| Comment Number: | OL-10511330 |
| Received: | 3/16/2005 3:05:52 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:
It seems the whole NSPS system is being constructed to fit the sole discretion of the SECDEF. I have grave concerns about concentrating so much power in the hands of a political appointee, even a Cabinet level appointee. Public service is a trust and we are required to act in the best interests of the government and the taxpayers. Doing the right thing is often unpopular, sometimes inefficient, and sometimes detrimental to one's career. We are not in private industry. If we were, we would be more driven to place our personal welfare above our duty. As long as it benefits us, we'll do it. I have seen this firsthand as I have been in the private sector. Pay for performance sounds good. It makes a good sound-bite for the media. It even sounds like a good thing. How could one be against a system that will more richly reward him if he produces more than another; unless he was one who does not produce? Dissent is already set up to fail, as it will appear to be the pleadings of the lazy not to cut the gravy train. The problem lies in that NSPS management has all the power, in fact almost unfettered power to determine what a "good job" is. I contend that the current system is not failing because the employees are not working hard, or hardly working. It is quite simply due to a failure of management to properly execute it duties. All the tools are in place to reward high performers. Tools are in place to stem the career of low performers. The problem is that DOD does not want to use the tools it has. It's too difficult for them. Well to borrow SECDEF Rumsfeld's remark, you don't get to pick the system you want, you work with the system you have. Is it difficult? Maybe; I'm not a supervisor. The proposed regulations mention numerous times that this is necessary to protect national security. What exactly, are we doing that is not in support of national security? I as a Federal employee would like to know. Congress should be briefed. And if there is such an urgent and legitimate need, a clear and present danger, for something to be done for national security purposes, can't it be done via Executive Order? OMB flyer? Congressional bill? If the need is so great, the nation should be looking at this seriously in a fair and open dialog. The case for a new personnel system is week. There are performance awards now. Guess what? They go unused. Employee disciplinary measures exist - they aren't used. Flexibility of personnel - DOD admits in its FAQ's that it already has that power. Seems like it isn't used. This does not sound like a legitimate need to me. This sounds like a want. DOD wants to control things more easily. DOD wants to call all the shots. So many of the references are for the SECDEF to be the last word on almost everything. With no oversight? This sounds like it could be abused quite easily. It does not matter if you are for or against any particular party. It could be used as a union busting measure or as a pork barrel. Too much is not yet established to really evaluate this system. Pay bands are not officially proposed. There are no numbers to look at and see EXACTLY what the pay band will be. RIF procedures seem to be set up for a "red pen" treatment of any office without much discussion. MRO's are not yet defined. SECDEF will decide what they are, and SECDEF will decide if the penalty is too severe for the offence. What if my political views are an MRO? This sounds ridiculous, but if SECDEF is the only and final word, what is to prevent this type of abuse. "Penalties selected by DOD may not be reduced or otherwise modified by the MSPB." p.7597 Why even have an appeals process? DOD is the final word. This seems like we are setting up a kingdom within the government. I urge Congress to revoke NSPS. If any human has taken the time to read this response, I truly appreciate your time and attention. Thank you