Comment Number: OL-10509946
Received: 3/15/2005 9:36:54 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:

First let me say “pay for performance” is similar to “motherhood and apple pie” it is hard to be against. However after reading the proposal in the Federal Register I have serious concerns. First the published rule is totally conceptual and does not define how the system will work concerning pay for performance, promotions, what is good or bad behavior, how people will be reassigned to different locations and how the program will be funded. Without specifics it is impossible to provide meaningful comments. As written we could be on the road back to the patronage system where good behavior is working for the party and not disagreeing with the executive branch. The good old boy system could block career paths with hiring from the outside based on support of the party destroying morale of career employees. Pay needs to be fair and positions filled with the best qualified. Based on the lack of specifics in the current draft proposal a new proposal with details of how the system will operate should be prepared with full involvement of the labor unions. The new proposal then should be published in the Federal Register for 60-90 days giving all employees, stakeholders and citizens an opportunity to comment on a very complex and complicated issue. Another concern is funding in the US Army Corps of Engineers Civil Works Program. Some Corps organizations are scheduled to deploy in the first tier. The Corps Civil Works budget is part of the Energy and Water Resources Appropriations with funds appropriated to projects to accomplish work. There is no specific amount appropriated by Congress for labor. Therefore funds appropriated for a specific project may be shifted to another project over even across appropriations through pay pools reducing the funding appropriated for a specific project. In addition the cost of administering the pay pools is certain to be much higher than the present system, further reducing dollars to do work at a specific project. Also this may create higher costs for our cost share partners who already say the Corps is too expensive and slow. Until this is satisfactorily addressed which may take a change in the way the Corps Civil Work’s program budgets, the Corps Civil Works program should not be included in the NSPS program. Since pay raises are now dependent on performance evaluations, the system is certain to be more complex than the present system in an effort to document why one employee is paid more than another. Employees who feel they should be paid more are certain to complain. The government is not the private sector where salaries are often kept secret. This will take more time from Supervisors. In the Corps Civil Works program, supervisors have been reduced significantly in the last fifteen years. In addition to being the supervisor over a number of employees they must still do work. Under this system more supervisors will likely be needed plus the existing ones will have to reduce their non supervisory workload. This again will increase costs and take funds away from accomplishing the work projects funds were appropriated. Another concern is it appears under the proposed system civilians may be ordered overseas or to war zones. If that is the case this should not apply to current employees unless this was a prior condition of employment. The Civil Works side of the Corps has provided large numbers of volunteers to work in Iraqi and Afghanistan however there is a huge difference between volunteering to go and being ordered to go. The Corps Civil Works Program is very similar to that of other non DOD civilian agencies and should not be in a system that can order them overseas or to a war zone. It should remain a civilian agency.