Washington DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Damon B. Ford
Classification Appeals and FLSA Claims Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


05/03/2022

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision changes the series of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702.  As discussed in this decision, our findings also show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E of the Introduction.  Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings.  The servicing human resources office must submit a compliance report containing the corrected PD and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as District Ranger, GS-0340-12, but she believes it should be graded at the GS-13 level.  The position is assigned to the Tongue Ranger District (District), Bighorn National Forest (Forest), Rocky Mountain Region, R-2, U.S. Forest Service (FS), U.S. Department of Agriculture, in Sheridan, Wyoming.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant states she performs work identical to District Ranger, GS-0340, positions assigned to the Forest but graded at the GS-13 level.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position.  By law, we must make that decision solely by comparing her current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified correctly, as the basis for deciding her appeal.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM PCSs and guidelines.  The agency also has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions.  The appellant provided PD number FS2275 for a District Ranger, GS-0340-13, which the organizational chart on record shows is assigned to her Forest counterpart at the Medicine Wheel Ranger District.  The GS-13 PD appears to describe duties and responsibilities similar to the appellant’s position.  Because we are unable to determine whether work performed by the GS-13 position is materially different from the appellant’s position to warrant a different classification, we have insufficient evidence to task the agency with a consistency review covering the Forest’s District Ranger positions.  Nevertheless, as discussed on page ii of this decision, the agency is obligated under 5 CFR 511.612 to review its classification decisions for identical, similar, or related positions to ensure consistency with this decision.

If the appellant considers her position so similar to others at the Forest that they all warrant the same classification, she may also pursue the matter by writing to her regional or headquarters human resources office.  In doing so, she should specify the precise organizational location, classification, duties, and responsibilities of the positions in question.  If the positions are found to be basically the same as hers, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to her the differences between her position and the others.

Both the appellant and her immediate supervisor believe the appellant’s current PD number FS2274 is not completely accurate because it does not adequately describe some of her duties, i.e., it does not identify all supervisory authorities delegated to her position.  A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that make up the work performed by the employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position, and not simply a PD.  This decision is based on the work currently assigned and performed by the appellant. 

Nonetheless, the appellant states her PD does not recognize that she hears and resolves group grievances or serious employee complaints; makes decisions on nonroutine, costly, or controversial training; and approves expenses comparable to within-grade increases, extensive overtime, and employee travel.  Although we discuss her supervisory authorities in detail under the grade determination section of our decision, we agree that her position is delegated authority to approve expenses comparable to within-grade increases, extensive overtime, and employee travel.  Because her PD does not fully identify the authorities delegated to her position to allow for proper evaluation of her supervisory work, we find the official PD does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise the PD to reflect the position’s responsibilities.

Position information

The appellant’s Forest is located in north-central Wyoming and consists of over 1.1 million acres divided into three Ranger Districts (i.e., Tongue, Medicine Wheel, and Powder River).  District Rangers are responsible for making land management decisions for their assigned area of the Forest with numerous major resources and protection considerations.

The appellant manages the resources, goods, and services of the District’s half-million acres.  She establishes and implements the development, production, conservation, and utilization of natural resources associated with her District.  This includes managing the District’s heritage, wildlife, range management, recreation, and fire programs.  The organizational chart shows the appellant directly supervises eight positions.  Of those, the agency classified three as supervisors based on the positions meeting the coverage requirements for evaluation by the General Schedule Supervisory Guide (GSSG).  These positions include a Supervisory Natural Resources Specialist (Recreation), GS-0401-11; a Supervisory Rangeland Management Specialist, GS-0454-11; and a Supervisory Forestry Technician, GS-0462-11.  The appellant is also the second-level supervisor over two Supervisory Forestry Technicians, GS-0462-08.  The appellant is the second- or third-level supervisor for all other District positions.  She estimates spending at least 50 percent of her time supervising District staff (i.e., approximately 20 permanent and 14 seasonal employees), and the remaining time on project-related and other nonsupervisory duties.  We discuss her duties in more detail in our series determination section of this decision.

In reaching our classification decision, we carefully considered all information provided by the appellant and her agency including her official PD which, although not completely accurate, we have incorporated by reference into this decision.  In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and her supervisor (Forest Supervisor).

Series, title, and standards determination

The agency placed the appellant’s position in the Program Management Series, 0340, which covers all classes of positions the duties of which are to manage or direct, or to assist in a line capacity in managing or directing, one or more programs, including appropriate supporting service organizations, when the paramount qualification requirement of the positions is management and executive knowledge and ability and when the positions do not require competence in a specialized subject-matter or functional area.  Positions in which specialized subject-matter or functional competence is a necessary qualification requirement are classifiable to whichever specialized or general series is most appropriate.  Page 2 of the Position Classification Flysheet for the 0340 series instructs:

In the [GS] position classification system established under chapter 51 of title 5, [U.S.C.], the positions addressed here would be two-grade interval positions at the grade GS-13 and above.  [emphasis added]

As discussed in our “Grade determination” section of this decision, we find the appellant’s position is properly graded at the GS-12 level.  Therefore, her position is not classifiable to the 0340 series due to the GS-13 and above grade requirement.

