| Comment Number: | OL-10512232 |
| Received: | 3/17/2005 12:05:46 AM |
| 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:
16 March 05 Earl Hem 10081 Canyonview Ct. Spring Valley, CA 91977-6921 I currently work for the Supervisor of Shipbuilding Bath Det San Diego where I have been employed for 18 years in a nonsupervisory role. Prior to that I was employed at the Long Beach Naval Shipyard where I worked a total of 9 years with the last 4 years as a first line supervisor of 12 to 21 employees. With that history, I can say I have experience the government work environment from both sides. The current management regulations that I am working under were not enacted without due consideration for previous rules and regulations. There were reasons for what regulations we are now using as guidance. They were adopted in reaction to public and private pressure to improve an unsatisfactory situation that embraced the abuse of the system fostered by the previous regulations. That is the usual and typical cycle of legislative regulations: act, react, counter-act, and counter-react. The cycle continues. The regulations we have now are cumbersome and inefficient for most elements of employment cycle: hiring, managing and laying off or firing. But it is not impossible to do each of the elements of employee supervision given adequate skill and foresight. When I read in the Federal Register Proposed Rules (2/14/05) such phrases as “provisions of title 5 may be waved or modified” and goes on to list those chapters (see below) that are to be casually deleted serves to give me caution: · Chapter 31, 33, and 35 (dealing with staffing, employment, and workforce shaping) · Chapter 43 (dealing with performance appraisal); · Chapter 51 (dealing with GS job classification); · Chapter 53 (dealing with pay for Federal employees) · Chapter 75 (dealing with adverse action) · Chapter 77 (dealing with appeal of adverse actions) And I am alarmed when I couple the above with such phrases? as “DoD and OPM are not limited by any provisions of title 5 or implementing regulations relating to- · The methods of establishing qualifications requirement for, recruitment for, and appointments to positions; · The methods of assigning, reassigning, detailing, transferring, or promoting employees; and · The method of reducing overall agency staff and grade levels, except that performance, veterans’ preference, tenure of employment, length of service, and such other factors as the Secretary considers necessary and appropriate must be considered in decisions to realign or reorganize the Department’s workforce.” When I read the bullets above of what is to be eliminated, the first thing that comes to mind is that many of the Civil Service regulations that were enacted to guard against and reduce (note I do not say eliminate) the tyranny of favoritism and partiality will be lost. We will revert back to the system of nepotism, cronyism and eventual despotism of the early to mid-1900s where, with every change of the political scene, civil service jobs were lost or won. That which is now happening in the Office of Special Council will become the norm. If you aren’t a “yes” person, you’re not on the team and can expect to be transferred without choice to Dallas, Oakland or Detroit, with no regard of impact to family or attachment to a community. In closing, let me say that I am near retirement, well past the minimum age. I do not write this letter for myself. I write it for my country and for my coworkers that I see coming into the workforce in years to come. This imposition of NSPS regulations, as they are written, is not the answer. Thank you. Earl Hem 619/698-4494