| Comment Number: | OL-10509868 |
| Received: | 3/15/2005 7:52:41 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:
As a member of the Military Sealift Command (MSC), I am writing to voice my concern about the proposed implimentation of the National Security Personnel System (NSPS) on civil service mariners (CivMars) employed by the Department of Defense (DoD) on ships of the Military Sealift Command. The current CivMar system has evolved over the past 50 years and operates in the best interests of national security, it should not be altered by the proposed NSPS. NSPS is not appropriate for managing CivMars employed by DoD due to the uniqueness of shipboard employment. NSPS will create distrust and resentment, distracting the seamen from their jobs to engratiate them to their superiors, disrupting the fragile balance that the current system has been designed to support. Unlike almost all other federal civilian service employees, CivMars working on government ships perform under highly stressful conditions that more closely resemble those on board ships manned by the U.S. military – they go where they are ordered to go when they are ordered to go; they are away from their homes for lengthy periods and do not go home at the end of each day to see their families; and they daily perform dangerous tasks in support of the U.S. military. CivMars are also considered legally excepted service employees, as opposed to competitive service employees, and are prevailing wage rate employees not covered by performance management systems. The bottom line is that they are part of a time-tested system that works and, because of its uniqueness, should remain subject only to 5 USC 71. As history has demonstrated, CivMars play an integral role in supplying U.S. troops and citizens of war torn nations with necessary supplies, reconstruction and humanitarian aid, including most recently in Operation Iraqi Freedom I (OIF I), OIF II, OIF 04/06 and in the Tsunami relief effort. In fact, the current CivMars structure has saved the military millions of dollars while improving logistic reliability and fostered a partnership with DoD that has enhanced the vitality and viability of military sealift and of the U.S. Merchant Marine. The contribution that MSC brings to the U.S. Navy with the development of a pool of qualified mariners available to DoD in times of war cannot be duplicated by any other government agency. Weakening the ability of MSC to provide training and to recruit CivMars will have the effect of reducing the pool of qualified mariners available to DoD during times of war. The service MSC provides to DoD and to the nation is an important component of national security. The specialized knowledge and skills required of CivMars makes seafarers unique assets to DoD. MSC contributes to the DoD mission by providing the means for DoD CivMars to continually upgrade their skills and perform to the high standards set by the international maritime community. CivMars have successfully answered the call time and time again under the existing system. It is a proven system that works. The proposed NSPS system would only undermine that system, decreasing our military sealift capabilities and the pool of qualified mariners needed to crew those ships. NSPS would also reduce MSC’s ability to attract, develop and retain a robust pool of mariners to the detriment of national security and the degradation DoD’s missions. Therefore, based on the uniqueness of CivMars, and the critical role they play in national security, they should be specifically excluded from the requirements of the NSPS. Respectfully, T.P. Carway, Chief Engineer U.S.N.S. Leroy Grumman T-AO 195 FPO AE 09570-4095