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


02/15/2024

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Date

Finality of Decision

As provided in section 511.612 of title 5, Code of Federal Regulations, 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).

As indicated in this decision our findings show the appellant’s 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 correct the PD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected PD within 30 days of the date of this decision to the Office of Personnel Management, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as Supervisory Air Traffic Control Specialist (Terminal), GS-2152-13, but he believes it should be graded at the GS-14 grade level. The position is assigned to the Air Traffic Control (ATC) Division, Directorate of Aviation Operations, U.S. Army Garrison, Army Installation Management Command (IMCOM), U.S. Department of the Army (Army), U.S. Department of Defense (DoD), at Fort Cavazos (formerly Fort Hood), Texas. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

Prior to the appellant occupying the appealed position, the record shows his official position description (PD), number EF 87048, was classified at the GS-14 grade level. However, the U.S. Office of Personnel Management (OPM) previously adjudicated a classification appeal for a similar Supervisory Air Traffic Control Specialist (Terminal) position and that September 25, 2002, decision (OPM Decision Number C-2152-13-01) determined the work was properly classified at the GS-13 grade level. As a result of the consistency review subsequently conducted by the employing agency, the appellant’s position was downgraded from the GS-14 to GS-13 grade level.

The appellant requested a desk audit of his position from Army, Civilian Human Resources Agency. Their October 2, 2020, desk audit findings supported his request for classification of his position to the GS-14 grade level. However, no further action was taken by the agency to implement the evaluation and officially change the classification of his position. The appellant filed a classification appeal with DoD, Defense Civilian Personnel Advisory Service (DCPAS), who conducted a classification review of his position based on application of the General Schedule Supervisory Guide (GSSG). Their February 8, 2022, decision sustained his current GS-13 grade level but lowered the level assigned to the position for Factor 6, Other Conditions, from Level 6-5c to 6-4a. The appellant later filed a classification appeal with OPM, citing concerns regarding DCPAS’s review and evaluation process of his position, e.g., its similarities to findings from OPM Decision Number C-2152-13-01.

In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position. By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Because our decision sets aside any previous agency decisions, any concerns regarding the agency’s classification review process are not germane to this decision.

Position information

Both the appellant and his supervisor certify to the accuracy of the appellant’s official PD number EF87048. However, we find the appellant’s PD is inaccurate because it describes “nonsupervisory” duties and responsibilities with their assigned respective percentages which we find are fully performed within the context of his overall supervisory and related program management responsibilities as the ATC Division Chief. For instance, he coordinates with heads of other civil or military ATC facilities on changes affecting work at his facility. He provides technical Data System Specialist supervisory controls for the operation of STARS computer programming, and ensures proper training is provided to his subordinate supervisors and employees on the ARTS II system. He also coordinates with Federal Aviation Administration (FAA) Maintenance Chiefs for scheduling flight checks and inspections of navigational aids and ATC equipment at his facility; ensures the maintenance of his facility records, adequate supplies, proper equipment operation, and adequate employee working conditions; and makes major recommendations and provides technical advice on a variety of matters affecting his ATC facilities including identifying the need for additional services for users within the terminal area, making organizational improvements within his Division necessary for the accomplishment of collateral duties of his subordinates and delegating authority as necessary for their accomplishment. Finally, as part of his supervisory responsibilities he regularly reviews the cost of facility operations to achieve cost reductions and adjusts the ATC Division’s budget to provide adequate equipment and supplies.

Given the PD inaccuracies described above, the appellant’s PD does not meet the standard of adequacy described on pages 11-12 of the Introduction. The agency must revise the PD amending the narrative to indicate that all the appellant’s duties noted in the preceding paragraph are performed within the context of his supervisory responsibilities and removing percentages currently identified as “nonsupervisory” work.

As ATC Division Chief, the appellant and his staff ensure the safe, orderly, and expeditious movement of air traffic, which includes military and civilian aircraft and unmanned aerial vehicles, within the assigned airspace. The ATC complex is situated at the Robert Gray Army Airfield (RGAAF) and Hood Army Heliport (HAHP). Operating sections include RGAAF Tower, HAHP Tower, Hood Flight Following, Radar Approach Control, and ATC/Navigational Aids (NAVAIDS) Maintenance. In addition, the ATC Division trains Army military air traffic controllers assigned to tactical units to ensure military controller qualification and proficiency prior to deployment to a combat theater of operations.

