Comment Number: OL-10500610
Received: 2/18/2005 10:29:28 AM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
No Attachments

Comments:

1. Re: section 9901.212: discussion on broad bands. Suggest BROADER bands than those in the demostration series. Most of the examples I have seen show only two (2) GS levels for a BROADBAND, especially above GS-11. This does not seem broad, and with the vast number of responsibilities, and differences we have in positions GS-12-15, it would be prudent to give management more latitude in determining level of effort, mission, responsibilities and function. 2. Re: Section 9901.331: Local Market Supplements: I am assuming this is to replace locality pay. I still do not fully understand how locality pay is determined. I live in San Diego, with the one of the highest cost of living scenarios in CONUS. Our housing prices are higher than LA, our gas prices are higher than LA, and our energy prices are higher than LA, and we have less people (hence a smaller employment pool to choose from) yet our locality pay is less than LA as well as a number of other urban areas. If Market Supplements replace locality pay, I would like to see the rationale for determining the MARKET with an emphasis on data and factual information on the cost of living and market availability of employees. 3. Re: Section 9901.409: Rating Performance: In the demonstration projects I have reviewed, a Performance Review Board was in place to provide for checks and balances during the rating period. I don't see this mentioned in the proposed rules. Please identify where the checks and balances will take place and the methodology for ensuring a third party will be responsible for fairness.