 to maintain this separate system? This is a confusing statement if the estimate is to complete the system design and the relations board with 158 million, why does it mean by no more than 100 million can be spent in any one 12 month period? Is this 158 million purely for the establishment of the administration? What appropriations will be set aside for any performance payout, or are they inclusive in of this amount. If so, what interfaces with pay out agencies will be established to ensure priorities will be established for the controlled expenditures. It is understood that this system is purported to cost much less in the long run because there will be less legal expense paid out due to the new flexibilities and improved labor management process resulting in more efficient and faster resolution of workplace and labor disputes. It appears that these saving will be generated by ignoring any labor rights that might be raised by employees, decentralizing the control authority to the organizational level and eliminating the need for Human Resources bargaining and benefit systems. We the DOD, have right sized, decentralized, outsourced, and streamlined so much of our Human Resources systems and Human Capital that our workforce is are strained as it is. Controlled by management by objective, and budgetary constraints, we are losing the ability to attract, build and retain this high performing workforce, focused on effective STRATEGIC mission accomplishment. Instead, we find ourselves pushing a rope up hill everyday trying to figure out what our next surprise will be and how to continue to perform our jobs in a highly proficient manner when the very basis of our personal security systems are being undermined and threatened by the subjections of an undefined, unrefined management system. We are workers of DOD but we are not the military. At least in the military there are congressional committees to take care of those individuals. We are not a part of the Non Judicial Punishment System, but in essence, with this newly proposed system, we fall under a similar set of regulations. “We have little to No Rights” The sad thing is, probably half of our 700-900 thousand personnel don’t even know that this NSPS is taking place, and what it will entail. We’ll be off to a good start! No case history to base complaints on, no implementing regulations to read and understand, no HR officers that are adept at using the new system, no merit step increases to keep pace with inflation, other laws recently enacted, no overtime for those making over 26K per year. All we can hope is that we receive ONE STRATEGIC OVERARCHING OBJECTIVE TO ASSES OUR PERFORMANCE BY, AND ASSESSMENT GOALS and BEHAVIORAL REQUIREMENTS ARE STANDARDIZED THROUGH CODES OF CONDUCT, ETHICAL AND REGULATORY STANDARDS, AND THESE STANDARDS ARE NOT DECENTRALIZED LINES OF AUTHORITY TO THE ORGANIZATIONAL CULTURE FOR PERFORMANCE ASSESSMENT AND GRADING.