ATC services at the RGAAF are provided 24/7, 365 days a year. The airfield spans 3,800 acres including five restricted areas, three military operations areas, one ATC Assigned Airspace, Presidential Prohibited Area, and approximately four military/auxiliary and eight civilian airfields. In addition to its runway (10,000 x 200 feet), the RGAAF also has two auxiliary landing strips, i.e., the 2,200 x 50 feet runway at Shorthorn Auxiliary Landing Strip and the 3,488 x 75 feet runway at Longhorn Auxiliary Landing Strip. Because the RGAAF is part of the FAA’s National Airspace System (NAS), the ATC Division provides air traffic services for civil, commercial, and military aviation. The staff provides ATC services to military and civilian aircraft under visual and instrument flight rules within the assigned airspace, which is comprised of a 60-mile radius of Fort Cavazos surface to 12,000 feet. Of the over 500,000 air movements performed annually by the staff, approximately 75 percent of the traffic count is from civilian aircraft and 25 percent from military aircraft. By agreement with the City of Killeen, the Killeen-Fort Hood Regional Airport operates alongside the RGAAF and serves as a small military/commercial joint-use airport, which currently operates 10 American Airlines flights daily. To provide continuous ATC services to civil, commercial, and military aircraft, the ATC Division runs three work shifts, i.e., from 8:00 a.m. to 4:00 p.m., 4:00 p.m. to 12:00 a.m., and 12:00 a.m. to 8:00 a.m. In addition to a Supervisory Air Traffic Control Specialist (Terminal), GS-2152-13, position, each shift typically includes nine or ten ATC Specialist (Terminal), GS-2152-12, positions. Given its responsibilities, the RGAAF has 10 operational positions consisting of radar, tower, flight following, and precision approach radar.

At the HAHP, the Division’s staff provides ATC services to support military aviation activities. Six helipads are located within the cantonment area. The HAHP occupies 1,500 acres with a runway spanning 3,100 x 144 feet. ATC Division staff includes a Supervisory Air Traffic Control Specialist (Terminal), GS-2152-12, position; two shift leaders (ATC Specialist (Terminal), GS-2152-11, positions; and four Air Traffic Control Specialist (Terminal), GS-2152-10, positions. The controllers are assigned to either the 8:00 a.m. to 4:00 p.m. or the 4:00 p.m. to 12:00 a.m. work shift. The HAHP has four operational positions consisting of local, ground control, flight data, and clearance data.

The maintenance section provides maintenance and safety of flight certification services, repairing and maintaining electronic ATC/NAVAIDS and communications equipment for RGAAF and HAHP facilities. The section is comprised of the Supervisory Electronics Technician, GS-0856-13, position and seven Electronics Technician, GS-0856-12, positions. Four nonsupervisory technicians are assigned to the 6:30 a.m. to 4:30 p.m. shift and three to the 2:00 p.m. to 12:00 a.m. shift. All are subject to call back. The appellant is responsible for coordinating with FAA and other agencies to schedule flight checks and inspections of NAVAIDS and other ATC equipment when required.

The record shows the appellant directly supervises four positions. Of those, the agency classified three as supervisors based on the positions meeting the coverage requirements for evaluation by the GSSG, and one nonsupervisory ATC Specialist (Staff), 2152-12. The three supervisory positions include a Supervisory Air Traffic Control Specialist (Terminal), GS-2152-12; a Supervisory Air Traffic Control Specialist (Terminal), GS-2152-13; and a Supervisory Electronics Technician, GS-0856-13. The appellant is also the second-level supervisor for three Supervisory Air Traffic Control Specialist (Terminal), GS-2152-13, positions. He serves as the second- or third-level supervisor for all other Division positions, i.e., a total of approximately 46 employees. As previously discussed, the appellant spends all his time on supervisory or related program management responsibilities. His position is directly supervised by the Director of Aviation Operations, a GS-340-14 Program Manager (Aviation Operations) position.

In reaching our classification decision we carefully reviewed all information provided by the appellant and his agency including his official PD which, although not completely accurate, we incorporate by reference into this decision. In addition, to gain more information about his position, we conducted a telephone audit with the appellant and a separate telephone interview with his first-level supervisor.

