| Comment Number: | OL-10511141 |
| Received: | 3/16/2005 2:11:51 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:
General comment #1: Throughout the document there are references to DoD will make this dtermination or that determination with unilateral authority. This includes pay bands, pay pools, classifications, and on and on. Quite frankly this is terrifying. It holds the entire DoD civilain workforce to the whim of DoD politics. This is not a good investement for DoD or its civilian workforce. General Commetns #2: To suggest that changing the civilian payroll systems is an item of National Defense is a farce and everyone knows it. The program will in the long term be utilized as a budgetary item off the backs of your own workforce. General Comment #3: This system will likely re-introduce the "good ol' boy" propmotion and pay system where local loyalty and back-side kissing will be rewarded. Page 7559 - Every reference to making sure that employess will not be disadvantaged has an out or escape clause. That leaves it open for abuse. Page 7559-7560 - There appears to be no COLA per say that would automaticlly increase pay bands. Again, all increases are left to DoD policy makers and the reality of the needs of the workforce will be completely ignored when push comes to shove. Page 7596 - Collective bargaining agreements are tossed aside if they are in any way in conflict with how DoD implements this law. Please, just turn back the time to prior to unions. These are agreements reached for a reason and should be included, not deleted, from a future system.