| Comment Number: | OL-10511625 |
| Received: | 3/16/2005 4:23:13 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:
NSPS-2005-001 p.7553, the Case for Action: Clear example of "throwing out the baby with the bath water". Listing of "one-size fits all" hiring problems could be corrected by hiring a sufficient number of personnel people to do the required work and deleting unnecessary requirements. Unser the new system you are going to have to hire additional personnel and retrain everyone and will take more time and money. Essentially an elaborate process is being created to hide the deletion of protection for Government employees and leave them subject to the whim of a manager on a given day. We in the Corps of Engineers who are not engineers work at a very high level of stress and performance but that is neither recognized nor rewarded now. Under the guise of performance, the new system will simplify funnelling all of the money to the engineers and all non-engineers will be left further out in the cold. It is stated: "As the department moves away form the General Schedule system, it will become more competitive in setting salaries..." As states elsewhere in this Notice, the amount of funds between FY 2004 and 2008 is fixed as if the GS system does not change. Therefore, you will not be able to significantly increase salaries without completely eliminating some percentage of the existing workforce. The President, elements of the Congress, and all of the conservatives have spent several decades bashing all Federal employees to the point that few seriously consider a career in the Govt. The proposed changes will not attract the best and brightest ("...skilled, talented, and motivated people...") - they are designed to rid current employees of basice safeguards and recognition of the years of dedicated Public Service on the part of current Federal enployees. A genuine problem with the propsed revisions is that throught the document "DOD civilian employees" as if they are a homogenous group doing exactly the same jobs (or not doing them from the perspective of the discussions throughout this document) rather than looking at the differences between the missions of the agencies. The Corps of Engineers knows what the mission, requirements, and goals are and does not use military personnel in lieu of civilians. No " uniformed men and women..." will be freed from the Corps by the proposed regulations. p.7555 Was anyone from the Corps (below the level of the Pentagon?) even involved in the process of creating these revisions? the corps is clear on its mission; there is no confusion. Not all Federal employees are identical. p.7559 In fact the current GS system does provide equal pay for equal work; the the NSPS does exactly the opposite contrary to the claim in column one. NSPS leaves employees subject to the whim of a manager. Tor those of us in poor locations (New Mexico) the prevailing wage rates are lower that the rest of the country. The Corps can very easily determine taht more funds need to go to "important" districts and less to "unimportant" districts (like Albuquerque). p.7560 Currently everyone in a local receives the same locality pay. The propsed "local market supplement" is devised to be discriminatory since management can target career groups based on whatever predilaction of the moment even though all employees are in the same locatity. Many new full time personnel will have to be hired to manage the new system and the "pay pool" and the Corps is too cheap to hire anyone new so the already understaffed and overworked personnel people will have to do more and the system will function even less than it does now. p.7562 The Corps ALREADY evaluates teamwork as a performance factor - this will NOT come about after implementing NSPS. Supervisors already have a "...broad range of options..." to deal with unacceptable behavior. This will not come about because of NSPS. DOD and the Corps is way too cheap to provide "extensive training".