| Comment Number: | OL-10509980 |
| Received: | 3/15/2005 10:41:34 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 would like to comment on the proposed NSPS for DoD. I have worked for DoD for 15 years as a teacher in both DoDDS and DDESS. During this time I have worked for several administrators achieving 15 fully successful, or better ratings. On occasion I've had to go to a union representative for clarification of the implementation of new programs, or to represent my views to management. This has been a valuable "check" to the system and helped "balance" the needs of management and my personal needs. Our whole system of government works on the bases of having checks and balances. The NSPS will weaken the protection from abuse that the union provides, thus removing the “check.” It would make the employees’ position meaningless compared to management’s position, thus invalidating the “balance.” Without meaningful union representation workers will be at a much higher risk for abuse, with little or no recourse. If the NSPS system is truly about rewarding high performers, all teachers in DoDEA should receive a substantial pay raise, as DoDEA’s students test scores rank at the top of the nation. However, the new system appears to leave the decision of which teachers are deserving, solely up to how his or her immediate supervisor perceives that teacher’s contribution to the overall success. It specifies no set objective criteria for making those choices. To leave this up to management makes it subject to the fallibility of humanity. The union contract is there to enforce the objectivity of the Civil Service Act. There does not appear to be any “check” on the subjectivity of NSPS. The Civil Service system has protected all of us equally and established a system to deal with the low performers. It has done a very good job in getting people equal treatment regardless of viewpoint while maintaining a high level of objectivity. NSPS could propagate an atmosphere of favoritism, cronyism, and narrow viewpoints; thus reducing the creativity that comes from entertaining opposing ideas. This could destroy the 50 years of progress in workers rights provided by union representation and guaranteed by the Civil Service Act. I can understand a need for a different type of system for our newly established Homeland Security and even for those agencies directly involved with that Security in these troubled times. However, I do not understand the need for such sweeping changes to other DoD systems not directly involved. I especially do not agree with a change that abrogates so many workers rights, protections, and due process. We trust in a proven system of checks and balances, not the NSPS which relies solely on one point of view. If the system needs to be modified, let those changes come about through the combined efforts of labor and management. Sincerely, Barbara Bryant