Comment Number: OL-10510266
Received: 3/16/2005 8:21:18 AM
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:

The justifications for this proposal are based on totally false premises, and the whole proposal is detrimental and unnecessary. One can only hope beyond hope that this will be totally scrapped. Does that ever happen, that comments are actually considered, and officials realize they were wrong and say "never mind"? The most glaring false justification and canard is the line under The Case for Action that says "The attacks of September 11 made it clear that flexibility is not a policy preference". What does September 11th have to do with any of this? It is inexcusable to try to use September 11th as a reason to gut the Civil Service system. As for the complaint that DoD sometimes uses military personnel or contractors where civilian personnel should have been used, what situations is this talking about? What kind of jobs is the DoD wanting civilians to take over that they couldn't hire for now? Is this about the many contractor jobs that are in Iraq that people willingly signed up for, knowing the great dangers they faced? Do you want to force a mechanical engineer to become a supply clerk, security guard, truck driver in Iraq? Let's be clear on just what you want to do. As for having us be "easily sized, shaped, and deployed" mentioned underGuiding Principles and Key Performance Parameters , what does that mean? One can only assume the worst, that the Government wants to be able to fire us at the drop of a hat just like the venerated private industry, or to ship us off to Iraq or anywhere else in the world for however long the Government wants. We had Operation Desert Storm where the Government miraculously was able to hire in great numbers. We've had Reductions in Force, Voluntary Early Reduction Authorities, and Voluntary Separations Incentive Pay enabling the Government to "size and shape" the workforce. So, what is the Government now looking to do differently? How do you define flexible and comtemporary? mentioned in Labor-Management Relations—Subpart I. Is that contemporary with other Democratic Governments around the world? Comtemporary with exactly what? And "flexible" is just another way of saying "change the rules at any time in any way". Now, the DoD is not at all limited in regard to "• The methods of assigning, reassigning, detailing, transferring, or promoting employees". mentioned in Authority To Establish a New HR System How is it an improvement that all of a sudden one can be transferred across country or another part of the globe, assigned to a totally different position, reassigned to yet another totally different position? The notice says in The Case for Action that currently high performers and low performers are paid alike. This is another lie. A poorly rated employee does not get rewarded the same, if at all, as a highly rated performer. New pay system (Performance pay pools,Pay and Pay Adminstration - Subpart C) the amount of money in the pay pool is very nebulous. It says "normally based". So, when would it be other than normal circumstances whereby it wouldn't be "based" on the criteria? Saying it is "based" on doesn't mean that it will "follow" what is listed, and saying "normally based" makes it even more questionable. And one's pay would be dependant on how one lucks out as to what pay pool you get put in. The best scenario would be to be in a pay pool with high salaries that are not maxed out in their grade, and for them all but you to be poor performers. That way plenty of money will be available and your share range will be worth more. This would not foster a cooperative environment. This whole matter was shoved down Congress's throats. It was lumped in with the Defense bill so as to make it next to impossible for them to vote it down. We should be in the business of promoting Democracy in our country, as well as the rest of the world. Instead, we're granting carte blanche dictatorial powers to the Secretary of Defense. This whole proposal should be totally thrown out the window!