| Comment Number: | OL-10510748 |
| Received: | 3/16/2005 11:44:31 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:
General: The rules as written offer little in the way of detail and leave us scant room to make an intelligent analysis. It seems to me this is just par for the course on how our government is now being run. Basically, the opinion of the people doesn't seem to matter. Our comments here are little more than something to point to suggest we were informed beforehand, despite the fact we have little information with which to make an assessment of the new system. Early adverse comments on the system are debunked with more non-sensical, sketchy quasi-facts from the personnel folks (NSPS - Myths and Facts). It's another sad day for open government and integrity in America, and another good day for American Disinformation. Subpart C Pay, Sections 9901.301 to 9901.373: I fear defense employees will now be at the mercy of the national budget/deficit as to whether they will receive a cost-of-living adjustment if the COLA is taken out of our yearly budget and lumped in with performance. When ANYONE receives no yearly increase, he is losing wages. That person may be a person who is low-graded and thus more likely to be scrimping by already. It is fine and reasonable to weigh the amount of raises upon an employee's performance per se (of course, if and only if that rating is just and fair). It is wholly unreasonable to deprive any person of a COLA, especially with the economy in the questionable state it is in. This would be a huge step backward for workers across America. It is difficult to determine how the budget and deficit will exactly impact our pay, however, since the details on this are nonexistent in this proposed regulation. Subpart D Performance Management - Sections 9901.404 to 9901.409: Since performance ratings will determine our pay rate and any RIF action, it is obviously imperative these ratings are done with fairness and accuracy and the findings should be contestable if an employee feels he has been under-rated. This regulation reveals no recourse for an employee, let alone a fair and just recourse method. Also, the methodology for the ratings themselves is not spelled out, despite the fact this new personnel system has been implemented in other agencies. Why then are we being asked to imagine so many of the rules? Why are the NSPS formulation folks hiding so many details? Subpart I Labor-Management Relations - Sections 9901.901 to 9901.929: It appears we are being Wal-Mart-ized as so many working folks are across America. With less bargaining or grievance rights, the priorities of management will trump any worker rights. Unfortunately, unlike Wal-Mart, government employees can be subject to deployment to dangerous war zones WITHOUT union bargaining, which is very much unlike the rules as they are now -- despite the so called facts just released by personnel.