Comment Number: OL-10511237
Received: 3/16/2005 2:40:03 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 proposed National Security Personnel System sounds great in concept, but the proposers, having offered no demonstrable reasons to justify a wholesale overhaul of the current DoD HR system, will cause the existing system to suffer in implementation and thus allow cronyism and favoritism to thrive, to the complete detriment of the DoD personnel service. It is a fallacy to assume that the DoD government personnel system can be run just like a for-profit enterprise where so-called high performers are adequately compensated and poor performers are not compensated. The hold of public and adminstrative law on the DoD system is substantial and for good reasons - the DoD public enterprise requires deliberations, consultations, published rules, equal treatment regardless to promote diversity, protection of all citizens, etc. Further, the proposed NSPS system has been poorly conceptualized, deliberated, and sold/promoted. In deed, the 24 Sep 04 "Townhall Meeting" here at Scott AFB. Illinois, featuring Maj Gen Speigel, Director of Personnel Policy, was really not a townhall meeting given (1) the limited time, (2) the size of the group, and the (3) top-down ---here is the information about the new personnel system ---approach of the entire event/meeting. Incredibly, no survey forms or questionnaires were provided so participants and others unable to attend could provide comments/inputs about the proposal being developed. I agree that the current General Schedule (GS) system needs tweaking to remove non-performing employees and their supervisors. However, it does not need wholesale displacement with cronies, smooth-talkers, fence-sitters and opportunists, and good-ole boy-type human/social networks.