| Comment Number: | OL-10511723 |
| Received: | 3/16/2005 4:57:57 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:
Subpart F Workforce Shaping - 9901.6012 to 9901.611 It is my belief that the proposed NSPS regulations will undermine the Civil Service and harm the ability of Defense Department employees to accomplish agency missions. An increasing amount of government work is being performed by people who are not government employees. At the same time, the demands of the work require advanced knowledge and scientific tasks. Organizations and employees must have the ability to learn and use new information quickly and effectively. The objective should be to train and retrain to support military systems as products evolve and at the same time maintain legacy systems throughout their functional lifespans of two or three decades for most military applications. The Defense Department should not change the current layoff/RIF rules (Reduction in Force), which give balanced credit to performance and the employee's valuable years of committed service. Under NSPS, management would have the option of targeting and eradicating large numbers of career civil servants before they reach retirement eligibility. Given the overhead cost of Federal Retirement, it appears that the hidden agenda within the NSPS RIF is to abandon older professionals rather than redeploy them. Targeting sub-organizational units for a RIF can be readily accomplished on a spreadsheet given age, years of service, salary and program. The result will be a RIF based entirely on retirement-avaidance. Subpart E Staffing and Employment - 9901.501-9901.516 - The proposed regulations would replace longstanding provisions on hiring found in 5 U.S. Code Chapters 31 and 33 with unpublished procedures to be prescribed at some future date through implementing issuances. Using this approach will allow the Defense Department to arbitrarily develop and administer new rules on staffing and employment that have not been made available for public comment. This is especially troubling given the proposal to engage in non-citizen hiring to positions within NSPS. Our natinal security would surely be put at risk if Defense Department managers were able to exercise such hiring flexibilities. Subpart C Pay - Sections 9901.301 to 9901.373 Defense Department employees should continue to receive the same annual pay and across-the-board adjustments (cost of living) that other GS/FWS workers receive. The individual pay increases for performance in the regulations should include guaranteed percentage so employees will understand the pay system and what their pay increase will be depending on their performance.