Comment Number: OL-10512011
Received: 3/16/2005 7:47:32 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:

I am a retired career Army combat vetern with service in both WWII, and Korea. Additionally, after my military career, I persued a long DA civilian career in support of my sons' generation. One of my sons is sending this (in)on my behalf. First of all: During this very long dual DA career, I have worked for 30 or more supervisors. My job(s) changed quite a bit over time. I had advanced to the position of a civilian Supervisor of serveral work units, entitled "Divisions". A good question is why have I had so many supervisors? I worked on an Army Base that is run by active duty Army officers. Despite Field grade rank, and Higher (GO level), many of them accept supervisory responsability over DA Civilians without any thought, "Rhyme, 'Nor Reason, as to HOW to attain an understanding of supervising civil service employees. When they first take charge, we know that many of them treat their employees worse than new privates. For many, something as simple as filling out a time card will confound them! The civil service rules that are currently in place took many years to develope and many hard battles where waged just to make it a FAIR system. It is certainly NOT PERFECT, BUT, IT DOES WORK BETTER THAN ANYTHING PREVIOUSLY IN PLACE!! If (some of) the supervisors that I, or my sons have endured were given all the power that this new system would give them, HOW you conducted YOUR job would be the last thing considered in order to determine how much you got paid. The "Good 'Old Boy" system would be alive and well, even though THAT system failed this country very badly! Despite this hard-earned historical lesson, this Administration insists that our Nation should simply "CHARGE BACKWARDS!!" . There are PLENTY of Management "Flunkies" around, and IF you are a "Buddy" of a high-graded (GM-14 and above) Supervisor, YOU WILL GAIN THE HIGHEST PAY, NO MATTER HOW LITTLE YOU DID! Why do you think they have promotion requirements in the Army? Let us NOT forget that the COMPLETE REPEAL of "Civil SERVICE" rules & regulations are designed to avoid All means of accountability by DOD Management. Any "Politically/PARTISANLY CORRECT" manager will (happily) take the easy way out. We have problems now simple ACCOUNTABILITY for SANITATION Work within DOD facilities (Contractor-provided, of course!). So, with just that simple an issue: This PRESIDENT intends to grant that PARTISIAN management crew TOTAL CONTROL of WHO, and HOW MUCH to pay our knowledgable Civil Service personnel?? Another point to consider: WHY are the traditional methods of dispute resolution (i.e. grievances) defined as adversarial? Grievances in themselves are not adversarial - in my experience, management is the one who makes most of the "dispute" process adversarial. A (Third) point to consider: Subpart I, section 9901.901 says that employees have the right to organize and bargain collectively subject to many conditions, including DoD issuances that have yet to be defined. DoD could publish an issuance that removes employees' rights to organize and bargain collectively under this section. This is contrary to PUBLIC LAW. This section should be ENTIRELY removed. The Workforce's "Attitude" is highly important to the success of ANY endeavor, and employee behavior needs QUALITY management attention. But complaining about the lack of air conditioning demonstrates neither poor attitude nor bad behavior. These (proposed) rules need to CLEARLY define the limits of what constitutes Unacceptable Behavior", or "Bad Attitude". A (Fourth point): Section 9901.807(d)(3) says that the Department's action may not be reversed based upon the way a performance expectation is worded This means that a supervisor can give an employee a performance expectation that is impossible to achieve, yet the employee cannot challenge, let alone win an appeal on that performance expectation. This is totally unacceptable, and gives far too much devious authority to any dishonest Supervisor. NO to NSPS