| Comment Number: | OL-10511670 |
| Received: | 3/16/2005 4:41:09 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:
I applaud the DoD efforts to establish a more performance-oriented pay system. I have the following requests and comments: 1. Public Comment period. A 30-day public comment period is insufficient review time for changes concerning this significant issue. Please extend the public comment period for an additional 45 days. 2. Regulations rather than "issuances." The proposed NSPS regulations lack critical details on how various aspects of the new system will operate and instead rely upon future "implementing issuances." The majority of these details, for example establishment of pay bands, should instead be issued in the form of regulations subject to public comment consistent with the Administrative Procedures Act. 3. Pay retention. While several provisions in the proposal allay concerns that pay will be decreased upon conversion to the NSPS, the proposed regulations do not appear to address the following concerns: a. pay bands can be adjusted downward at a later date under 9901.322. b. pay bands may not have the same maximum pay opportunities as the current system. For example, a GS-14, step 1 currently has an opportunity to reach a GS-14, step 10; the proposed NSPS regulations only protect the current pay not the promotion opportunity under the current system. Thus, the pay band created under the NSPS may not include a range equivalent to a GS-14, step 10. I appreciate the opportunity to comment on these proposed regulations and understand the challenges that DoD will have to overcome in order to implement improvements to its system. Respectfully, Karen Heckelman