Comment Number: OL-10501910
Received: 2/28/2005 12:52:14 PM
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 comments concern pay banding levels (section 9901.211 and 9901.202) specifically as they relate to civilian attorneys within Department of Defense. I work primarily with labor law matters and am currently topped topped out at the top of the GS-13 scale, having previously worked as a GS-14 at Department of Justice on similar matters. It seems quite clear to me that the attorney pay band should at least include GS-13, GS-14, and GS-15 in the same pay band, if not GS-12 as well. This would make it much easier for DOD to obtain high quality representation from other branches of government and encourage retention of personnel who would otherwise be tempted to transfer to other agencies. It is quite apparent that the current grading system in DOD is low compared to other agencies. Bottom line: the GS-13 should be in the top pay band for attorney positions. Please feel free to email me at ken.muir@us.army.mil if I can be of any assistance. Regards, Ken Muir