In addition, positions in the 0340 series do not require competence in a specialized subject-matter area.  Our fact-finding shows the appellant’s position clearly requires knowledge of natural resource management.  In the “Knowledge Required by the Position” section of her PD, it states:

District Rangers, responsible for leading an organizational unit and implementing Forest policies, are expected to be proficient in the management competencies of External Relations, Communications, Environmental Awareness, Leadership, Interpersonal Relations, and Management Functions, as well as being knowledgeable in Natural Resource Management.

Natural Resource Management – Knowledge of natural resources management to provide leadership for the District’s programs.  Ability to adapt approaches and precedents to meet the distinctive resource protection, development, and management situation.  An understanding of land management to provide leadership for integrated management of public forest lands.  Ability to assess local social and economic conditions and trends, identify needs, and to provide the leadership for adjustments in the District’s programs.

During our interview the appellant explained her position requires the ability to think critically for science-based processes, communication skills, leadership, etc., but the work does not necessarily require professional knowledge in natural resource management, forestry, or related fields (the appellant’s degree is in engineering).  The Forest Supervisor concurred stating during his interview that recruitment for District Ranger positions have traditionally come from employees of Federal land management agencies such as the Bureau of Land Management (BLM) and National Park Service (NPS).  Line work in those agencies typically requires knowledge of natural resource or land management.

The appellant directly supervises eight positions and of those four are professional positions:  (1) Supervisory Natural Resources Specialist (Recreation), GS-0401-11; (2) Supervisory Rangeland Management Specialist, GS-0454-11; (3) Wildlife Biologist, GS-0486-11; and (4) Archeologist, GS-0193-11.  She provides administrative and technical supervision for District staff including its professional employees.  For example, she interacts daily with the GS-0401 Supervisory Natural Resources Specialist, who administers recreation passes and permits for the District.  The appellant, who is the decision-maker and signatory authority on permits, and the specialist discuss applications for permits, e.g., from cabin owners requesting repairs to residences on Federal property; tour guides requesting permission to host rock climbing, hunting, or other trips; and individuals planning weddings, large events, and other special recreational events at the District.  In addition to making decisions when the subordinate specialist recommends closures or changes to recreation sites, the appellant ensures the closure or change is implemented to manage the site (e.g., by changing signage).  After conducting field surveys, the Wildlife Biologist, GS-0486-11, also discusses with the appellant any concerns affecting specific wildlife within the District.  After discussing the impact and possible mitigations, the appellant works with recreation and/or other staff on the mitigations to protect wildlife, e.g., installing gates to protect bats hibernating at the mouth of a popular recreational cave.  In addition, the appellant participates on the Forest Leadership Team which includes the Forest Supervisor, other District Rangers and Forest-level staff, to develop and organize Forest policies and programs for management and protection of natural resources.

We do not find it plausible the appellant could perform such work (i.e., making critical natural resource management decisions, working and coordinating with multiple agency partners, and providing supervision to administrative, technical, and professional District staff) based solely on management and executive knowledge.  While we recognize the appellant is responsible for implementation and oversight of the District’s overall programs, including such program management duties as participating in the development of individual program plans, establishing objectives, tracking their accomplishment, and attending regular information planning sessions, these responsibilities are carried out by applying specialized knowledge and skills.  This conclusion is supported by our fact-finding including information disclosed during our interviews and key statements in her PD which indicate the appellant’s actual duties could not be effectively performed without requiring and applying competence, operational understanding, and sufficient knowledge of natural resource management of the District’s various occupational fields to make decisions and set priorities for managing the District’s natural resources. 

Because the appellant’s position requires specialized subject-matter knowledge, we note that the “Additional Occupational Considerations” section of the 0340 series flysheet states that positions, like the appellant’s, “which manage, direct or assist in a line capacity one or more programs, when qualifications of the position do require competence in a specialized subject-matter or function area”, such positions should be classified in the appropriate specialized series, or if none is established, in the Miscellaneous Administration and Program Series, GS-0301.

We initially considered the Park Ranger Series, GS-0025, which includes positions the duties of which are to supervise, manage, and/or perform work in the conservation and use of Federal park resources.  This involves functions such as park conservation; natural, historical, and cultural resource management; and the development and operation of interpretative and recreational programs for the benefit of the visiting public.  Although the GS-0025 PCS defines park “to include national monuments; seashores; parkways; historical, military, natural, and urban parks; lakes; and other related areas administered by the Departments of the Army and the Interior,” we note page 5 of the Handbook of Occupational Groups and Families (Handbook) removed agency restrictions by stating that all agencies may use any occupational series.  That the appellant’s position is assigned to the FS rather than to the Departments of the Army or Interior would not automatically preclude classification of her position to the GS-0025 series.

