| Comment Number: | OL-10512165 |
| Received: | 3/16/2005 10:50:58 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| Attachment: | NSPS Myths and Facts Mar05 (2).doc Download Adobe Reader |
Comments:
I am very wary of the proposed changes to the Personnel System. I am, unfortunately, not an expert in the current system nor can I make complete sense out of what is presented in this proposed rule. I understand the desire of the DoD to have a personnel system which can quickly be manipulated to fit changing needs. This system would do that, however, it appears that the rights that existing employees have will be reduced under this system. The system would favor the high performing employee – that is the good news. The system could also favor the well-connected. The system could be used to abuse those that march to a different drum, those that offer the contrary view, the aging employee, and the whistle-blower. Is that acceptable? We run the risk of losing thought diversity within the organization. I question the relevance of my position, managing Civil Works construction for the Corps of Engineers, to this national security need. I doubt that the “... NSPS is essential to the Department’s efforts to create an environment in which the total force, uniformed and civilians, thinks and operates as one cohesive unit.” That smacks of hyperbole. I recently received an attachment from my District headquarters, which I will attempt to attach, which indicates that civilians will likely be assuming duties that military personnel now hold. If that is the need for the NSPS, I would suggest the DoD adopt this program for these former military positions only. I also noted that the document was authored by DAITECH, which may be the same DAITECH which is to provide training assistance for this new program. I find that disconcerting. There will be costs associated with training the work force for this new system – costs in training and in lost production while the training is ongoing. Has that been considered in the overall scheme? There are a number of details which the DoD will flesh in once the NSPS is authorized. I am disappointed. Some specific concerns are below: 9901.607 Retention standing: Having over 25 years invested in Government service, this provision does me no favors, especially since the rating of record (which I assume to be the one most current rating) trumps my years in service. Perhaps the NSPS should look farther back in an employees rating history for a true indication of what the employee’s performance is. One mediocre year’s rating should not consign a longstanding performing employee to the ash heap. 9901.352 Setting pay upon reassignment: Why should a reassigned employee’s pay be possibly reduced? 9901.712 Mandatory removal offenses: Should not the list of these be fleshed out here for comment? 9901.715 Opportunity to reply: I am under the impression (perhaps wrong) that the time allowed for reply has been curtailed. This is not employee friendly. Limiting an employee’s representation is also not employee friendly. 9901.803 Waivers: I get nervous when MSPB provisions are superceded. Thanks for allowing me to comment.