| Comment Number: | OL-10509961 |
| Received: | 3/15/2005 10:05:04 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:
Regulatory Review – Page 7574 The proposed rule states that, “The marginal cost of the accelerated payment of earned WGIs (wage-grade increases) is difficult to estimate, but is not a significant factor in the benefit cost analysis for regulatory review purposes.” First, if it’s difficult to estimate, how do you know that it’s not significant? Secondly, why is this difficult to estimate? The data are available as to who will be entitled to a step increase and when. It seems that one must only make an assumption as to the interest rate(s).