| Comment Number: | OL-10510835 |
| Received: | 3/16/2005 12:18:31 PM |
| 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:
NSPS Proposed Rule. Comments relate to ALL Sections. I OBJECT/OPPOSE THE REMOVAL OF MY CIVIL SERVICE RIGHTS UNDER PRESENT LAW BY NSPS IMPLEMENTATION WHILE OTHER FEDERAL WORKERS CONTINUE TO BE PROTECTED UNDER THE PRESENT SYSTEM. Promotions/raises will be TOP-HEAVY. I PRAY THAT CONGRESS TAKE ACTION ON THIS BAD NSPS PROPOSAL As a DoD civil service worker, I STRONGLY OBJECT and OPPOSE all sections of the proposed NSPS rule based on the following but not all inclusive list due to IMPOSED character space limitations. 1) Proposed NSPS rule is a shell, it fails to contain specific relevant/critical detail, it raises additional questions. It places the cart before the horse. Approving this shell without specific detail upfront negates DoD worker input on critical details once developed. It is not transparent. 2) Language in proposed NSPS referencing contractors and placement with non-citizens is threatening. Indicates our positions could be replaced/filled without appropriate competition. Counter to homeland security as DoD lacks control over whom contractor hires, illegal alien hire 3) Fails to afford DoD employee protection. No checks and balances. Any/all employee issues/grievances to be decided by a board selected by Secretary and only if another board under the Secretary determines merit first with outside representation very limited at best. Strong concern over swift removal or demotion of employee, can be abusive/unwarranted under management. Affords advantage for DoD, NO REAL EMPLOYEE PROTECTION. Reads like a dictatorship. 4) Present civil service system is more equitable, but lacks sufficient funding. The proposed NSPS reverts to the initial cause of civil service reform in the first place. NSPS is counter to DoD's mission. NSPS fails to provide an equitable work environment, promotes favoritism with managers. Unfair labor practices breed discontent among co-workers. Witnessed unfair labor practices very prevalent in the real word. No real protection/relief for DoD employee under NSPS. 5) Question sufficient funding. Placement in bands with assigned scores based on performance is an UNFAIR NUMBERS GAME that removes individuality from the worker and pits coworkers against one another. Funding presently scarce under present system. Foresee competitive limited funding source with no guarantee for raises/bonuses even with high score achievement. Bonuses presently heavily taxed, resulting in little $ received, no yearly increase bad for survival with increased cost of living. 6) Presently under severe budget constraints w/no yearly travel, training. Live/work in a frontier state, travel = 14+ hours from east to west border. Required to frequently travel in state to attain performance standards but unattainable with yearly travel restrictions/state size, unable to cover in 8 hour day, often donate time. Training needed to meet development standards cancelled yearly due to budget constraints. This automatically sets employee up to fail performance under new NSPS system. Also, we do not produce countable widgets so how will one compare. Workload for one could = 10 simple projects vs. workload of another = 2 very detailed, difficult projects. Degree of difficulty not reflected. 7) New system costly, question NSPS training $, since training to meet performance objectives cancelled on yearly basis to date. 8) Coworkers swiftly volunteer to Iraq, Afghanistan, hurricane disasters,etc. Remaining workers support mission by picking up the resultant additional workload. Present system is no threat to homeland security. Problems result from poor management, NSPS fails to correct those problems, will only worsen. I am deeply offended as a perceived threat to homeland security and most concerned with how government is being shaped. NSPS is counterproductive to tax payer $ and services. Present administration is hostile to already overworked government civil work force, NSPS proposal reinforces hostility. Why higher chain excluded?