| Comment Number: | OL-10511959 |
| Received: | 3/16/2005 6:54:40 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:
a) It hasn't worked anywhere else, like NAF or state governments, where it is simply a vehicle to indefinitely freeze or cut pay for everyone who doesn't have either a connection to, or an EEO complaint against, the pay-band decision-maker. Everyone who is not a crony or extortionist gets shorted, but the manipulative benefit. ----- b) People don't join government service because of its limitless upside monetary potential, but for the security of knowing exactly what they're going to get and exactly how many hours a week they'll be working. NSPS takes away the security without any predictable (or even necessarily significant) upside based on objective performance, assuming solely for the sake of argument that relative performance would indeed be objectively measured. ----- c) Managers without the courage to take adverse actions under the current system will continue to lack the courage to take adverse actions under NSPS. ----- d) EEO complaints will go through the roof since this adds a whole new (and very large and important) field of discretionary decisions to management's now-rather-limited panoply of complainable personnel actions, most of which currently do not involve actual money. ----- e) Freezing pay at current step levels is better than cutting it I suppose, but it results in anyone who hasn't spent his or her entire career in civil service being treated inequitably in relation to their peers of equal or lesser experience who have done so, and who are therefore at higher steps on NSPS inception. The effect of this will be to actually discourage new blood since we will try to bring in new people at the ebb of the band and they have no predictable hope of progressing from that point. ----- f) Meaningful comments are futile in my view, since the decisions have already been made and nothing is going to change Secretariat-level minds at this point. The entire comment process is merely a meaningless charade to comply with statutory requirements. ----- g) The idea that NSPS represents any enhancement to national security whatsoever is simply not based in reality, which is admittedly not exactly unprecedented. As far as rendering it easier to send civilian employees on deployments, the benefit is illusory since that is easily-enough done under the current system. The big disadvantage to deployments for civilians from the employee's point of view is not addressed by either system...i.e. the uniformed military's jealous protection of its prerogatives such as combat zone tax exclusion, despite essentially equal levels of danger for deployed civilians and the majority of the soldiers who are not in combat arms units. Really it just amounts to yet another reason for new employees to avoid DOD as an employer. This will certainly help in our quest to become an employer of choice....LAST choice. ----- h) I am sure that everyone associated with implementing this mess at DOD and the Departments will reap large rewards for it, in the finest traditions of slash-and-burn management. By which I mean the norm seems to be to implement something that is incredibly, foreseeably stupid in the long run, but sounds good in some sort of alternate-reality accounting mumbo-jumbo, then escape to another assignment or appointment before the brain-eating zombies erupt from their shallow graves on someone else's watch.