| Comment Number: | OL-10511668 |
| Received: | 3/16/2005 4:40:33 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:
-- The document is filled with wrong assumptions. For example, on page 7553, column 1, the narrative spin says a uniform pay system that is fair and easy to understand is labeled one-size-fits-all and called a weakness of the personnel system. Uniform actually means fair to all. -- The document claims that the 9/11 attacks made flexibility an absolute requirement. NONSENSE. The Department of Defense is supposed to always be ready to respond to attacks, that's what it does, it fights wars. 9/11 no more created a need for flexibility in how the Pentagon handles it civilians than did the Vietnam War, the Korean War, the Gulf War, etc. The 9/11 reference is an attempt at emotional hijacking. Using fear and emotion to justify changing citizen and in this case employee rights. -- The document claims to be proceeding in a collaborative process, but if the SECDEF doesn't agree he can set it all aside and do as he pleases anyway. -- The idea that no one understands DOD and its unique save-the-world- mission is NONSENSE. There are many agencies involved in safety and security issues in America, such as DOE and the FAA. In this document, this emotional and fraudulent assumption is being used to justify every unfair labor practice the document drafters choose to impose. DOD claims to need its own labor relations board? Why? Because no one understands the DOD mission like DOD. This theme reoccurs several times in the proposal as if just saying it is enough justification for the outrageous changes that are proposed. Under NSPS, employees can appeal to the Merit System Protection Board, but if the SECDEF disagrees he can set aside, reverse or ignore the decisions of an administrative judge's decision; Why? Because no one understands the DOD mission like DOD. The document fails to make a case as to why DOD needs to reinvent the appeals process, unless of course they want to make it more management friendly, which ensures it will be more labor unfriendly. The agencies that already exist in the federal government to mediate and resolve labor and management disputes should oversee how DOD treats its employees. -- These new rules as they relate to unions are nothing short of union busting. The proposal sweeps aside labor and lets DOD ignore union concerns, grievances and agreements. This is unacceptable. I'm not even in a union but I know this is not the way to trust and respect employees. -- The idea that DOD's leaders and civilian employees and unions will continue to work toward a mutually beneficial relationship is laughable when you read the paragraph on page 7573 that says: To proceed with implementation...the secretary must determine (in his/her sole and unreviewable discretion) that further consultation and mediation are unlikely to produce agreement. First of all, underline the word unreviewable; this sounds like an absolute power grab. Secondly, what the paragraph actually means is the SECDEF can stop talking at anytime he decides and put whatever he wants in place. Take it or leave it. -- The pay system sounds like a return to the spoils system. It's not about performance any more; the NSPS will create a cadre of yes-men by the thousands who do what they're told with out question. Yes, without question, because one of the attributes that decides your rating and pay under the new system is attitude. DOD will be able to get rid of an employee for having a bad or different attitude. This NSPS proposal is UNBELIEVABLE. -- The system that is being created will allow those with a political agenda to fire those who disagree, reward those who go along and return the civil service process to the old political spoils system of years ago, which the current GS schedule attempted to fix. -- The authority that DOD will have over its silenced and repressed civil service employees will in-effect be the BACKDOOR DRAFT we heard about during the presidential campaign; DOD civilian are being made to join the military instead of working for it.