Comment Number: EREG-000001
Received: 2/14/2005 8:00:00 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
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Comments:

My comment relates to an example provided at the NSPS web site. Though the Federal Register did not specifically address which grades would be converted to which bands, my comment involves the GS-13 conversion. A laboratory example was presented which had converted the GS13 employees into a lower band. This band included GS-11 thru GS-13. The placement of GS-13 into the lower band may have been effective in an organization dealing with only with scientific research. Such an organization is likely to have been "top heavy" and not reflective of most DoD offices.

The historic division of the GS-13 level has been equated with a "field grade" assignment. In fact, civilian deputies to field grade officers are GS-13's and above. Most GS-13's are serving in leadership, management and figure head positions which fully warrants the inclusion of this grade in the top pay band. Failure to place the GS-13 grade in the top band would severely limit a commanders/senior managers and place the leader/manager in the same band at the supervised. It would then be common for employees with less responsibility to potentially be paid more. Failure to make this distinction during the conversion will threaten the success of the new system.