Similar to GS-0025 positions, the appellant is responsible for the day-to-day work of the District, the direction of its operations, and providing guidance to its staff on dealing with operational problems.  Nonetheless, the primary responsibility of her position, as stated by her PD, is for “administering an area of National Forest land with numerous major resources and protection considerations.”  The GS-0025 PCS describes three broad functional areas:  interpretation, visitor protection and services, and resource management.  As described by the GS-0025 PCS, resource management involves “the protection, management, and conservation of the natural, historical, and other characteristics of the area through activities such as forest, wildland, and structural fire prevention and suppression; boundary encroachment and land-use activities; fish and wildlife management; preservation of natural, cultural, and/or historical structures and objects; and flood control activities.”  Before presuming the resource management related work performed by the appellant is of the same breadth and depth described by the GS-0025 PCS, we first considered the original intent behind, as well as the illustrations provided by, the PCS in comparison to the duties of the appealed position.  The GS-0025 PCS was originally designed for agencies such as the NPS.  While National Parks are charged with preservation of the land (i.e., with a mission of preserving natural and cultural resources of the park by barely altering its existing state), National Forests are under a significantly different multiple-use mandate with forests specifically managed for many purposes including timber, recreation, grazing, wildlife, fish, etc.  After careful consideration, we conclude the occupational information and illustrations provided by the GS-0025 PCS describe positions responsible for the management of resources for the chief purpose of land preservation.

In contrast, the natural resource management work performed by the appellant involves the intense consideration of the conflict between and among the many District resources, its uses, and the resulting conflict from interest groups.  She establishes and implements the development, production, and utilization of the District’s natural resources, making decisions related to grazing, timber, mineral extraction, water use for municipalities, roads and trails, wildlife, etc.  She is responsible for District projects including the environmental analysis, decision-making, and implementation stages, e.g., the Tie Flume Vegetation Management project encompassing approximately 47,500 acres.  The project entails 2,000-3,500 acres of commercial harvest, 1,700 acres of pre-commercial thinning, prescribed burns, aspen and riparian meadow restoration, fish habitat improvement, and changes to roads and trails.  Her work requires regular contact (to communicate, coordinate, or conflict resolution) with the general public; representatives of city, county, State, and Federal Government officials; wildlife, land trust, and nonprofit organizations; permittees, mining operators, loggers, and contractors; various civic groups; and Forest and operating unit staff.  Unlike GS-0025 positions, when making resource management related decisions, the appellant’s considerations extend beyond the objective of land preservation to include complicating factors as a result of the FS’s multi-use mandate.  For example, she must weigh considerations such as community dependency on resources; pressure from industries, recreationists, and other organizations; conflict in potential use; and high resource values and scarcities requiring development of resources and its increased use.  We note this kind of work typically falls under the Natural Resources Management and Biological Sciences Group, 0400, which the Handbook describes as “professional and scientific or subordinate technical work in any of the fields of science concerned with living organisms, their distribution, characteristics, life processes, and adaptations and relations to the environment; the soil, its properties and distribution, and the living organisms growing in or on the soil; and the management, conservation, or utilization thereof for particular purposes or uses.”  Therefore, the GS-0025 series is not appropriate.

After careful consideration, the appellant’s position is properly classified to the GS-0301 series, which includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no other series is appropriate.  The work requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives.  The purpose of the GS-0301 series is to cover two-grade interval specialized work for which no appropriate occupational series has been established and which is not elsewhere classifiable.  The essential criteria for classifying positions in this series are:  (1) the primary work of the position is of an administrative, two-grade interval nature; and (2) the primary work of the position is not classifiable in any other series.  The appellant directly supervises all professional employees assigned to her District, providing both administrative and technical supervision to the four professional positions.[1]  As previously discussed, her position does not require applying knowledge in the natural resources or other fields to the same degree or extent as the District’s professional employees, although we note she must apply similar knowledge sufficient to serve as the decision-maker on all of the District’s significant resources-related issues and as the reviewer of work accomplished by her professional staff.  The professional employees perform day-to-day work at their own discretion.  However, they must consult with the appellant when needed on various technical matters, and alert her of any professional concerns since it is the District Ranger’s responsibility to serve as decision-maker on resources-related issues and to liaison, consult, negotiate, and otherwise serve as the District’s representative on matters involving the general public and others.  We also note the number of professional employees assigned to her District is limited (i.e., representing only 4 of the 34 permanent/seasonal employees).  In addition, all work accomplished by the professional staff is classified no higher than the GS-11 grade level.  Given the limited extent and breadth of professional work performed within/for the District, in addition to our findings regarding the nature of the interaction between the appellant and professional staff, we conclude her supervisory responsibilities for both professional and non-professional staff require application of analytical ability, judgment, discretion, and knowledge of program principles, concepts, policies, and objectives characteristic of the GS-0301 series.  Moreover, because the duties and knowledge required of her position do not compare to a specific occupational series, it is appropriately classified in the GS-0301 series.

There are no grading criteria for positions classified in the GS-0301 series.  The Position Classification Flysheet for the GS-0301 series instructs applying criteria in a standard for a specific occupational series that involves analogous knowledge and skills.  The standard selected for cross-series comparison should cover work as similar as possible to the kind of work performed, the qualifications required to do the work, the level of difficulty and responsibility, and the classification factors that have the greatest influence on the grade level.  Positions that also meet the coverage criteria of the GSSG are to be evaluated by that guide.