Series, title, and standard determination

The agency classified the appellant’s position in the Air Traffic Control Series, 2152, which includes positions concerned with the control of air traffic to ensure the safe, orderly, and expeditious movement along air routes and at airports when a knowledge of aircraft separation standards and control techniques, and the ability to apply them properly, often under conditions of great stress, are required. Also included are positions concerned with the development, coordination, and management of air traffic control programs. The appellant does not disagree, and we concur with the agency’s series determination.

Because the appellant’s position fully meets the coverage requirements specified in the GSSG for titling and evaluation as a supervisor, we applied the grading criteria therein to evaluate his supervisory work. The correct title and series for the appellant’s position is Supervisory Air Traffic Control Specialist (Terminal), GS-2152.

Grade determination

The GSSG is a cross-series guide used to determine the grade level of supervisory work in the General Schedule. 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.

DCPAS credited the appellant’s supervisory work as follows: Level 1-2 for Factor 1 (Program Scope and Effect); Level 2-1 for Factor 2 (Organizational Setting); Level 3-3b for Factor 3 (Supervisory and Managerial Authority Exercised); Levels 4A-2/4B-2 for Factor 4 (Personal Contacts); Level 5-7 for Factor 5 (Difficulty of Typical Work Directed); and Level 6-4a for Factor 6 (Other Conditions). In his appeal to OPM and in statements made during the telephone audit, the appellant expressed his disagreement with DCPAS’s evaluation of Factors 1, 4, and 6.[1] After careful review, we concur with DCPAS’s evaluation of the remaining factors and have credited the position accordingly. Therefore, we confine our analysis to Factors 1, 4, and 6.

Evaluation using the GSSG

Factor 1, Program Scope and Effect

This factor assesses the general complexity, breadth, and impact of the program areas and work directed, including its organizational and geographic coverage. It also assesses the impact of the work both within and outside the immediate organization. To assign a factor, the criteria dealing with both Scope and Effect, as defined below, must be met.

Scope

Scope addresses the general complexity and breadth of the program (or program segment) directed; the work directed, the products produced, or the services delivered. The geographic and organizational coverage of the program (or program segment) within the agency structure is included under Scope.

At Level 1-2, the program segment or work directed is administrative, technical, complex clerical, or comparable in nature. The functions, activities, or services provided have limited geographic coverage and support most of the activities comprising a typical agency field office, an area office, a small to medium military installation, or comparable activities within agency program segments.

At Level 1-3, the program segment directed performs technical, administrative, protective, investigative, or professional work. The program segment and work directed typically have coverage which encompasses a major metropolitan area, a State, or a small region of several States; or, when most of an area’s taxpayers or businesses are covered, coverage comparable to a small city. Providing complex administrative or technical or professional services directly affecting a large or complex multi-mission military installation also falls at this level.

The appellant’s position overall meets Level 1-2. While we recognize that the higher graded technical ATC work directed by the appellant is more characteristic of that performed at Level 1-3, the service provided is confined to a mix of military, civil, and commercial aircraft within the limited geographic coverage of its assigned airspace including Fort Cavazos and by agreement with the City of Killeen concerning ATC operations with the Killeen Regional Airport. That airport operates alongside the RGAAF and serves as a small military/commercial joint-use airport. Comparable to Level 1-2, the ATC support provided is typical of a specialized agency field office providing comprehensive services within the scope of its specific program to a limited population of clients, i.e., aviators.

The appellant’s position does not meet Level 1-3. Unlike this level, the ATC technical support services provided do not have coverage encompassing a major metropolitan area, a State, or small region of several States. Alternately, while we can consider the Killeen-Temple-Fort Cavazos Metropolitan area with a population of 507,892 people comparable to a small city, the ATC services provided by the appellant’s organization are not related to nor do they cover most of the area’s taxpayers or businesses.

Level 1-3 also indicates that positions providing complex administrative or technical or professional services directly affecting a large or complex multimission military installation also falls at this level. The GSSG defines two situations comprising a large or complex multimission installation as follows:

 A large military installation (including a military base with only one or a few major missions) or group of activities with a total serviced or supported employee-equivalent population exceeding 4000 personnel, and with a variety of serviced technical functions. These personnel are directly affected by, but not supervised by, the position under review. These can include Federal civilian and military employees, contractor personnel, and volunteers.

