Comment Number: OL-10511128
Received: 3/16/2005 2:09:20 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:

The DoD proposal mentions that civilian employees must be flexible and a responsive part of the team. Does this mean that they can be deployed with notice to anywhere in the world to support military activities? What safeguards will protect the DoD civilians from being placed in harm’s way? 9901.101(b) Appears that the NSPS proposal would allow civilian employees to be assigned to war zones without any recourse on the part of the employee. What if I don’t want to be sent to a war zone? 9901.101(a) Why not correct the failure of management and supervision to correctly manage the current pay system, which does allow for compensation to be linked to performance instead of spending funds to implement a new system which will only workif your boss likes you? 9901.103 Current law allows for rewarding high performers with monetary bonuses and quality step increases, so it is unclear as to why NSPS rules to introduce pay banding will improve things. 9901.342(a) Based on my personal experience with supervisors it will take tight internal controls and oversight to insure that supervisors do not use the new pay banding systems to reward their friends. Awards are handed out in this manner and if pay banding is allowed, wages will be controlled in the same manner. 9901.212(d) If the proposed NSPS system is as harmful to the process of hiring and promoting qualified individuals as was the centralization of personnel offices, then rather than improve upon the flexibility already found in the civil service system, NSPS will merely make things even worse. 9901.511 NSPS will not correct the problems with the personnel system created by poor management. The current civil service system can provide for the same level of flexibility as is now necessary without eroding the rights and protection of the employee. As it is the employee finds himself fighting an uphill battle to defend his rights. NSPS will make this even worse. 9901.601 DOD runs the military. Trying to eliminate civil service and replace it with NSPS is just a thinly veiled attempt to use the terrorist attacks of Sep 11 to replace the existing civil service system. 9901.602 DoD seems to feel that they are forced to use military personnel or contractors when federal civilian employees would be more appropriate. Because of this DoD feels that NSPS will provide relief. Mismanagement of personnel by supervision and management should not be the reason to create NSPS and effectively eliminate the protections afforded under civil service. 9901.513 I understand that the intent of Congress to allow for meaningful discussions concerning the development of the NSPS has not been followed and rather DoD is attempting to put NSPS in place without these discussions. 9901.101(a) Understand that DoD wants to remove the word “consult” from the new bargaining agreement. I understand that the word “consult” requires that the parties reach an agreement, which in turn means that DoD must bargain in good faith to agreement or impasse. I object to this attempt to weaken my collective bargaining rights. 9901.917(a) The Civil Service Reform Act of 1978 mandated the establishment of performance standards and the periodic evaluation of performance. If NSPS is now proposing that this process needs to be changed, what evidence do they have that the current system, if used correctly, is not up to the task of providing for proper performance evaluations? 9901. 342(a) If a new plan for an improved good faith bargaining system is required, then the NSPS proposal should provide for both parties to come to the bargaining table with equal rights. National security should not be used as an excuse to dismantle the existing federal labor laws. 9901.917(a) NSPS is using the guise of national security to change current law relating to pay raises for federal employees. 9901.917(a) The Transportation Security Agency has been ruined, why do you wnat to ruin the rest of us.