The agency evaluated the appellant’s nonsupervisory work by application of the grading criteria in the Administrative Analysis Grade Evaluation Guide, which provides criteria for nonsupervisory staff administrative analytical, planning, and evaluative work at grades GS-09 and above.  Considering her line organization and the nature of work performed, we find the appellant’s nonsupervisory duties and responsibilities are best evaluated by cross-reference to the grading criteria in the GS-0025 PCS.  Duties of GS-0025 positions characteristically include assignments such as forest and structural fire control; protection of property from natural or visitor related depredation; dissemination to visitors of general, historical, or scientific information; control of traffic and visitor use of facilities; enforcement of laws and regulations; investigation of violations, complaints, trespass, and accidents; search and rescue missions; and management activities related to resources such as wildlife, forests, historic buildings, archaeological properties, and recreation areas.

The GSSG is used to grade supervisory work and related managerial responsibilities that are accomplished through the combined technical and administrative direction of others; constitute a major duty that occupies at least 25 percent of the position’s time; and meet at least the lowest level of Factor 3 of the GSSG.  The appellant’s position meets the requirements for coverage and evaluation by the GSSG.  Since there are no titles specified for the GS-0301 series, the agency may construct a title, which must include a supervisory designation consistent with guidance in the Introduction.

Grade determination

Evaluation of supervisory duties using the GSSG

The GSSG is a cross-series guide used to determine the grade level of supervisory work in the GS.  The GSSG has six evaluation factors, each with several factor-level definitions and corresponding point values.  Positions are evaluated by crediting the points designated for the highest level met under each factor and converting the total to a grade by using the point-to-grade conversion chart in the guide.

The appellant’s agency credited her supervisory work as follows:  Levels 1-2 for Factor 1 (Program Scope and Effect); 2-2 for Factor 2 (Organizational Setting); 3-2c for Factor 3 (Supervisory and Managerial Authority Exercised); 4A-2/4B-2 for Factor 4 (Personal Contacts); 5-6 for Factor 5 (Difficulty of Typical Work Directed); and 6-4 for Factor 6 (Other Conditions).  In her appeal to OPM, the appellant only disagrees with the agency’s evaluation of Factor 3-2c, believing her position meets Level 3-3b.  After careful review, we concur with the agency’s evaluation of Factors 1, 2, and 4A/4B, and have credited the position accordingly.  Therefore, we have confined our analysis to Factors 3, 5, and 6.

Factor 3, Supervisory and Managerial Authority Exercised

This factor considers the delegated supervisory and managerial authorities exercised on a recurring basis.  To be credited with a level under this factor, a position must meet the authorities and responsibilities to the extent described for the specific level.

In order to meet Level 3-2, a position must meet any one of the conditions described in paragraphs a, b, or c under this factor level.  The agency credited the appellant’s position at Level 3-2c.  Supervisors at this level must carry out at least three of the first four, and a total of six or more of the 10 responsibilities listed at that level in the GSSG.  Based on our review of the record, we agree the appealed position fully meets Level 3-2c.  As this is contested by neither the appellant nor agency, we will not address the responsibilities further but incorporate them by reference into this decision.

In order to fully meet Level 3-3, a position must meet the conditions described in paragraphs a or b, under this factor level.  Level 3-3a describes managerial positions with authority to devise long-range staffing needs and are closely involved with high-level program officials (or comparable agency-level staff personnel) in developing overall goals and objectives for assigned staff functions, programs, or program segments.  This is not characteristic of the appellant’s position.

The appellant asserts her position should be credited at Level 3-3b.  At this level, a supervisor must exercise all or nearly all of the supervisory responsibilities and authorities described at Level 3-2c, plus at least 8 of the 15 responsibilities listed under Level 3-3b of the GSSG.  The appellant’s position exercises all of the responsibilities described at Level 3-2c.  Of the 15 responsibilities listed under Level 3-3b, the agency credited her position with seven of the responsibilities (i.e., responsibilities 1, 2, 3, 5, 6, 8, and 14).  Our evaluation of her duties and responsibilities follows.

Responsibilities 1, 3, 5, 6, and 8 refer to situations where work is accomplished through subordinate supervisors, team leaders, or other similar personnel.  Further, the supervisor’s organizational workload must be so large and work so complex that it requires using two or more subordinate supervisors, team leaders, or comparable personnel to direct the work.  The District’s organizational chart shows the appellant serves as the first or second-level supervisor for five positions classified by the agency as supervisors based on their meeting the requirements for coverage and evaluation by the GSSG and two positions classified as leaders based on their meeting the requirements for coverage and evaluation by the General Schedule Leader Grade Evaluation Guide.  Given the District’s organization is sufficiently large and distinct as to require using subordinate supervisors and leaders to direct the work, the appellant’s position is credited with responsibilities 1, 3, 5, 6, and 8.

Responsibility 2 is credited because the appellant exercises significant responsibilities when dealing with the Forest Supervisor, Regional Forester, other district rangers, and staff of other program offices to develop Forest policies and programs as discussed in her PD of record.

