Overall there is NO NEED to reinvent the wheel.  Current regulations are sufficient along with the pay schedule.  This new system gives more power and control to managers and supervisors, whom many now do a poor job.  (Does 9/11 ring a bell, how many good employees reported events upward but no one responded?)  If you don't think the current system works, ask an employee who has filed EEO or some other action and watch how the system turned on them.  

The part of the system that needs to be re-configured is HR and the managers and supervisors.  As it stands now, if you "PLEASE” the supervisor and give them what they WANT (regardless of the law or mission) you will be fine.  If not, you will be labeled.   A change of management and the HR system is in order.  Change the supervisory and HR chain.  OPM can handle the potential hires to an agency and the Agency can contract out the managerial needs to a bonded contractor.  Currently, the system allows too much power to managers to promote and hire who they will and managers control HR.  The system is already theirs, despite what the law says.  A bonded contractor would be held financially accountable for any law suits versus the tax payers.  Try it and watch the difference.  Non-performing employees at any level will be out the door and the mission of the agency can be enhanced.  A contractor will be more fair and equitable because the "good olde boy system" will be broken and there is real penalty.  

All the talk about security in the document is just that talk.  In the real world, report a violation (as I did) and watch what happens.  Yes, the violation was dealing with an aspect of national security.     

This new system promotes a system giving virtual control to supervisors.  Federal employees are already at a disadvantage in legal fights for fairness and to limit time is criminal.  Have you ever tried to obtain legal counsel on a federal case?  The legal costs are too tremendous along with emotional and mental trauma and many a good employee jests walk away.   Where is the fairness that is talked about so much in this country?  

If you are going to give supervisors control that supersedes legal rights afforded under the U. S. Constitution, and then change the law whereas, the supervisors MUST PAY their own legal cost.  As it stands now, tax payers are paying their defense.  This would be an incentive for management to watch playing the good ole boy system and to play honestly by the established rules versus engaging as exceptions to the law.  

The pay bands are referenced but where is there a conversion chart and more specific data on the pay band?  None was provided for review.  

    http://www.cpms.osd.mil/nspscomments/