| Comment Number: | OL-10509907 |
| Received: | 3/15/2005 8:51:34 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 find it difficult to make specific comments on any section within 5 CFR Part 9001 without the ability to review the DOD implementing issuances. It reads as general guidance and fails to address the specific "Unknowns" important to career DOD employees. A fundamental academic principal for developing a personnel system is to put people first. As stated on page 7555 of the Federal Register the guiding principles put “mission first” and do not emphasize the importance of people other than their legal rights under NSPS will be respected. Very hard to determine what their legal rights are under the proposal. The system was obviously developed using acquisition reform principles. Principles designed for developing software, equipment and weapons systems. As stated on page 7555 of the Fed Register "Key Performance Parameters will recognize High Performing Employees". Will measurements of Employee performance be gathered similar to collecting data on a weapon system performance as it processes through research, design, development, test, production and fielding phases? What methodology will be employed to measure employee performance and behavior? How will management be trained to a standard system of measurement and not apply subjective judgements? Who will provide the training and what are the impacts to current mission in respect to resource requirements to spin up management and employees to the new system? I find most disturbing the clear intent of the system to deploy civilians in contractor and military personnel (people who have volunteered to deploy) positions as needed. Why the change from a voluntary system, I know, mission first.