| Comment Number: | OL-10511324 |
| Received: | 3/16/2005 3:05:13 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:
The regulations as presented, are very general in nature. I suggest that the new system not be implemented until such time as the specifics are identified. For example, the pay banding and funding of awards. Also the grievance and arbitration regulations. These should be specified and then another comment period allowed, to ensure that the new regulations meet the intent of Congress when the new system was allowed to be pursued. The 'devil is in the details', as they say, and until the details are provided, it is impossible to determine if the new system will meet their lofty and admirable goals while maintaining the correct sense of Congress for the establishment of the new system. It is also noted in the section on Pay that primarily it will be based on performance, with locality pay presumably included (this needs to be specified). If the base pay portion goes away, this affects the areas such as Hawaii and Alaska, where we do not participate in the locality pay. If this happens (base pay increases cease), the compensation for Hawaii and Alaska (and other similar areas) needs to be addressed to bring those areas under locality pay. Proposals have been put forth by the Alaska and Hawaii COLA committees on how this can be accomplished. These proposals need to be considered before base increases are reduced or eliminated.