| Comment Number: | OL-10512224 |
| Received: | 3/16/2005 11:57:18 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 had originally planned to write specific comments to specific parts of the rule, but this rule is sufficiently vague as to leave most things up to interpretation and it is very clear that DoD plans to implement this new system regardless of the comments made here. If I were running my own for-profit, private industry enterprise, these are the kind of rules I would want to follow with my employees. They give management complete control while making a pretense of employee participation in decisions. They spell out a host of ways that employees and their representatives can be involved and informed and give comments to make them feel like they are a part of the process without giving them any real power to insure that their suggestions or concerns are anything more than considered and recorded. The Secretary and Director are required to include employee representation in the process but are not required use any of their suggestions. Do you realize there are over a hundred references to future “implementing issuances” that will define the details of how this new system really effects employees pay, job security, and working environment? Without these details in this rule it is (although a lengthy and wordy good start), only a promise that at some future date, the most important details to the employees will be defined and told to them. In the meantime, those of us in the first few spirals that will already be under the new system, will not have the old system to guide us nor will we really have the new system. I fully understand that this is a work in progress, a new process that will be designed over the next few years. However, considering the lack of specific details on such key items as pay rate methodology, performance rating methodology, and position classification, God help those of us in the pilot spiral and the next few phases of deployment. These rules do appear to provide great flexibility to readily adjust/modify the process and corporate structure, but they set the stage for an environment where the employee has little definition of what is expected of them from one month to the next, one week to the next, or even one day to the next. This removes security and structure that was a large part of the incentive for employees to stay in Government service rather than be lured away to private industry.