Comment Number: OL-10508169
Received: 3/14/2005 7:42:18 PM
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:

After reviewing the Federal Register notice re: NSPS, I could find no reference to the annual cost of living increases (usu. 2-3%). Would Federal employees under NSPS continue to get these minor increases in pay? What about the Regulatory Branch? Regulatory's budget is a separate line item in the Corps of Engineers annual budget. Congress mandates that this budget cannot be increased nor decreased except by an act of Congress. Therefore, how will the pay pools (Subpart C) be implemented for Regulatory, since this money cannot be combined with funds outside of Regulatory? Most Corps Districts have less than 60 employees in their Regulatory Branch. Will Regulatory's pay pool be separate from everyone else's? If the pay bands are supposed to modernize the civil service pay system, why make hard and fast upper limits to basic pay. If an employee is truly a peak performer, shouldn't he/she be able to move on up? This sounds like a hold over from the current system. To truly revolutionize the civil service pay scale, there should only be one "band" that encompasses GS-1 to GS-15 pay grades. Without more information regarding the individual pay bands, we have no idea where we fall into the band system (e.g., a GS-12/step 10 = Senior Expert upper limit?). For this reason, we cannot give more specific comments on this topic. Alaska and Hawaii are currently paid Cost Of Living Allowances (COLA). The rest of the U.S. is paid locality pay. Are Alaska and Hawaii going to receive locality pay under NSPS? As you are aware, COLA does not count toward retirement like locality pay does, and when the rest of U.S. gets a 3% cost of living increase, Alaska and Hawaii only receive 2%. The other 1% goes to an increase in locality pay which is not paid to Federal employees in these two States. Therefore, a combination of COLA and locality pay, or replacement of COLA with locality pay would benefit those wishing to retire from Federal Service in the states of Alaska and Hawaii.