 A complex multimission installation or group of several organizations (directly supported by the position under evaluation) that includes four or more of the following: a garrison; a medical center or large hospital and medical laboratory complex; multimillion dollar (annual) construction, civil works, or environmental cleanup projects; a test and evaluation center or research laboratory of moderate size; an equipment or product development center; a service school; a major command higher than that in which the servicing position is located or a comparable tenant activity of moderate size; a supply or maintenance depot; or equivalent activities. These activities are individually smaller than the large installation described in the preceding paragraph.

Regarding the first situation, while Fort Cavazos is one of the largest Army military installations with thousands of military service members, civilian employees, and military dependents working or residing on post, they are not all directly affected by the appellant’s ATC function. Rather, his position only directly services and affects a far more limited population of civil and military aviators. In addition, the appellant’s ATC program does not service a variety of technical functions performed at the installation. It provides only air traffic control to military, commercial, and civil air operations.

Concerning the second situation, in an email to OPM the installation states that Fort Cavazos is a complex, multimission installation having four of the required organizations listed in the GSSG. These include a Garrison, the Darnall Medical Center, a service school identified as the Non-Commissioned Officer Academy (NCOA), and a major command (Third Corps/FORSCOM). However, while the installation contains a Garrison and Medical Center, the NCOA at Fort Cavazos does not constitute a principal Army service school (e.g., U.S. Army Military Academy, Army military branch school, Command and General Staff College). In addition, the Army’s website addressing Army schools indicates there are thirty-two NCOAs located at thirty-two separate Army installations across the United States that provide leadership and developmental training to new NCOs. While we understand the importance of this career development training, given the number and dispersion of the NCOAs we do not consider them major Army schools. The installation identifies Third Corps at Fort Cavazos as a major command. However, the Army’s website shows that Third Corps is not a major command but rather reports to a major command, i.e., the U.S. Army Forces Command (FORSCOM) located at Fort Liberty, North Carolina. In addition, we find that the ATC services provided by the appellant are confined to aviation operations and do not directly support or affect the varied and multiple other mission focused activities performed at Fort Cavazos.

Based on the preceding analysis, the Scope of the appellant’s position is evaluated at Level 1-2.

Effect

This element addresses the impact of the work, the products, and/or programs described under “Scope” on the mission and programs of the customer(s), the activity, other activities in or out of Government, the agency, other agencies, the general public, or others.

At Level 1-2, the services or products support and significantly affect installation level, area office level, or field office operations and objectives, or comparable program segments; or provide services to a moderate, local or limited population of clients or users comparable to a major portion of a small city or rural county.

At Level 1-3, activities, functions, or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests (e.g., a segment of a regulated industry), or the general public. At the field activity level (involving large, complex, multi-mission organizations and/or very large serviced populations), the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.

The appellant’s position meets Level 1-2. Like this level, the ATC services directed by the appellant significantly affect the installation’s ability to guide, expedite, and ensure the safety of the air operations and activities falling within the installation’s airspace. As previously discussed, those services are provided to a limited population of aviators performing military, commercial, and civil air activities.

The position does not meet Level 1-3. Unlike this level, the appellant’s ATC services do not directly and significantly impact a wide range of the Department of the Army’s activities (including its overall ATC program), the work of other agencies, or the actual operations of outside interests such as segments of an entire regulated industry. As previously addressed, the appellant’s position does not involve a large, complex, multimission organization, nor substantially impacts the provision of essential support operations to a broad variety of numerous technical, professional, and administrative functions performed at Fort Cavazos.

Since both Scope and Effect meet Level 1-2, 350 points are assigned for Factor 1.

Factor 4, Personal Contacts

This is a two-part factor which assesses the nature and the purpose of personal contacts related to supervisory and managerial responsibilities. The nature of the contacts credited under Subfactor 4A and the purpose of those contacts credited under Subfactor 4B must be based on the same contacts. The agency credited Levels 4A-2 and 4B-2 under this factor.

Subfactor 4A-Nature of Contacts

This subfactor covers the organizational relationships, authority or influence level, setting, and difficulty of preparation associated with making personal contacts involved in supervisory and managerial work. To be credited, the level of contacts must contribute to the successful performance of the work, be a recurring requirement, have a demonstrable impact on the difficulty and responsibility of the position, and require direct contact.

