Comments:

Program Executive Office

  National Security Personnel System

  Attn: Bradley B. Bunn

  1400 Key Blvd, Suite B-200

  Arlington, VA 22209-5144

  Please review and consider the following comments:

  Re Classification - Subpart B (p 8), and Section 9901.212, Pay schedules

  and pay bands (p 29)

  My principal concern is with "pay banding".  There is more to job satisfaction and effectiveness than higher pay; there is also the "equivalent rank" status that comes with working within the hierarchical framework of the military and being recognized as serving at certain grade levels, such as GS-15 (O-6 equivalent).  That distinction will be blurred or lost under pay banding.  No one will know who is being paid a higher rate and who is not as that is not public information.  I would prefer to see greater flexibility in moving between the existing grades and steps, based upon performance.  For example, it should be easier to promote a GS-13, Step 10 to GS-14, without the requirement to obtain approval of a position upgrade based upon increased responsibilities and then opening it up for competition.  In my current job, being an O-6 equivalent means something and it comes with certain protocol benefits that may be lost in the proposed pay banding system unless some effort is made to identify "equivalent" ranks/grades.

  Re Performance based pay (p 10), and Sections 9901.341, et seq:

  We all know that performance appraisal systems are subject to inflation, i.e. almost everyone is rated "outstanding", no matter what means is used to discourage it. That is just human nature. Many efforts have been employed over the years to overcome this strong tendency but to my knowledge, no agency in DOD has ever succeeded in doing so. This will make it difficult, if not impossible, to achieve the objectives of performance based pay in any meaningful way.  In my view, only the clearly unacceptable performers will be affected by this system.Everyone else will be eligible for increased pay.