Comment Number: OL-10510514
Received: 3/16/2005 10:16:43 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:

I have a number of general comments/concerns with the proposed NSPS regulations. I believe that supervisors who claim that it is too difficult and too cumbersome to adequately discipline employees under the current GS system are simply making excuses based on the common "urban legend" that it takes an Act of Congress to remove a federal employee from service. Overall, I see the NSPS as a way for supervisors to capriciously monetarily penalize or remove employees from federal service. I also see NSPS as a mechanism for managers to offer external candidates higher rates of pay and more benefits than existing federal employees. Since seniority has no place in NSPS, the federal government would be allowed to act in the same morally repugnant manner as have many large corporations by firing older employees, ostensibly because the younger employees have the "desired skill set" which is "lacking" in the older employees. Firing older employees would, of course, be couched in appropriate language to indicate that the older employee was not performing as well as the younger employee, but would really be a thinly veiled way for management to save money by eliminating those employees who would soon be drawing full pensions. I think that the current practice of retaining employees based on BOTH seniority and on performance is a perfect formula and should NOT be altered. NSPS reduces employee incentive to move to a new job in a new area if one is an "expert" in their existing area because they would move from the "expert" level of their pay band to the "novice" level of their pay band and would thus lose money in the process. Since there would be no incentive for employees to move to new areas to work, exchanges of ideas and skills between areas would decrease and workplace stagnation would occur. I also take exception to the use of "local market factors" in setting the pay band ranges. Recently, Chillicothe was added to the Columbus region for purposes of setting locality pay. Chillicothe is a far poorer area than Columbus with a higher rate of unemployment (true unemployment, which includes folks who have fallen off the unemployment roles because their benefits have run out and they are STILL unemployed) and a lower cost of living than the Columbus/Franklin County region. In past years, locality increases for Columbus were in the upper third of the range of locality rates. I believe that the reason that Columbus received one of the lowest locality increases this year was because Chillicothe was added to the Columbus locality. I believe that pay bands will be factored lower for Columbus also, if Chillicothe remains in the Columbus locality. Chillicothe and Columbus are light years apart in terms of standards of living and cost of living and should NOT be lumped together for purposes of calculating rates of pay. On the whole, I think that the NSPS system is an imperfect system that will be replacing another imperfect system and, I feel that much money will be wasted in the process with few benefits gained. It is being ram-rodded through by the current administration to enable them to hire business cronies to federal positions with hirer rates of pay and greater job security than existing, loyal, hardworking, dedicated employees. I hope that someone has the courage to stand up and reveal the weaknesses in the proposed system before it is implemented.