| Comment Number: | OL-10511261 |
| Received: | 3/16/2005 2:47:13 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:
As a 15-year veteran of the Federal Civil Service System, I am opposed to the NSPS. I'm writing to state that the proposed NSPS will undermine the Federal civilian worker which serves America's citizens so well. Subpart A - Union representatives must be involved in developing the details of the system (before a draft is proposed). Subpart C - The DoD should not have the flexibility to reduce overall worker payroll amounts. Nor should the agency have the right to set local market supplements for workers. To be fair, locality pay should be given equally to all employees in the same local area. The performance pay pool will result in some outstanding employees receiving less money than other outstanding employees at the same pay grade. The new proposal would escalate cases of supervisor favoritism. The Entry and Developmental Band could be used by managers for age discrimination. Older Federal employees may be abused by requiring participation in an unrealistic developmental program. The DoD should not be allowed to set its own pay rates or premium pay. All pay rates should be standardized across the Federal Government. Subpart D Performance Management - It is important that DoD staff are able to appeal a performance rating to an independent arbitration process. DoD should not have the abillity to change expectations for employees without input and coordination with the employee and the Union. Subpart E Staffing and Employment - The Union must be involved in writing the criteria for probationary periods. If all promotions are considered to be probationary, why would an employee want to take the risk of accepting a promotion? Subpart F Workforce Shaping - The current layoff/RIF rules should not be changed. Military veterans and Federal employees with years of dedicated service should receive credit and be allowed to bump and retreat. Subpart G Adverse Actions - Current standards approved by the courts to guide an independent body reviewing a major suspension should continue to be used. Subpart H Appeals - The ability to appeal to the Merit System Protection Board must be maintained. Often times, it is the last resource for a Federal employee with an abusive supervisor. Judges at the MSPB, are able to recognize trumped-up charges by supervisors and protect the worker. Managers, who are supported by agency attorneys, will bleed the worker dry of his or her monetary resources with delight. So, it is important that the MSPB have the ability to liberally grant attorney fees to workers. Subpart I Labor-Management Relations - There is no compelling reason to take away collective bargaining rights or grievance rights. This is a Union-busting tactic. Any dispute board must be "jointly selected" by management and the Union.