At Level 4A-2, frequent contacts comparable to any of those below meet this level. Contacts are with:

  members of the business community or general public;

higher-ranking managers, supervisors, and staff of program, administrative, and other work units and activities throughout the field activity, installation, command (below major command level) or major organization level of the agency;

representatives of local public interest groups;

 case workers in congressional district offices;

 technical or operating level employees of State and local governments;

 reporters for local and other limited media outlets reaching a small, general population.

Contacts may be informal, occur in conferences and meetings, or take place through telephone, televised, radio, or similar contact, and sometimes require nonroutine or special preparation.

At Level 4A-3, contacts comparable to any of those below meet this level. Contacts are with:

 high ranking managers, supervisors, and technical staff at bureau and major organization levels of the agency; with agency headquarters administrative support staff; or comparable personnel in other Federal agencies;

 key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage;

 journalists representing influential city or county newspapers or comparable radio or television coverage;

 congressional committee and subcommittee staff assistants below staff director or chief counsel levels;

 contracting officials and high level technical staff of large industrial firms; 

 local officers of regional or national trade associations, public action groups, or professional organizations; and/or State and local government managers doing business with the agency.

Contacts include those which take place in meetings and conferences and unplanned contacts for which the employee is designated as a contact point by higher management. They often require extensive preparation of briefing materials or up-to-date technical familiarity with complex subject matter.

The appellant’s contacts meet Level 4A-2. Like this level, he has frequent contact with higher ranking managers, supervisors, and staff of program, administrative, and other work units and activities at, supported by, or providing support to the installation, as well as counterparts at FAA facilities and other civil/military aviation organizations. Contacts take place in face-to-face meetings or through telephone, electronic mail, or comparable medium. His contacts may require special preparation to explain air traffic operations, problems, and available options.

The appellant’s contacts do not meet Level 4A-3. This level can be credited only if his work situation fully meets the level description for the contact’s organizational relationship and authority level, as well as the setting and difficulty of preparation in which the contact occurs. Unlike Level 4A-3, the appellant’s contacts do not regularly require extensive preparation of briefing materials, nor does he have contact with politically influential public interest groups, journalists, Congressional committee and subcommittee staff assistants, contracting officials, or local officers of regional or national trade associations. He seeks to credit his position at Level 4A-3 based on contact with high-ranking military and civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency. He states he participates in multi-agency groups and organizations to discuss aviation matters and other issues of concern. For example, he occasionally has contact with officials at the U.S. Army Aeronautical Services Agency, the U.S. Army Communications-Electronics Command, U.S. Army FORSCOM, Air Traffic Services Command, and U.S. Special Operations Command.

 Regardless, the GSSG requires that we solely credit the regular and recurring contacts identified under Subfactor Factor 4A which are the basis for selecting a level under Subfactor 4B. Therefore, while he may have occasional contact with technical staff of higher-level commands within the Department of the Army or multi-agency groups, his regular contacts are limited to those identified under Level 4A-2 and for the purpose identified later under Level 4B-2. In addition, we find he meets none of the other contacts listed under Level 4A-3.

Level 4A-2 is credited for 50 points.

Subfactor 4B-Purpose of Contacts

This subfactor covers the purpose of the contacts credited in Subfactor 4A, including the advisory, representational, negotiating, and commitment making responsibilities related to supervision and management.

At Level 4B-2, the purpose of contacts is to ensure that information provided to outside parties is accurate and consistent; to plan and coordinate the work directed with that of others outside the subordinate organization; and/or to resolve differences of opinion among managers, supervisors, employees, contractors, or others.

At Level 4B-3, the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment(s), or organizational unit(s) directed, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts. Contacts at this level usually involve active participation in conferences, meetings, hearings, or presentations involving problems or issues of considerable consequence or importance to the program or program segment(s) managed.

The purpose of the appellant’s contacts meets Level 4B-2. Like this level, the purpose of his contacts identified under Level 4A-2 is to ensure that information provided to outside managers, supervisors, and technical staff is accurate and consistent with installation ATC policies and procedures, and to plan and coordinate the work he directs with other aviation organizations outside his unit to ensure seamless ATC operations, e.g., Killeen Regional Airport and FAA.

The appellant’s position does not meet Level 4B-3. Unlike this level, in representing his ATC program to outside parties the purpose of his contacts is not to justify, defend, or negotiate matters regarding ATC operations and procedures, including obtaining or committing resources or gaining compliance with established policies, regulations, or contracts. Regarding resources, we note the appellant does not have responsibility nor authority to obtain or commit them. This responsibility resides with the Director of Aviation Operations, Deputy Garrison Commander, and other higher-level positions.

