| Comment Number: | OL-10511259 |
| Received: | 3/16/2005 2:45:40 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:
IX. Temporary Promotion i. Federal Register Sections 9901.371(b) and 9901.373(a), (d), and (e). ii. The Navy has a majority of employees who hold temporary promotions to their positions. iii. These personnel hold “positions of record” at the lower GS level, with a pay differential of several thousand dollars. iv. These tempoary promotions positions are essential to the success of the NSPS. v. Conversion to the NSPS pay system would require these personnel be returned to their position of record for conversion (i.e., they would be given a pay cut) then they would have to be promoted under the new system. The NSPS promotion system has not yet been defined. The Federal Register does not offer a time when the department issuance with regards to promotions would be available. vi. Should the conversion take place before the department has defined the new promotion method, these personnel would be asked to perform the same duties for significantly less pay for an indeterminate amount of time. This would have significant impacts not only on employee moral, but on success of the NSPS overall. vii. This brief overview of the issue does not address the budget constraints that will likely be faced by tenant organizations who are provided salary budget at the “position of record” level, not at the current working salary level of employees. Should the budgetary issues affect the commands ability to immediately return these workers to their current salary levels, mission completion will be compromised. DoD eludes to this potential problem on page 7573 of Federal Register (Vol. 70, No. 29/Monday, February 14, 2005/Proposed Rules), which states, “It is expected that actual payroll costs under this system will be constrained by the amount budgeted for overall DoD payroll expenditures, as is the case with the present GS system.” viii. At the time of conversion, Navy will be in the midst of a significant workload, with personnel shortages. The personnel affected by the temporary promotions are those with 10-20 years experience, the essential workforce to take our installation through its workforce regeneration. Approximately 48% of Navy personnel will be eligible to retire by 2009. The percentage of personnel with 10-20 years experience is very small. Workforce revitalization has created a nuclear engineering department with approximately 50% of the workforce with less than 10 years experience. Should those limited personnel with 10-20 years experience be attacked due to the temporary promotions rule, the longevity of the workforce will be in question.