| Comment Number: | OL-10512267 |
| Received: | 3/17/2005 2:59:13 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:
1. "The Case for Action", page 7552, states in part..."DOD Civilians are unique in government: they are an integral part of an organization that has a "military" function. As a member of the U.S. Army Corps of Engineers, we also have a critical "civil works" function. There is an Assistant Secretary of the Army for Civil Works. We are somewhat unique to DOD in that we also perform work that is of the utmost importance that involves vital infrastructure for thousands of citizens (flood control dams/levees, locks and dams for navigation, etc.), yet no where in the entire proposed regulation is there an explanation of this function - This deserves special attention that should be considered in the follow-on "implementing issuances". 2. General Comment. It has taken almost 2 years to develop this document, yet only 30 days has been set aside to review a complex document that will affect the careers and livelihoods of thousands of employees. This is an insufficient amount of time for such a massive change. Request that the review period be extended for at least another 60 days to allow sufficient time for employees to digest and understand the implications and provide meaningful comments. 3. Page 7554, "Process" states in April 2004, senior leadership approved the collaborative process....and further under "Outreach" it states.....in April 2004, the PEO developed and implemented a communications strategy.......and further under "Outreach to Employees", it states "the PEO sponsored a number of focus group session and town hall meetins at various sites across DOD". At no time, as a current DOD employee was I notified of any such communication plan, nor was I notified of any such focus group activity that I would have a chance to participate in. Why not??? In my view, the communciation plan failed miserably, and continues to fail. The first vague information on this began to surface in our DOD organization a few months ago - and in most cases, upper management indicated "we don't have any details - we don't know much, etc. etc." What kind of communication is that?? This is unacceptable. As stated above, this whole process needs to slow down and employees given ample opportunity to have full disclosure about what this change means and the opportunity to comment on it. 4. Page 7556, General Provisions, Subpart A. The document itself is very superficial - lots of general statements and platitudes, but no "detail", i.e., it's difficult to comment on "philosophical" wording. As an example, in many places, there is references to "Implementing Issuances", such as the one in thies paragraph that states...."Supart A also allows DOD to prescribe internal Departmental issuances that further define the design characterisitcs of the new HR System". THIS IS WHAT I SHOULD BE SEEING IN THIS DOCUMENT. WE NEED TO SEE AND BE ALLOWED SUFFICIENT TIME TO REVIEW AND COMMENT ON THESE "IMPLEMENTING ISSUANCES". Will we be allowed to review and comment on these "Implementing Issuances" before the first "spiral" begins?? If not, why not? Be specific in your response. 5. Page 7559, Table 1. There is not enough explanation of the relationship of the Engineering and Scientific Supervisory/Managerial Pay Schedule to the Engineering and Scientific Professional Pay Schedule in regards to the three levels, and the below three bands. Provide more information on how these are related. It would also appear that if the three bands in the lower part of the table represent first line, second line and third line supervisors, doesn't this limit flexibility in "organizational structure", which is counter to the entire purpose of this new system?? More explanation of this is needed.