| Comment Number: | OL-10511426 |
| Received: | 3/16/2005 3:26:14 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: I believe the proposed NSPS will undermine the Civil Service and hurt national security by creating a competitive environment that fosters "Survivor"-type alliances and infighting that will detract from cooperative teamwork focused on mission accomplishment. Subpart C Pay, Sections 9901.301 to 9901.373: The employees in DoD should continue to receive the same across-the-board annual pay adjustment that other GS/FWS workers receive. The individual pay increases for performance should include guaranteed percentages in the regulations so that employees will understand the pay system and what their pay increase will be depending upon their performance. Subpart D Performance Management - 9901.401 to 9901.409: In order to insure fairness and accuracy, DoD employees should be able to appeal any performance rating to an independent grievance and arbitrations process like they can now do. Subpart F Workforce Shaping - 9901.6012 to 9901.611: DoD should not change the current layoff/RIF rules which give balanced credit to performance and the employee's valuable years of committed service to DoD. Subpart G Adverse Actions - 9901.701 to 9901.810: Due process and fairness demand that the independent body reviewing a major suspension or termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor-Management Relations - 9901.901 to 9901.929: The labor management law that has governed the employees' right to organize and engage in collective bargaining has worked well since 1978. There is no compelling reason to take away most of the collective bargaining right or grievance rights. DoD should not create a "company-dominated dispute board." Any dispute board must be "jointly selected" by management and the Union.