Comment Number: OL-10511925
Received: 3/16/2005 6:27:38 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:

1. General/Overview: The potential reduction of political independence and opportunities for internal advancement allowable for U.S. Civil Servants under the NSPS in the Department of Defense are damaging to the central theme and purpose of American Civil Service reform -- the MERIT PRINCIPLE. By limiting civil servant independence via removal of within grade opprotunities for pay advancement within their military services and by subjecting civil servants to greater control and manipulation by political appointees and their subordinates, NSPS takes us back to the era of the spoils systems. Bottom Line: Political leadership comes and goes, but, Civil servants must be insulated and protected from political interference and be free to apply their skills, knowledge, and abilities to accomplishment of the total American public interest. NSPS reduces their independence and rewards for exercising their all important contributions. 2. Specific Issues: a. Previous Experiments in Paybanding in the Military Services have not resulted in Greater Quantity or Quality of Work: The experiments at the Navy's Chiina Lake installation and the Marine Corps' Systems Command (MARCORSYSCOM) at Quantico Marine Base, VA did not improve matters. In fact, at MARCORSYSCOM following adoption of its paybanding program, a former commander was found to have improperly and, perhaps illegally diverted authorized Navy Operation and Maintenance, civilian payroll funds to performing military construction projects at the Quantico base. How in the world does that improve civilian employee performance? In fact, it demoralizes and subverts civil servants. b. There are only limited opprtunities for advancement in the Federal Service due to its reductions and to the growth of contract operations. Therefore, removing within grade advancements is to reduce incentives to provide quality work.