| Comment Number: | OL-10512051 |
| Received: | 3/16/2005 8:39:39 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | Attatchment to comments on NSPS.doc Download Adobe Reader |
Comments:
You say in the opening page (#7552) of The Federal Register that you want to create a new National Security Personnel System (NSPS). A human resources management system for the DoD that protects the civil service rights of its employees by transforming the way it leads and manages the people who develop, acquire, and maintain our Nation's defense capability. You say that DoD civilians must complement and support the military around the world in every time zone, every day. That is what I thought I was doing as a Federal employee in the DoD for the last 17 ½ years by being an integrated, flexible, and responsive part of the team. You sat that “despite the professionalism and dedication of DoD civilian employees, the limitations imposed by the current personnel system often prevent managers from using civilian employees effectively.” I say that isn’t so. I say that in the large percentage of time, managers are the ones that are ineffective because they were never trained to be managers. In stead they were kicked up the ladder because no one could get them do anything as employees. Then once they became managers, it became “do as I say as not as I did.” Which in most cases usually wasn’t much. Next on page 7555 of the Federal Register, you lay down some guiding principals; “Put mission first-support National Security goals and strategic objectives.” “Respect the individual – protect rights guaranteed by law.” “Value talent, performance, leadership and commitment to public service.” “Be flexible, understandable, credible, responsive, and executable.” “Ensure accountability at all levels.” What I can’t understand is why these goals can not be met with the current human resources management system. Is this system so broken that it can not be fixed to meet theses goals. It reminds me of the saying my mother used, “your throwing the baby out with the bath water”. Now lets get down to some of the specifics. Under general provisions-subpart A, Page 7557 you talk about “Continuing Collaboration” . And a system, known generally as the "30/30/30" process. I would thing that if you want to make as many changes in the DoD human resources management system and you wanted to get it right. Shouldn’t a system that will eventually effect over 700,000 DoD civilian employees take more time that to consider. Especially since most of the details haven’t been worked out yet. And yet on the next page it goes on to say that,” this process does not affect the right of the Secretary to make the final determination as to the content of implementing issuances,” Even if this “Continuing Collaboration” offers the opportunity for employee representatives to participate meaningfully in the process it sounds like if the Secretary doesn’t like what he hears he can go ahead and do what he wants to anyway. Under general provisions-subpart B, Page 7558. DoD (in coordination with OPM) will establish broad occupational career groups by grouping occupations and positions that are similar in types of work, mission, developmental/career paths, and/or competencies. Sounds like you are going to end up with a generalized workforce in which no one will have a specialty. And if no one has a specialty, than there is no need for any difference in pay. Sounds like I could end up having such a broad band of duties that there is no job description that could cover it all. Currently managers have the rights to assign work. Just how much more work will I be expect me do that is currently not in my job description? If there are too many job descriptions now it is because managers made a lot of them up to keep from getting themselves and other managers from being effected in a RIF. Job descriptions can be simplified without NSPS. And lets not to forget to mention premium pay. If that is taken away, very few people will want to work overtime. What will that do to help National Security? Basically, I can not see a reason for a lot of the proposed changes under sub part B.