Comment Number: OL-10501369
Received: 2/24/2005 6:02:57 PM
Subject: Notice of Proposed Rulemaking, Request for Comment
Title: National Security Personnel System
CFR Citation: 5 CFR Chapter XCIX and Part 9901
Attachment: LOCALITY PAY.doc Download Adobe Reader

Comments:

LOCALITY PAY. The cost of living in the area is the same for everyone who lives in this area, regardless of their income, job title, or profession. Further, if locality pay is lowered for employees other than those in engineering and scientific fields, that would lead to a loss of employees and difficulty in recruitment in all other professions. It cannot be viewed as anything other than discrimination against non-scientific personnel that must carry the same local area cost-of-living burdens, without being given the added incentive pay already enjoyed by scientists and engineers in comparable grades. For example, the turn-over rate of contracting personnel is enormous -- it would go even higher with the loss or downward adjustment of the locality pay: If the intent of keeping the locality pay as is for engineering and scientific personnel is for recruitment and retention, then it does not seem to be working well with the continual shortage of these professionals. The locality pay only offsets the cost of living in the area and is not an increase in wages. In fact, data at the OMB website shows that historically, the OMB has recommended significant raises in locality pay for this region (LA) that has not been implemented. OMB does not set the locality rates in a vacuum. All areas of this region are having recruitment and retention problems with locality pay. Los Angeles AFB has instituted a retention bonus of 1and 1/2% that is paid bi-weekly. It doesn't come out to a lot, but even with the additional money LAAFB is still having problems with retention and recruitment. The expressed direction of this personnel system revamp appears to be detrimental to the average government employee.