Responsibility 4 is not credited because the appellant does not direct a program with multimillion dollar resources directly under her discretion and control.  In her request to OPM, the appellant states that the Forest’s budget “is over 8 million dollars annually and is not assigned to one person to determine how those funds are expended but is determined by the Forest Leadership Team, of which I am a member of under direction of the Forest Supervisor.”  The appellant further explains the Leadership Team participates in a two-day meeting annually to review all Forest projects with the intent of identifying priorities and determining the resources or funds to be allocated to different resource areas, projects, and other non-fixed and fixed items.  She states that it is ultimately at the Forest Supervisor’s discretion to make budget decisions.  While her participation on the Leadership Team affects the allocation of Forest resources, responsibility 4 is intended to credit supervisors that exercise direct control over a multimillion-dollar level of annual resources.  We found no evidence the appellant exercises such direct control, e.g., she cannot reprogram funds at her discretion as any such changes would require approval from higher-level officials.

Responsibility 7 is credited to positions who make or approve selections for subordinate nonsupervisory positions.  The agency did not credit the appellant’s position with this responsibility, stating that “only the Forest Supervisors have the final authority to make or approve selections for subordinate nonsupervisory positions.”  To place this responsibility in the proper context, we considered the related descriptions at Levels 3-2c and 3-4b.  We conclude responsibility 7 at Level 3-3b must fall between the description at Level 3-2c of supervisors interviewing candidates for positions and recommending appointment, promotion, or reassignment to positions, and the description at Level 3-4b of supervisors exercising final authority for the full range of personnel actions.  We also note the use of “or” in the description of responsibility 7 at Level 3-3b.  Supervisors may thus be credited with responsibility 7 for either making the selection or approving the selection.  When the District has a vacancy for a supervisory or nonsupervisory position, the appellant determines whether the agency should recruit internally or externally for candidates.  She identifies the panel members, which typically includes the subordinate supervisor of the position and two other staff members.  The panel reviews the candidate certificate, conducts the initial screening, and makes reference checks.  The appellant participates during interviews with candidates.  Along with panel members, she discusses and identifies the top candidate for the position.  If the group is tied, the appellant makes the selection.  She then completes the agency’s required documents for hiring, which include providing a description of the recruitment process, number of interviews conducted, reason for selection, etc.  Required documents are sent to the Forest Supervisor, who then forwards the action to the human resources office for processing.  The appellant’s selections are always accepted.  We conclude the Forest Supervisor’s limited involvement in the District’s hiring process is procedural rather than substantive, and the appellant’s active, direct role throughout this process demonstrates that she is responsible for making selections for the District’s subordinate positions.  Furthermore, the appellant makes and approves selections for seasonal employees.  Once she identifies selectees for seasonal positions, she forwards the required documents to the human resources office for processing.  Because the appellant is responsible for making selections involving subordinate positions (and approving selections for seasonal positions), responsibility 7 is credited.

Responsibility 9 is not credited because the appellant does not hear and resolve formal group grievances or serious complaints from employees.  She can effect minor disciplinary measures (e.g., warnings, reprimands, or counseling letters); however, such responsibility would not exceed the description at Level 3-2c, which is credited to supervisors who effect minor disciplinary measures and recommend other actions in more serious cases.  She resolves or attempts to resolve employee complaints, but she is expected to involve the Forest Supervisor and/or the agency’s employee relations staff on more serious grievances and complaints.  Although she can propose recommendations to her supervisor, the appellant has less authority to resolve formal group grievances and serious employee complaints than intended under responsibility 9.

Unlike responsibility 10, the appellant does not have authority to review and approve serious disciplinary actions (e.g., suspensions) involving nonsupervisory subordinates.  In her appeal to OPM, she asserts that “just because the authority rests with the Forest Supervisor does not mean that [she does] not review and approve serious disciplinary actions.”  However, this responsibility is specifically credited to supervisors delegated with authority to both review and approve serious disciplinary actions.  Although she works closely with her subordinate employees on performance- or disciplinary-related issues, the appellant consults with the agency’s employee relations staff and the Forest Supervisor to ensure proposed actions, especially those relating to removal or other serious actions, align with agency practice.  Because the Forest Supervisor serves as the approving official on serious disciplinary matters, he is held responsible and accountable for the action should the employee challenge the agency.  Responsibility 10 is not credited.

Responsibility 11 is not credited.  The appellant does not make decisions on nonroutine, costly, or controversial training needs and training requests related to employees of the unit.  She supports crediting this responsibility, stating she makes decisions on all training requests for subordinate employees.  Responsibility 11 is not necessarily credited to supervisors who act on all training requests from subordinate staff.  Instead, this is credited to supervisors who, by virtue of the size or mission work of the organization, must on a regular basis respond to training requests that may be characterized as nonroutine, costly, or controversial.  Given the District’s organization of 20 permanent employees and functions performed, the appellant would be precluded from acting on training requests characteristic of responsibility 11 on a regular basis.  We find her training responsibilities do not exceed the description at Level 3-2c of supervisors identifying training needs and providing or arranging for needed training.

Responsibility 12 is not credited because the appellant does not oversee the work of contractor personnel.

