Comments:

After reading through the regulation, I find a serious flaw in your premise. The Federal Government has not, traditionally, hired and kept competent managers who would manage employees in a fair and unbiased manner.

  I have worked nearly twenty years in the Federal system and during that time I have experienced four types of managers. Pay banding appears similar to the way awards are currently given to employees. So in comparison, the types of mangers I've experienced include:

     1) The manager that works very hard and reviews their staff's work on a regular basis and gives awards that reflect employee performance. This type of manager dies young.

     2) The manager that bonds with certain employees at the water cooler and sports bars (after hours). This manager gives their "good guy" employees the awards no matter how little work these employees produce.

     3)  The manager that has certain departmental agendas, i.e. pet projects that they like to hire extra staff for even if the function of the department is harmed and the department gets deeper and deeper in the red every year. This manager doesn't give awards and tries to cut corners on essential programs in order to feed his habit of wanting recognition for being on the cutting edge.

     4) The manager that takes all the award money for himself. No decisions or added effort in this solution.

  If a section were added to the regulation to include requirements for management training and better oversight of those making pay raise decisions, I would embrace this regulation. But, as it is, the regulation does not take into consideration the shortcomings of management and I fear the government will continue to lose their very best employees if this regulation is implemented as is.