| Comment Number: | OL-10509750 |
| Received: | 3/15/2005 5:37:24 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 believe the proposed NSPS regulations will undermine the civil service and hurt the ability of DoD employees to accomplish the agency's mission. As published, the proposed NSPS regulations lack critical details on how various aspects of the new system will operate. Relying on implementing issuances denies the American public the opportunity to offer substantive comments on NSPS and does not provide the requisite transparency Congress needs to carry out its oversight function. Please consider the following comments and delay final implementation until the proper steps have been taken to effectively involve the elected representatives of DoD workers and the public. In the supplementary Information section of the proposed regulation under "The Case for Aciton", Mr. Rumsfeld states that the old system of "one-size-fits-all system of defining work, hiring staff, managing peopl, assessing and rewarding performance..." are "inherent weakneses". This may be true, but changing over to the new system is built on the military way, which if I was in the military would be fine, that's what I joined into. However, the civilian work force for DoD isn't in the military perse and should not be governed by the same principles. I feel that if the proposed regulations are implemented it will not retain workers it will force them to leave to a more stable and worker friendly system that exists elsewhere in the Govt. Furthermore, in this same section it is stated that Public Law 108-136 provides DoD authority to develop and deploy a new HR system, however as shown thoughout the proposed regulation that much work is still remaining on just about all aspects of the regulation. How DoD could possibly hope to deploy such a system without the very critical portions missing is beyond me and the common man/woman. Another key statement in this section is related to the retention "of the core values of the civil service" and yet it is intent on shatering the core of the civil service system and establish what appears to be a dictatorship system in which DoD can do whatever it deems to do without anybody except themselves to monitor the situation. General Provisions - Subpart B: Classification, Removing the standard classification of positions will make it very difficult for personnel to move between agencies within the Fed. Govt., that must be how they will retain personnel in DoD. Also, since these new classification systems have not been developed yet it is impossible to comment on them. These items need to be addressed and commented on prior to implementation. Subpart C Pay, DoD employees should continue to receive the same annual pay and across-the-board adjustments that other GS/FWS workers receive. These type adjustments are not performance based and the only reason not to give them to the DoD civilian is to ensure this new system has zero budget impact. If we are to be like the military we should receive the same adjustments they get. The individual pay increases for performance in the regulations need to be detailed out so the public has a chance to comment on them and you have some understanding on what you can attain with good performance. The proposed pay bands need to adjust annually with any across the board or cost of living adjustments. These pay bands need to be established prior to implementation. The broad occupational career groups proposed to replace the current job descriptions need to be established prior to implementation so the public can comment on this as well. The proposed pay bands result in a cap on salary increases weather or not you are perfoming well. Once you are at the top of your band you can no longer receive pay increases until somebody in DoD decides to raise the limit, if they don't you only receive one time payments will affect your potential retirement since this is based on your high three which you will no longer be able to plan for. ELIMINTE THE NSPS for DOD or DELAY