Letters

While his well-written article focuses on the undeniable impact on federal workers--and, indeed, on all workers--of higher pay, it attaches significantly less importance to the critical factors of being satisfied and fulfilled in the workplace. The National Treasury Employees Union is a leader in pressing for higher pay for federal employees. However, a higher paycheck is only one element of such satisfaction and fulfillment for most workers.

For example, whether the work venue is private or public, the most important element of any union contract always has been an effective grievance procedure; that's the first step in giving employees a meaningful voice in their day-to-day work lives.

Our contracts have such procedures and something equally important: a variety of mechanisms by which employees not only play a key role in identifying impediments to workplace satisfaction and productivity but also suggest and help implement solutions to these problems.

When the daily details of employees' work lives are more disruptive than helpful, the impact can be genuinely severe, both personally and professionally. You need only ask those employees of the Internal Revenue Service who didn't have the training and all the reference materials they needed to do an effective job, or those in the Federal Deposit Insurance Corporation who worked in insufficient and cramped space. NTEU addressed these issues and more like them and that is something that men and women in the workplace note and appreciate on a continuing basis.

There's another important point to be made about labor-management partnership. Government employees aren't just union-represented workers, they're public servants who want to do a good job and to accomplish their agency's mission effectively and efficiently. That they know they truly have a choice in getting that done goes a long way toward meeting those goals, for themselves and for the taxpayers.

Robert M. Tobias
National President
National Treasury Employees Union

Beware of Good Deals

I just read the December Travel column ("Look Both Ways Before Crossing"). There is another snag the government traveler should be wary of when renting a car. Never accept a lower rate for a rental car than is authorized on your itinerary. This will nullify the government contract including the collision damage and personal accident insurance.

I found this out the hard way when a rental agent, trying to do me a favor, offered to give me the weekend rate when the one car they had available wasn't quite ready. I told the agent, "the government is paying for it, so it doesn't matter to me." I subsequently slid on some ice and tagged a bumper. It took over six months to get it all straightened out. So I advise your readers to refuse any good deals on rates. Only take the upgrades.

Chris Pokorski
Washington

More on Negotiated Rulemaking

Thomas Kelly, director of the Regulatory Management and Information Office at the Environmental Protection Agency, takes issue with my analysis that negotiated rulemaking has failed to achieve its two main goals of saving time and reducing litigation ("Questionable Conclusions," Letters, October). He specifically charges that my research "mistakes ... the documentary record." It is Kelly who mistakes the record. I will highlight three of his errors.

First, Kelly claims that negotiated rulemaking saves time because, in his estimation, EPA has completed the average negotiated rule in fewer calendar days than other rules. Even if one accepted Kelly's rosy numbers, they fail to address the amount of staff time and resources it takes to conduct a negotiated rulemaking. Here the evidence is undisputed. Negotiated rules demand consistently more time, effort and resources. Even the study that Kelly approvingly cites found that negotiated rulemaking consumed nearly twice the organizational resources as did traditional rulemaking.

Second, Kelly asserts that EPA's lengthy farm worker protection rule was a "traditional rulemaking" and therefore I should have excluded it, as he does, in calculating the average time for negotiated rules. The fact is that EPA did negotiate the farm worker protection rule even though it failed to achieve full consensus. Including the rule in my study followed both appropriate standards for empirical research and EPA's own classification of the rule. In at least eight separate Federal Register notices published from the late 1980s through the 1990s, EPA explicitly classified the farm worker protection rule as a negotiated rulemaking. Only in the face of results that he finds less than complimentar does Kelly, a longtime proponent of negotiated rulemaking who oversees regulatory management at EPA, seek to reclassify the farm worker protection rule.

Finally, Kelly suggests that negotiated rulemaking has inspired EPA managers to expand their use of collaborative procedures. Whatever else EPA may be doing to seek input from the regulatory community, it has not initiated a single new negotiated rulemaking in more than five years. It is hard to square Kelly's continued advocacy of negotiated rulemaking with his agency's apparent abandonment of the procedure.

Cary Coglianese
Associate Professor of Public Policy
Harvard University

Correction

"The Power of Pay" (January) misidentified Jane Garvey as the secretary of the Transportation Department. She is the administrator of the Federal Aviation Administration.