Comment Number: OL-10511512
Received: 3/16/2005 3:51:08 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:

This is not a form letter, please read it in its entirety. After graduation from SUNY Maritime College in 1985 I worked aboard Military Sealift Command (MSC) vessels serving in licensed engineer positions as up to and including First Assistant. I served aboard USNS ships including the Neosho, Sirius, Saturn and Maury. In 1994 I left MSC and continued my maritime career as a member of the Marine Engineers' Beneficial Association (MEBA). As a member of the MEBA after 1994 I continued to contribute to the sealift needs of the US making use of my knowledge of the MSC organization and systems by serving as a crew member aboard and Port Engineer for several US Maritime Administration Ready Reserve Force (RRF) vessels during all phases of maintenance and operation. These vessels include the Capes Gibson, Girardeau, Borda, Blanco, Fear, Mohican, Bon, the Meteor and the Northern Light. When not employed by the union or directly aboard the vessels I have also worked in a contract capacity aboard these and other vessels to effect voyage repairs and other maintenance and repair activities. Some of the other vessels include the Capes Horn, Henry, Hudson, and the Orlando. Since I have served as both a civil service mariner (CivMar) and union employee I feel that I am uniquely able to comment on the proposed imposition of the National Security Personnel System (NSPS) on MEBA CivMars employed by the Department of Defense (DoD) on MSC ships and the US Army Corps of Engineers (USACE). Because I gained my MEBA union membership while I was a CivMar working aboard the MSC vessels I was able to continue my work aboard these ships and advance my career in the MEBA. I have since served as Chief Engineer aboard commercial and MSC contracted vessels in support of the sealift efforts in Iraq. If the MEBA had not been the bargaining unit for the CivMars working for MSC it is almost certain that I would have left MSC, continued my career outside the maritime industry and the knowledge that I had accumulated during my time working for MSC would have been lost to the RRF, US government and commercial maritime industry. I also personally know of many others who were in the employ of MSC at the same time that I was who have left the MSC and continued with the MEBA. To a man these people have in the past and would in the future support any sealift effort of the USA. Several others that I had worked with at MSC who did not exercise the option to become full members of the MEBA have left the maritime industry, let their credentials lapse or expire, gone on to other careers or professions and are no longer available to serve the country in times of need. This "brain drain" or loss of trained personnel will only continue to further erode sealift capability and thus the national security of the country if there is any additional loss of trained and knowledgeable people from the pool of sea going and shore based personnel available in times of crisis. I feel that an action to exclude the representation of CivMars by the MEBA or other maritime unions will only act to accelerate the loss of these talented and skilled individuals. The current system where the MEBA represents licensed engineer CivMars aboard MSC vessels is complimentary and provides an additional career route for those who would otherwise leave the industry completely. Unlike other federal civilian service employees CivMars aboard DoD ships are similar to personnel aboard ships manned by the U.S. military - they daily perform dangerous tasks in support of the U.S. military. CivMars are considered legally excepted service and not competitive service employees, and are not covered by performance management systems. They are part of a system that works and should remain subject only to 5 USC 71. Respectfully, Todd Simonse First Engineer M/V Pres. Adams