Comment Number: OL-10510528
Received: 3/16/2005 10:20:27 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 am writing because of my concern about the National Security Personnel System (NSPS) scheduled for implementation for Department of Defense employees over the next year. NSPS was authorized under the 2004 Defense Authorization Act, passed by Congress in November 2003. However, I believe there is a significant difference between the skeletal authorities Congress approved and the authorities that Secretary of Defense Donald Rumsfeld is now jamming down the throats of all Department of Defense employees. The Secretary asserted that the Pentagon's broad mission requires greater "flexibility" in hiring, disciplining, compensating and assigning civilian personnel. All this "flexibility" is a smoke screen for allowing the military "managers" within the different defense departments to systematically eliminate individuals that do not meet their ideas. It has less to do with national defense than it has with allowing these uniformed "managers" in creating a department that fits their ideas. No one will disagree with anything a member in uniform says out of fear of losing their job. This system appears to me to allow the proliferation of discrimination based on an employees age. In short, the Secretary is demanding the same "chain of command" authority over civilian personnel as he enjoys over uniformed military personnel. Throughout all this hardball selling of the NSPS, no one has provided concrete examples of how the current system has impinged on the Pentagon's mission. Although Congress acceded to the broad requests lodged by the DOD, it attached certain strict conditions--including a specific requirements that DOD observe legal requirements of labor relations statutes and that they involve duly elected unions in the development of the new system. I do not believe that the DOD has done neither. Although DOD has convened "town hall" meetings to "brief incumbents", there has been no information sharing from DOD on exactly what problems management wishes to address with the adoption of NSPS. The Pentagon's stated objective in advancing NSPS is to construct a "pay for performance" system. This is deceptive and misleading. This system has been tested for over 20 years and the results have indicated that majority of employees felt cheated by promotion and pay decisions which were based solely on the discretion of a "supervisor". The process is designed to reduce salaries; the ultimate results have been lost to non-existent morale. NSPS is an autocratic system that ultimately is designed to eliminate employee redress for decisions made on the basis of bias, not merit. While I do feel that some change is necessary and would be beneficial to the Department of Defense, I do not think the proposed NSPS is the answer. The system in place now has protected employees' rights from favoritism and bias. In an ideal working environment, the proposed system would benefit dedicated workers and not benefit those unfit for the job, but not everyone works in an ideal environment. Individuals that are not employed in ideal environments would be severely limited and impacted. I feel these issues need to be addressed before implementing the proposed system. For these reasons, I oppose the implementation of NSPS and I urge you to stop any further development or implementation of NSPS.