| Comment Number: | OL-10511595 |
| Received: | 3/16/2005 4:15:52 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:
Re: RIN 3206-AK76/0790-AH82. Pgs. 7558-7559 Classification subpart B DOD has provided no objective criteria that will be applied to determine the value of an employee's worth to the organization when grouping employees into occupationa categories and levels of work for pay and other related purposes. The NSPS proposed regulation are silent on the matter. Who will determine the criteria and how will it be fairly & consistently administered to avoid the potential for selection favoritism and abuse by managers. We need to have an open public discussion relative to these proposed changes to DOD personel system and Congress needs to fully understand the monumental changes to the existing Civil Service that are being proposed. How will DOD avoid compromising the merit system principles of equal pay for work of equal value cf. 5 U.S.C. 2301(3)? Pgs. 7568 - 7573 Labor-Management Relations - subpart 1 The creation of a separate DOD Labor Relations Board sends a distressing signal to unions nation-wide that the adverse actions and appeals process as it has been administered in the past, will be elimated and replaced by a far riskier mechanism for due process activity, heavily stacked in favor of management biased outcomes. The three DOD LRB members, appointed by the DOD Secretary, fail to represent an unfettered board that can effectively and objectively mete out UNBIASED DECISIONS ON ADVERSE ACTION AND APPEALS MATTERS WITHIN THE DEPARTMENT. How will the rights of employees be objectively protected when the board is made up of Dept. managers and not impartial third party representatives as currently in place with the FLRA? This does not pass the laugh test. I am very concerned as a federal civilian employee with 26 years of dedicated federal service that this new personnel system sets up a political patronage and spoils system that will encourage prohibited personeel practices and violate all merit system principles. This is not a private enterprise this is the federal government where employees spend their careers in dedication and work for the good of the public and should be treated with diginity and respect and the labor rights that they are entitled to. We need to have honest and open public discussion held with all parties regarding these proposed regulations and Congress needs to be fully aware of the monumental changes to the existing Civil Service rules that are being proposed