| Comment Number: | OL-10510772 |
| Received: | 3/16/2005 11:55:50 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:
Subpart A: General Provisions, Section 9901.104 If the NSPS is not limited by any specific law or authority under the title USC9902(b)(5) then what stops the government from changing any of these provisions whenever it wants. Section 9901.106 is nothing more then a route to bust the union. Subpart B: Classification, By creating a new pay system outside the GS and WG systems we are no longer "equal" across the board of all other government employees. To be a GS requires a degree and constitutes being a "professional". By changing that classification we won't be able to compete for other agencies jobs on a equal basis. Subpart C: Pay Administration, Section 9901.311, broad, occupational career groups is asinine. Are you going to group Biologist and Bio-techs together and now the Bio-tech will be doing a biologist job if so told too yet has no degree in Biology which is required to be a Biologist but not a Bio-tech? Again by eliminating position discriptions you remove the possibility of anyone competing for jobs in other government agencies because the classification for a Biologist will not apply in NSPS. As for comparing comparing our jobs to local jobs, in this area almost all Biologist work for the Federal Government or State Government which has poitions descriptions and specific pay for specific grades. Section 9901.355Just another way to pay us less for doing the same job we do now. Section 9901.361 Another way to pay us less and work us more. Section 9901.343 This is basically the good ol boys club concept. My buddy get the raise, I don't like you so you loose pay. Subpart D: Performance Management, With only one progress report per year an employee wouldn't know they were not meeting their performance goals until it was too late and if his pay were lowered he could not challenge the ruling, VERY AMERICAN. All the years spent creating a safe, no harassment environment for american workers down the drain wouldn't our forefathers be proud, WE'RE IN THE ARMY NOW. Subpart E: Staffing and Employment, Again an "at-will" system goes completely against tile 5 for protection of civilian workers. Subpart F: Reduction in Force, Veterans have always been protected under title 5 and the cloudy outline of this part implys that that may no longer be the case. Subpart G: Adverse Actions, Another way to rid yourselves of an undesirable employee with no avenue for challenge, very morale boosting environment you got going here. Subpart H: Appeals, Seciton 9901.807 Lets make appeals as difficult as possible for the common man so we can ensure he does not succeed so you can still rid yourselves of undesirable employees. Labor-Management Relations: Subpart I, No collective bargining=no avenue of challenge=you have ultimate control over the employees job at all times, very democratic. Section 9901.903, No grievances on alleged violations of a law, so now american citizens who work for DO D dont have the protection under the Whistle Blower law. Section 9901.922 One more step backward, starting to feel like a second class citizen. Section 9901.907, NSLRB "appointes" we know how this one works, independent, distinguished citizen with integrity, impartiality and expertise, who defines this one, politicaians who have no integrity, who aren't imaprtial, and do have expertise in covering their own butts but don't appear to care about those of their constituents. Section 9901.923 Good excuse to get around the laws of arbitration for DOD. Seciton 9901.919 Again DOD decides when and what on a national level not the union who speaks for the local employee with local issues. Section 9901.918 and 919, No ratification votes=no democracy. This is nothing more then a way to increase the numbers of military personnel. These provisions read very closely to those that cover enlisted personnel. You can't get americans to volunteer so you recruit your civilian employees against their will. Very smooth.