| Comment Number: | OL-10511686 |
| Received: | 3/16/2005 4:46:24 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 comments on entire document. Every time history repeats itself the price goes up. Those who don't learn from history are doomed to repeat it. Dear Sirs, I am writing to protest this attempt to invent a new government employee system. In my opinion, it will be a reverting to the time before civil service was established, allowing newly elected administrations the ability to replace government employees with "yes men". With each new administration and a new Secretary with new and different "discretions", with new inconsistent and perhaps, incompatible ideas of how the system is run, the stability of an in-place government is lost. The government should have some consistency over time and I feel it will be lost with NSPS. This is no way to run a railroad, much less a government. In case you don't remember , civil service was created to stop the "spoil system" which this is determined to bring back. There is no protection for the employee as a person, the union is eviscerated, and front line supervisors are threatened. If we go to this system, teamwork will be out the window, as ever person, work group, agency, etc. to the highest levels will be fighting over money to pay the highest wages and to support themselves. I don't believe people have improved any over the last 100 years and believe any weaknesses and holes of which there are many, will be used to promote, hire and pay personal friends as opposed to best qualified. Granted this is happening now, but the government has managed to retain a core of competent employees throughout. I don't feel this will happen with the new system. Many protections that keep this core of competency stable are being removed. The ability of the employee (and sometimes management, because there is always a higher level of management) to predict who, when, where, why and how jobs will be done have been taken away. Civil service, as it stands, is a clunky archaic behemoth, but it is still much better than the proposed NSPS. Let's improve the system we have and not compound or create problems that we don't need. My specific concerns with NSPS: 1.I disagree with present system encourages dispute-oriented relationship -- you want to see adversarial, then tie money to subjective analysis of quantity and quality of work (p.7553) 2.Managers will have flexibility to manage budget -- those favored by higher ups will have the flexibility those in the renches won't (p.7555) 3.Agile and responsive -- we're not the military (p.7557) 4.Pay for performance, pay pools and pay bands are too vague, need specifics (whole document). Still depends on "management" getting money (Whose management? 5.Says money won't be less (p.7559), but doesn't say more 6.In RIF, employees' pay protected by issuances not written yet -- why should we trust you? (p. 7561) 7.If the mission changes, then does the money change? Whose mission is the mission, DoD's, AF, wing, division, unit, office? (p.7565) 8.Union contracts not good as of implementation of NSPS? Where will all our hard fought rights go and who will protect them when the unions are gone? (p. 7569)(9901.905 9.NSLRB has built in bias toward DoD. (p. 7569) 10.Personnel clerks and lawyers can't belong to the union? Getting rid of anyone who knows how the system works? (p.7570) 11.No union rep allowed in disciplinary meetings? Are we going back to He said, she said (p. 7571) 12.Savings provisions are saving you. Remedies need to go with time proceedings were begun.(p.7573) 13.Unacceptable performance is measured. How?9901.201 14.9901.105e allows managment to appoint anyone they want to. 15.9901.106a6 Can change issuances anytime wanted. If management can change the rules on the fly, how can this be good for employees? It's like trying to build a life on shifting sands 16.9901.211 and 212 too vague 17.9901.323 Pay raises depend on money to the pay bands 18.9901.401b7 Safeguards need to be spelled out I think I could write a book. Uncaring and one-sided is this.