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Washington, D.C.—The head of the nation’s largest independent union of federal workers today warned of the high risks of failure—and the accompanying costs to the nation—involved in pending new personnel regulations at the Department of Defense (DoD).

President Colleen M. Kelley of the National Treasury Employees Union (NTEU) said these “unnecessary and dangerous risks” arise from the failure of DoD to involve front-line employees and their representatives in meaningful ways in design of the new regulations, along with the sharp restrictions in employee and union involvement in day-to-day matters impacting working conditions contained within the new system.

“Other federal agencies should take note that any system that minimizes employee input into changes as far-reaching as these is likely to fail,” the NTEU leader said.

President Kelley added that the DoD regulations, which are expected to be published in the Federal Register next week, “are in a lot of unfortunate ways a mirror image” of the worst of new personnel regulations recently announced for the Department of Homeland Security (DHS).

NTEU represents more than 15,000 DHS employees and has filed a federal court suit alleging that DHS and the Office of Personnel Management (OPM) overstepped their authority with regulations that sharply cut back employee rights in labor relations and collective bargaining, and that fail to protect their due process rights.

“As with the DHS regulations, those advanced by the Defense Department will go a long way toward demoralizing the DoD work force, particularly with their limits on collective bargaining and the shrinking of independent third-party review of labor-management disputes.”

She also warned about the negative effect on agency recruitment and retention efforts. “Massive changes impacting employee pay, performance management, appeals and labor relations systems, will hurt—not help—recruitment and retention efforts,” she said. “DoD’s actions will prove to be very costly lessons for taxpayers and the nation.”

At the same time, the NTEU leader said the projected DoD pay-for-performance system “promises to have little to no credibility with employees.” The key problem with pay-for-performance, President Kelley said, is the inability of managers to differentiate between and among the job performance of employees, compounded by the lack of a credible performance appraisal system to provide them with the tools they need to apply the pay system in an appropriate and workable manner.

Pay-for-performance “simply is not going to work as the administration envisions, either at DHS or DoD,” Kelley said.

NTEU is the largest independent federal union, representing some 150,000 employees in 30 agencies and departments.