Comment Number: OL-10511081
Received: 3/16/2005 1:57:20 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:

I have reviewed the subject rule and have the following concerns: 1. As a COE Section 404 of the Clean Water Act regulator, considering our growing amount of work and limited budget, I am concerned that employees will not receive pay increases/bonus because of limited funding. How will this be addressed, to insure that average and above performers are adequately recognized and receive additional pay? 2. Overall, I am in support of a pay for performance program, having spent most of my career in the private sector. I am concerned with the use of a rating system driven pay system, however. Presently, supervisors are using boiler plate type evaluations which do not adequately rate employees. Taking into account the availability of additional funds to support the program and increased pay for those deserving, I would question how those serving in independent offices (field) versus those serving in HQ or district offices will be compared. I presently do not see my rating supervisor more than once per year. In three years, he has yet to visit my office or area of responsibility. How will he rate me sufficiently to reflect a competitive pay increase? I have received performance awards over the past two years! 3. Taking into account limited budget, under this proposed program, management may option out of performance pay increases to reduce budget expenditures. Government operates under a fix budget, whereas the private sector works under a profit driven budget. If a company's profits increase, the availability of additional funds to pay bonus or increase annual salary is available. Under the proposed rule, pay increases are only available if the budget warrants. Congress and management in the HQ / Washington levels will control what occurs in the field level, regardless of individual performance. 4. Without the ability to review the new bands, several questions exist. Will Engineers, sceintist and biologist be combined into bands through combination of Series and levels, or will job functions be combined, such as Planners, Construction Ops and Civil Works, with Regulatory being separately? Regulatory "police's" the people with reflect to the Clean Water Act. Our ultimate coustomer is the aquatic environment. Where as the rest of the Corps has coustomers which are project generated. How can you combine regulators with planners for example, and let them compete for limited performance raises? Thank you for allowing me to comment. I look forward to seeing the proposed bands. Tony Curtis