| Comment Number: | OL-10511123 |
| Received: | 3/16/2005 2:06:45 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Comments to NSPS RIF Rules.rtf Download Adobe Reader |
Comments:
FOR COMPLETE SET OF COMMENTS, SEE ATTACHED: 'Comments to NSPS RIF Rules.doc' SUBPART F - Workforce Shaping Pages 7564-7565 and Pages 7588-7590 Section 9901 and Section 9901.601-611 Background: Comments are an attempt to share ‘Expertise’ gained from: 1) 1996 RIF; USAF Rome Laboratory; Griffiss AFB, NY (Base Closure) 2) 1999 QDR; USAF 38TH EIW, Tinker AFB, OK (Wing Folded to Grp) 3) 2004 Alignment; US Navy, NUWCDIVNPT, RI (NUWC Realignment) Introduction: Thank you for this opportunity to give comments. Below is my reaction based on my above background and ‘expertise’, in particular from the RIF process. General Comments 1. Such drastic change out of character of DoD’s successful cost-saving approach. 1.1 Propose reducing cost using developmental change as apposed to that of current NSPS Proposed Rules. 2. Costly Oversights (a typical case example from RIF Experience) 2.1 NSPS Reference Document does not allow for previous actions, which made a RIF action work. 2.2 Summary of deficiencies (NSPS Proposed Rules): 2.2.1 TRANSITIONAL COOPERATION: Previous RIF Action allowed time for management to work with affected employees, such as: 2.2.1.1 On site job-relocation services 2.2.1.2 Community job-relocation services 2.2.1.3 Priority Placement 2.2.1.3.1 Mitigate costly/hasty Permanent Change of Station (PCS) decisions. (Time was allowed for me to first consider local options (less costly to DoD). 2.2.1.4 Undesirable RIF Effects (that can only get worse with current Proposed Rules.) 2.2.1.4.1 Disgruntled Employees 2.2.1.4.2 Casualties such as suicide (I had lunch w/ my vice-commander who had the unfortunate ‘additional duty’ of investigating such a suicide. Please count the costs instead of starting from scratch.) SUMMARY: Based on my background experience (listed above), NSPS does not consider the ‘big picture’ nor ‘count the cost’ from such drastic change. RECOMMENDATIONS: 1. Please return to DoD’s heritage of responsible developmental change. (Don’t ‘throw out the baby with the bath-water.’) 2. Please return to DoD’s ‘family/community’ type heritage. Consider ‘bottom-up’ solutions (as well as ‘top-down’ directives) gained from our NUWC & NAVSEA Realignment investments, as well as VERA options. 2.1 From my experience, the DoD has been more of a community, working together to work out solutions. As a local example, our current motto is: ”Working Together to Deliver the Best Solutions Quickly” Naval Undersea Warfare Center (NUWC) Motto You and I are facing real challenges. Let’s work together.