Comment Number: OL-10510594
Received: 3/16/2005 10:40:46 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 an attorney with the Department of Defense. I would love to be able to comment on this proposed regulation, but, frankly, so little information is contained in the regulation, and so much is left undecided, that there is no way to make substantive comments. This regulation tells us no more than the press release made upon Congress's granting of the authority to the Secretary of Defense to create the NSPS, other than the decision to allow MSPB to have jurisdiction over DoD cases, albeit with different rules (such rules also still to be decided). After reading this regulation, we still do not know how many pay bands there will be, which GS grades will be included in the bands, how bonuses and pay will be figured, what the rules will be regarding time in grade requirements, what will be done about supervisors who play favorites when deciding pay and performance issues, or a whole host of other important items this regulation should have contained and doesn't. Considering I am supposed to be in the first wave of employees included in the system, I am very concerned that it appears the system still hasn't been built. I can understand the unions concerns. It appears few substantive decisions have been made concerning NSPS (or at least few that are to be released to the public), so how is it possible to state that unions had involvement in the decision-making process prior to the publishing of this regulation? Considering this is an entirely new personnel system that will affect a huge portion of the federal employment sector, this regulation is woefully deficient in every respect. I am paid very little to do my job, compared to what I would make as an attorney in the private sector. I am certainly not paid enough to be Donald Rumsfeld's guinea pig.