5 CFR Chapter XCIX and Part 9901 

I write as a private citizen to voice my concerns about the proposed NSPS, in particular with its proposed classification and pay systems.  Subparts B §9901.201 - 222 and C §9901.301 - 373   My concerns are with:

1.  An imposed pay system.  The combined classification and pay system gives the DoD authority to create a brand new pay system, and to determine each employee’s locality and base pay, and each employee’s yearly pay increase, without requiring any bargaining with the employee representatives--bargaining was mandated by the legislation providing for the creation of the NSPS.  Experience in the private sector suggests that imposing a pay system from on high creates as many problems as it solves, and that the attendant problems of recruitment, retention, morale and job performance are exactly the problems that could undermine the national security mission 

2.  Experience elsewhere.  Public services elsewhere have experimented with pay banding along lines similar to those proposed by the NSPS.  
>The British public service, for example, has reported ongoing problems of pay progression, non-consolidation and no increases at upper band levels with attendant morale and retention problems which plague the service.
>The British government of Hong Kong in a 2001 report found problems in finding comparable jobs in the private sector, so that this pay strategy was not pursued, and adjustments on civil service pay were ultimately made on the basis of cost of living data.  The service also reported recruitment and retention problems, especially with junior civil service officers.

3.  Bypassing the bargaining representatives.  It is notable that the DoD unions have apparently expressed their willingness to negotiate over pay and over a new pay system that would provide for many of the elements DoD wants: 1) a component to keep all employees comparable with the private sector; 2) a locality component to keep all employees comparable with the private sector and living costs; and 3) a performance component with fixed percentages tied to performance levels.”
4.  Missing details and hidden processes.  Many details of vital importance to employees are not spelled out in the proposal  --  for example the grouping of jobs into occupational clusters, which positions will be in each pay band, the pay rates  -- minimum and maximum-- of each band, or the pay point values which govern performance-based pay progression within each band.  Critical decisions on matters such as pay rates for each band, annual adjustments to these bands and locality pay supplements and adjustments must be made in public forums like the U.S. Congress or the Federal Salary Council, where employees and their representatives can witness the process and have the opportunity to influence its outcome.
5.  Insecurity, unpredictability and internal divisions for pay competition.  If the system proposed is implemented, employees will have little or no basis to predict their salaries for the next year, or whether they will receive any increase at all, despite having met all performance expectations identified by DoD.  Does this sound like the “individual career growth and opportunities” (“The case for action: p. 7553) that is supposed to be a by-product of the new system?  The “pay-for-performance” element of the proposal could even pit employees against each other for performance-based increases.  For example, the results of pay pooling combined the system of individual “shares” based on a supervisor’s evaluation can mean that:
Raises could vary widely within pay pools; the better your group performs, the lower the value of your share, and the worse your group performs, the higher the value of your share.  That sort of internal competition for pay increases clearly works against the spirit of teamwork needed to keep our country safe.  Indeed, transforming the management of its people—as it is envisioned in the NSPS--is persuasively counter-productive to the ultimate over-arching goal of transformation and the mission of the DoD.
6.  Recommendation: Complete withdrawal.  The pay and classification proposals should be withdrawn and published for comment only when: 
a) the Agencies are willing to disclose the entire system to Congress, the American public, and the DoD employees; and 
b) the Agency consult with the bargaining representatives to devise a more fair and reasonable system which must contain the transparency and objectivity of the General Schedule.