The agency did not credit the appellant’s position with Responsibility 13, which describes responsibility for approving expenses comparable to within-grade increases, extensive overtime, and employee travel.  The agency explains its reason for denying credit, stating the responsibility is identified on the Forest Supervisor’s PD but not the appellant’s.  Based on our interviews with the Forest Supervisor and appellant, we found she approves such expenses at her discretion.  For example, she approves staff requests to travel for training or for work on fire and other emergency assignments.  She approves within-grade increases, acknowledging the employee is (or is not) performing at an acceptable level once she receives notification of an individual’s eligibility in the agency’s e-performance management system.  In addition, she regularly approves extensive overtime.  When she receives an overtime request, she follows up with the subordinate supervisor if she has questions or issues with the request prior to her signing the overtime authorization form.  The appellant states that, for the last 12 pay periods, she has approved 10 hours of overtime for approximately 10 employees to work at recreation sites on weekends, patrol for fire activity, etc.  She estimates approving approximately 1,000 overtime hours this season.  Responsibility 13 is credited.

Responsibility 14 is met.  The appellant recommends awards and bonuses for nonsupervisory personnel and changes in position classification, subject to approval by higher-level officials or others.  She coordinates with the human resources office when she identifies PDs assigned to subordinate employees that do not align with the actual duties performed.  The Forest Supervisor states that, to ensure duties assigned to her subordinate staff are consistent with the classification of the position, the appellant at her discretion can make changes to existing PDs or request assignment to a new PD.  Given this environment, a recommendation to the Forest Supervisor by the appellant to make changes to the PD or classification of subordinate positions would have a reasonable chance for adoption.

Responsibility 15 applies to supervisory and managerial positions that oversee organizations with workloads that are so large and complex as to require attention to team building, reducing barriers to production, or improving business practices.  This would apply to large organizations whose missions would be susceptible to the application of such methodological or structural improvements.  The appellant does not oversee a workload of that magnitude and complexity, nor does the work supervised lend itself to these types of management applications.  Her efforts to improve office operations meet the demands of finding ways to improve production or increase the quality of work directed described at Level 3-2c.  Therefore, this responsibility is not credited.

The appellant’s position exercises all ten of the delegated supervisory authorities and responsibilities described at Level 3-2c of this factor, and nine of the fifteen listed responsibilities under Level 3-3b.  Therefore, Level 3-3b is credited for 775 points.

Factor 5, Difficulty of Typical Work Directed

This factor measures the difficulty and complexity of the basic work most typical of the organization directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility.

In evaluating second (and higher) level supervisors like the appellant under this factor, the GSSG instructs to first use the basic method described for first-level supervisors.  This involves determining the highest grade of basic (mission-oriented) nonsupervisory work performed that constitutes 25 percent or more of the workload of the organization.

The following types of work are specifically excluded from this workload calculation:

• Subordinate work that is graded on the basis of supervisory or leader duties;
• Work for which the supervisor does not have the minimum supervisory and managerial authorities defined under Factor 3 (including such basic administrative supervisory functions as approving leave and evaluating performance);
• Lower-level support work that primarily facilitates the basic work of the unit; and
• Work that is graded based on an extraordinary degree of independence from supervision.

The agency credited the appellant’s position at Level 5-6, identifying GS-11 as the base level work of the District.  Although the appellant does not disagree, we will nonetheless discuss this factor as our evaluation determined a different base level.

The appellant supervises directly, or as the second- or third-level supervisor, the District’s 20 permanent full time equivalent (FTE) positions and 14 seasonal employees.  We excluded one position as lower-level support work, i.e., the GS-3/4 Customer Service Representative position allocated to the Miscellaneous Clerk and Assistant Series, GS-0303, as the PD confirms the position performs work solely to facilitate the basic work of the unit.  We also excluded the supervisor or leader work based on information reported in PDs provided by the agency.

Because they typically work full time from May to October every year (on 1039 appointments), seasonal employees will be credited at ½ work year.  The four professional positions are also included in our workload calculation.  Although the appellant’s position does not require similar education prerequisites, she provides both administrative and technical supervision to the four professionals as discussed on page 6 of this decision.  As previously noted, this issue has been addressed in OPM’s Digest of Significant Classification Decisions and Opinions, Number 15.  The lack of full technical qualifications in a given occupation does not preclude exercising technical direction over work in that occupation.  In this case, the PDs for the professional positions describe a degree of technical supervision typical for work at their levels, i.e., where the supervisor establishes goals and resources available; confers with the employee on the work to be done, the deadlines, and any concerns or controversies that arise; and reviews the work for results.  This level of supervision does not require full technical skills in the occupation to actually perform the work but rather an understanding of how the work is done, what is required to do it, what end products are expected, and the implications or consequences of particular actions.  Therefore, we included the four professional positions in the base level determination.

We note the organizational chart includes a prospective position for an Assistant Fire Management Officer, GS-0301-09, which the appellant states the District will eventually fill.  Although prospective positions are not considered for purposes of workload calculations, we note the GS-09 level would be fully representative of the highest level of nonsupervisory work performed by the District even if we considered the organization with the prospective GS-09 position.  For supervisory and leader positions we only credited the percentage of time spent performing nonsupervisory/non-leader duties.  The base level of work for the District follows.

