| Comment Number: | OL-10511222 |
| Received: | 3/16/2005 2:34:46 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: The time allowed between issue of proposed rules and cut-off date (30 days) was inadequate. The local Q & A meeting was only two weeks before the cutoff date, notice of the meeting was short, and was held off base during working hours with limited capacity for attendees. Concerned that the number of comments will be relatively less than it could be with more time for discussion and review. A low number of comments should not be taken as tacit approval of the proposal. The current civil service system was developed and refined over decades and has resolutions and precedents for nearly all questions. This proposed system was developed in 7 months and is being rushed to implementation without adequate time for critical review and open discussion. My suspicions are aroused when limiting feedback from the affected people seems to be designed into the system. Pay and Pay Administration-Subpart C, Table 2.: Sample Rating Methodology; I have been involved with end of year bonus award determinations for the past 2 years using this method of rating. The method effectively predetermines that a fixed percentage of staff is considered as no more than average and the remainder of staff is subjected to classification based on their fortune or misfortune of the being assigned to particular supervisors (who have quite different and subjective ideas of what employees merit). Found that nearly all employees were left with bad feelings about bonuses. 9901.313 (a) and (b): "To the maximum extent practicable" amount of pay allocations, leaves it open to an equal amount or nothing at all. How is the amount of money available determined and who is responsible to set forth the amount? 9901.910 Management Rights: Grants management the "sole, exclusive, and unreviewable discretion to determine the procedures that it will observe in exercising the authorities set forth in 9901.910(a)(1) and (2)" to do most anything it pleases without answering to anyone. I am not sure that this is the way to build loyalty and expect hard work and commitment to the cause. It has been my experience that most people desire to do their best when treated with respect and integrity and have some assurance that that their job will be there next year. Summary: There are many things that are left open in this proposal. I always thought of civil service as the backbone of a nation's middle class. This proposal, despite its loftily stated goals, appears to give management the ability to dissolve the civil service in DOD under the guise of expediency.