| Comment Number: | OL-10509914 |
| Received: | 3/15/2005 8:57:31 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:
General: The proposed NSPS will undermine the Civil Service and hurt the mission of DoD Employees. It is ill thought out and not even completed in details, thus making it a bad joke for most part. Subpart C Pay, Sections 9901.301 to 9901.373 The employees in DoD should continue to continue to receive the same annual across-the-board adjustments that other GS/FWS workers receive. A change in pay systems is not causing our appartment rent, house rent, food, gasoline, etc. to not go up at or above the pay increases authorized. A change in pay systems certainly should not carry with it the authority for DoD to arbitrarily lower that amount. Too much power in too few hands will lead to favoritism, ethics violations and various other corruptions. Let Congress decide the pay employees receive. The individual pay increases for performance should include guaranteed percentages in the regulations so employees will understand the pay system and what their pay increases will be depending on their performance. Remember: Managers could not handle the current system even with years of experience. How can they be expected to properly and fairly increase pay under a pay for performance system? Subpart D Performance Management - 9901.401 to 9901.409 In order to insure fairness and accuracy, DoD employees must be able to appeal any performance rating to an independent grievance and arbitration process like they can do now. To keep it "all in the Family" is to encourage the so called 'good old boy' system to come full blown back into existence (not that it is dead) and in charge. Very demoralizing to employees! Subpart F Workforce Shaping - 9901.6012 to 9901.611: Dod should not change the current layoff/RIF rules with give balanced credit to performance and the employees valuable years of comitted service to DoD. Subpart G Adverse Actions: Due process and fairness demand that the independent body reviewing a major suspension or termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor-Management Relations - 9901.901 to 9901.929 Curent labor management law that has governed the employees' right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away any collective bargaining rights or grievance rights. DoD should not create a 'company dominated dispute board.' Any dispute board must be 'jointly selected' by management and the union. Closing Remarks: Pay issues are important and the arbitrary setting of pay, the renaming of Locality Rate to Market rates are poor planing. Knowingly trying to go ahead with NSPS on a "we'll let you know the rules after we make the system a Fact is just plain stupid. The current system is not broken to the point of needing to be replaced. It does need some fixes. Unfortunately many of the fixes needed are fixes to Management. Management has failed us so now we are replacing the System, Retaining the Failed Managers and telling the Emplyees how lucky they are to have a new improved System! Please rethink this system if you must proceed with it. Trust your employees. They may suprise you!