             GS-11

1.0       Archeologist, GS-0193 (PD number FS5118)

1.0       Wildlife Biologist, GS-0486 (PD number FS3079)

.75       Supervisory Natural Resources Specialist (Recreation), GS-0401 (PD number FS2260)

.75       Supervisory Rangeland Management Specialist, GS-0454 (PD number FS4079)

.70       Supervisory Forestry Technician, GS-0462 (PD number FS1526)

4.2

             GS-9

2.0       Recreation Management Specialist, GS-0301 (PD number FS5180)

             GS-8

1.5       Supervisory Forestry Technician, GS-0462 (PD number FS1471)

             GS-7

1.0       Support Services Specialist, GS-0342 (PD number FS3199)

1.0       Forestry Technician (Recreation), GS-0462 (PD number FS2329)

1.0       Range Technician, GS-0455 (PD number FS2311)

2.0       Forestry Technician, GS-0462 (PD number FS1472)

5.0

            GS-6

.50       Forestry Technician, GS-0462 (Seasonal)

             GS-5

1.0       Administrative Support Assistant, GS-0303 (PD number FS5778)

.50       Archaeology Technician, GS-0102 (Seasonal)

.50       Range Technician, GS-0455 (Seasonal)

.50       Biological Science Technician (Wildlife), GS-0404 (Seasonal)

1.0       Forestry Technician, GS-0462 (Seasonal)

1.5       Forestry Technician (Recreation), GS-0462 (Seasonal)

2.0       Forestry Technician, GS-0462 (PD number FS1477)

1.5       Lead Forestry Technician, GS-0462 (PD number FS1478)

8.5

             GS-4

.50       Biological Science Technician (Wildlife), GS-0404 (Seasonal)

1.0       Forestry Technician, GS-0462 (Seasonal)

.50       Forestry Technician (Recreation), GS-0462 (Seasonal)

.50       Forestry Technician (Trails), GS-0462 (Seasonal)

2.5

Total nonsupervisory mission-oriented workload is 24.2 work years.  The percentage of nonsupervisory mission-oriented workload at each grade level is as follows:

GS-11:             17.4%

GS-9:               8.3%

GS-8:               6.2%

GS-7:               20.7%

GS-6:               2.1%

GS-5:               35.1%

GS-4:               10.3%

At 17.4%, the GS-11 grade level work constitutes less than 25 percent of the nonsupervisory workload.  At 8.3%, the GS-09 grade level work also constitutes less than 25 percent of the nonsupervisory workload.  However, when combined with the 17.4% expended on the GS-11 workload, we find the GS-09 work fully representative (25.7%) of the highest level of nonsupervisory work performed by the District.

Level 5-5 is credited for 650 points.

Factor 6, Other Conditions

This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities.  If the level selected under this factor is 6-1, 6-2, or 6-3, and if three or more of the eight Special Situations described are met, the original level selected is increased by one level.  If the level selected is 6-4, 6-5, or 6-6, the Special Situations do not apply and the original level selected is credited.

The agency credited the appellant’s position at Level 6-4, but we find her position meets Level 6-3a instead.  At Level 6-3a, supervision and oversight requires coordination, integration, or consolidation of administrative, technical, or complex technician or other support work comparable to GS-09 or 10.  The work directed requires the coordination and integration of work efforts, ensuring consistency of product, service, interpretation, or advice; conformance with the output of other units, with formal standards or agency policy.  Like Level 6-3a, the appellant’s supervisory work requires coordination, integration, and consolidation of work equivalent to the GS-09 grade level.

The appellant’s position does not meet Level 6-4a, where supervision requires substantial coordination and integration of a number of major work assignments, projects, or program segments of professional, scientific, technical, or administrative work comparable in difficulty to the GS-11 level.  As discussed under Factor 5, we find the base level of work for the District is GS-09, not GS-11 as expected at Level 6-4a.

Unlike Level 6-4b, the appellant’s position does not direct subordinate supervisors and/or contractors who each direct substantial workloads comparable to the GS-09 or 10 level.  Because she does not direct subordinate supervisors who are each responsible for substantial workloads comparable to the GS-9 or 10 level, her position cannot be credited with Level 6-4b.

Since Level 6-3a was selected, the Special Situations (i.e., Variety of Work, Shift Operations, Fluctuating Workforce or Constantly Changing Deadlines, Physical Dispersion, Special Staffing Situations, Impact of Specialized Programs, Changing Technology, and Special Hazard and Safety Considerations) were considered.  We credited the Variety of Work situation to the appellant’s position.  This situation is credited when more than one kind of work, each kind representing a requirement for a distinctly different additional body of knowledge on the part of the supervisor, is present in the work of the unit.  Because the appellant supervises positions in multiple professional, administrative, and technical occupations requiring distinctly different bodies of knowledge, this situation is credited to her position.  We also considered the Physical Dispersion situation, which is credited when a substantial portion of the workload for which the supervisor is responsible is regularly carried out at one or more locations that are physically removed from the main unit, under conditions that make day-to-day supervision difficult to administer.  Due to the nature of the work, some staff are dispersed throughout the District’s half-a-million acres.  However, the appellant states she can communicate with her employees by phone, email, or face-to-face when necessary.  Since there is no evidence the physical separation of staff makes it difficult to provide day-to-day supervision (e.g., in making assignments, coordinating tasks, evaluating work, or performing other day-to-day responsibilities), the Physical Dispersion situation is not creditable to the appellant’s position.  Further, we found no indication that other special situations apply.  Because the appellant’s position does not meet three of the eight special situations identified, no additional level is warranted.

