| Comment Number: | OL-10510434 |
| Received: | 3/16/2005 9:37:16 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:
Federal Register, Monday, February 14, 2005, Part II Department of Defense Office of Personnel Management, 5 CFR Chapter XCIX and Part 9901, National Security Personnel System; Proposed Rule. In general this entire proposal should be abolished even before it is implemented. First, under this system it is quite possible that an employee can be placed in a pay band that include former GS grades 05 through 09, and although the employee is receiving a GS 05 pay, management can demand that he or she does the work of a GS 09. This is pretty close to the days when two men, of different color, would be working side by side doing the same job, yet one would be paid $2.00 per hour and the other would be paid $1.00 per hour. The only different was the color of thier skin. We do not want to return to days of getting paid according to how much your "boss" likes, or dis-likes, you. It took the works of many people to organize and form unions. And becuase of the union's right to negotiate, employees obtain the right to 40 hour work weeks, overtime pay, notice of pending removal, transfers, shift changes, etc. Now our Secretary of Defense, as outlined in the Register wants to take all of this away with a mere stoke of a pen. I implore you to prevent this from happening. Page 7565, #3 Adverse Action Procedures. Please note that DoD is severely limiting the notice of pending adverse action, yet it the time frame for management to gather the neccessary information to take such actions are noticebly missing. Management can take six month to take an action, and the employee only has fifteen days before he or she is fired. Actually, you will notice that few limits are placed on management through out the entire register, while DoD has no problems limiting the employees and their unions. I refer to the "Myths and Facts" email that was send out by OPM, under benefits it says, "Myth, I will lose my benefits under NSPS. Fact, NSPS will not affect rules governing retirement benefits or eligibility, health and life insurance, leave, attendance, and other similar benefits." I beg to differ. If an employee is unjustly terminated and the Secretary refuse to reinstate him/her, the employees all of the above. And all because the mood of a single person on any given day. Page 7562, 3rd colum, 1 paragraph, and 7584, 3 colum, Subpart D Performance Management 9901.401 Purpose (5), although it says that supervisors, managers, and employees will be trained, it does not say that this will be completed before the implementation of this system Remember this is to start in July 2005. Will this be a learn as you go process? If so, at what cost to the employees and their unions. Page 7571 1st and 2rd colums, Other than surface bargaining, the right to bargain is all but lost. I do not know any union that will put the nation at risk under any circumstances. Since 1978, the negotiation process, including the use of the independant third parties, has worked quite well. Fair and balance negotiations are important parts of any successful Labor-Management Relations. I don't understand why the Secretary and this administration just will not come clean and say that their pirmary goals are to bust all Federal Sector, then, Private Sector unions. What purpose will be served if the union negotiates in good faith and management waste time, then the parties submit their best and final offers to a DoD hand picked panel to decide which offer to implement. As management once said following the implementation of the CSRA, "we have lost our sure fire wins because now ULPs will be handled by an independant third party, not by us anymore." Now they are sure to say, "we have gotten the power to abuse back again." All employees under this management has all power system will surely lead to unjust terminations, lowering of morale, fear of not knowing what to expect next, hand picked favorites getting all rewards and bonuses. Please void the system.