Level 6-3a is credited for 975 points.

Summary
Factors	Level	Points
1.  Program Scope and Effect	1-2	350
2.  Organizational Setting	2-2	250
3.  Supervisory & Managerial Authority Exercised	3-3b	775
4.  Personal Contacts
A.  Nature of Contacts	4A-2	50
B.  Purpose of Contacts	4B-2	75
5.  Difficulty of Typical Work Directed	5-5	650
6.  Other Conditions	6-3	975
Total		3125

A total of 3,125 points falls within the GS-12 range (2755-3150) on the grade conversion table provided in the GSSG.

Evaluation of nonsupervisory duties using the PCS for Park Ranger Series, GS-0025

The grade-level criteria in the GS-0025 PCS are presented in terms of two main classification factors:  Nature of assignment and Level of responsibility.

GS-12 park rangers direct complex programs in resource management, interpretation, and/or visitor services and perform advisory, coordination, and review services for park activities.  The following situations are typical:  (1) an intense public interest in the development of additional recreational resource facilities that exists when the current level of use is already threatening one or more of the park’s resources; (2) a strained relationship with the local community that develops because of efforts to acquire additional land to protect the existing resource; (3) the need to restrict entry to an area of significant public interest due to factors such as the fragile nature of the resources involved, severely limited funds, overcrowding, vandalism, motor vehicle noise and pollution, land development encroachments, or other related programs; or (4) the need to determine the extent to which it is appropriate to develop a particular resource.  The appellant regularly performs work in such or similar situations.  For example, she manages the District’s natural resources, which may cause conflict or tension regarding the multiple uses including grazing, timber, recreation, mineral extraction, and water usage.  She makes decisions to institute road closures, install gates, and other mitigations to protect wildlife or other natural resources.  Because such protections are typically met with resistance, the appellant is responsible for dealing with the public, recreational groups, and others adversely impacted by the decision.  When restricting areas to the public (e.g., if a foreign bacteria is discovered in the District), she coordinates with the Forest’s hydrologist to treat the water while ensuring proper notice and signage for the safety of the public.  Conflict also arises when conditions at the District are unfavorable for grazing and, as a result, cattle must be removed from pastures.  The appellant deals with the expected resistance from affected permittees of the grazing program.  In addition, she must weigh her obligations to support the timber market, organization, and industry while sustaining the District’s other natural resources.

Like the appellant’s position, GS-12 assignments have complex technical, administrative, or public relations implications and typically require analyses and decisions in areas where precedents differ or there are no pertinent or apparent precedents.  GS-12 rangers are free from technical control and are expected to independently select techniques, establish methods and procedures for studying and resolving particular problems, handle conflict situations, and otherwise carry assignments through to completion.  GS-12 rangers also serve as spokesperson for their function, park, or office in contacts with community leaders, State officials, and leaders of interest groups in order to obtain objectives of agency policy and concurrently maintain or establish good public relations.  The description of park rangers at the GS-12 level is a match to the appellant’s personally performed work.  Moreover, her position is comparable to the illustration at the GS-12 level, which describes park rangers responsible for all resource management and visitor protection and services activities within a park.

In contrast, GS-13 park rangers develop programs of broad scope with widespread impact and a high degree of complexity.  GS-13 rangers:  (1) assert technical leadership and provide staff coordination, review, and consultation on basic issues in assigned functions; (2) determine the need for, initiate, and/or recommend policies, program procedures, and standards to be used as guides by park managers, rangers, contractors, concessionaries, lessees, and others in a variety of situations; (3) review operating programs for quality and effectiveness; and (4) develop a variety of original plans, concepts, systems, and programs that involve significant departures from current practices, are highly controversial, and embody numerous complex variables.  Park rangers at this level typically perform work at organizational levels above the park level.  GS-13 rangers also represent and speak for the agency in the program area to which assigned and have authority to make joint decisions with cooperating and intra-agency committees.  After careful consideration, we conclude the appellant’s work, her organizational level, and authority delegated to her position fall short of the description at the GS-13 level.  Also unlike her position, the illustration at the GS-13 level describes park rangers that serve as expert advisors and technical leaders in the national office in several diverse program areas, or that serve as functional leaders or program chiefs in an office in charge of a major phase of the agency’s park program (by providing advice, guidance, and coordination to the staff of various parks for the planning, development, and operations of interpretation facilities such as visitor centers, museums, and wayside exhibits).

The nature of the appellant’s assignments and level of responsibilities do not meet the GS-13 level.  Therefore, the GS-12 level is assigned.  Because such work is neither grade-enhancing nor does she assert that her nonsupervisory work exceeds the GS-12 grade level, we will not evaluate it further.

Decision

The appellant’s position is properly classified in the Miscellaneous Administration and Program Series, GS-0301, at the GS-12 grade level.  Selection of an appropriate title is at the agency’s discretion but with the “Supervisory” prefix added to the selected title.

 

 

[1] We note that a similar situation (although dealing with establishing the base level of work supervised) is addressed in OPM’s Digest of Significant Classification Decisions and Opinions, Number 15, September 1991.

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