Level 4B-2 is credited for 75 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. Conditions affecting work for which the supervisor is responsible, whether performed by Federal employees, assigned military, contractors, volunteers, or others, may be considered if they increase the difficulty of carrying out assigned supervisory or managerial duties and authorities.

In order to evaluate Factor 6, two steps are used. First, the highest level that a position meets fully is initially credited. Then, if the level selected is 6-1, 6-2, or 6-3, the Special Situations listed are considered. If a position meets three or more of the situations, then a single additional level is added to the level selected in the first step. If the level selected in the first step is 6-4, 6-5, or 6-6, the Special Situations may not be considered in determining whether a higher factor level is creditable.

The numbered paragraphs under Factor 6 are structured to address positions that function as either first-level or second- and higher-level supervisors and managers. The appellant functions as a second-and higher-level supervisor.

The evaluation statement attached to the appellant’s PD credited his position at Level 6-5c; however, DCPAS credited his position at Level 6-4a instead. Level 6-4a pertains to supervision that 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 grade level. For example, such coordination may involve work comparable to one of the following:

identifying and integrating internal and external program issues affecting the immediate organization, such as those involving technical, financial, organizational, and administrative factors;

integrating the work of a team or group where each member contributes a portion of the analyses, facts, information, proposed actions, or recommendations; and/or ensuring compatibility and consistency of interpretation, judgment, logic, and application of policy;

recommending resources to devote to particular projects or to allocate among program segments;

leadership in developing, implementing, evaluating, and improving processes and procedures to monitor the effectiveness, efficiency, and productivity of the program segment and/or organization directed;

reviewing and approving the substance of reports, decisions, case documents, contracts, or other action documents to assure that they accurately reflect the policies and position of the organization and the views of the agency.

OR

b. The position directs subordinate supervisors and/or contractors who each direct substantial workloads comparable to the GS-09 or 10 level. Such base work requires coordination similar to that described at Factor Level 6-3a for first line supervisors.

This level is typically credited to positions that directly supervise GS-11 grade level work as determined under Factor 5. In the appellant’s case, Factor 5 has been credited at the GS-12 grade level. After careful consideration, we find the appellant’s position exceeds the descriptions at Level 6-4a and b.

At Level 6-5a, supervision and oversight requires significant and extensive coordination and integration of a number of important projects or program segments of professional, scientific, technical, managerial, or administrative work comparable in difficulty to the GS-12 level. Supervision at this level involves major recommendations which have a direct and substantial effect on the organization and projects managed. For instance, making recommendations in at least three of the areas listed below or in other comparable areas:

significant internal and external program and policy issues affecting the overall organization, such as those involving political, social, technological, and economic conditions, as well as those factors cited in the first item of Level 6-4a;

restructuring, reorienting, recasting immediate and long range goals, objectives, plans, and schedules to meet substantial changes in legislation, program authority, and/or funding;

determinations of projects or program segments to be initiated, dropped, or curtailed;

changes in organizational structure, including the particular changes to be effected;

the optimum mix of reduced operating costs and assurance of program effectiveness, including introduction of labor saving devices, automated processes, methods improvements, and similar;

the resources to devote to particular programs (especially when staff-years and a significant portion of an organization’s budget are involved);

policy formulation, and long range planning in connection with prospective changes in functions and programs.

OR

 b. Supervision of highly technical, professional, administrative, or comparable work at GS-13 or above involving extreme urgency, unusual controversy, or other, comparable demands due to research, development, test and evaluation, design, policy analysis, public safety, public health, medical, regulatory, or comparable implications.

OR

 c. Managing work through subordinate supervisors, and/or contractors who each direct substantial workloads comparable to the GS-11 level. Such base work requires similar coordination as that described at Factor Level 6-4a above for first line supervisors.

In addition to a base level of GS-12, the appellant’s position meets Level 6-5a within the context of his overall ATC program management responsibilities. Like this level, he is responsible for making recommendations relating to the areas described above. We note his official PD describes the following duty:

Makes major recommendations and provides technical advice on matters that; (a) Affect the basic content and character of terminal operations by determining the need for additional services generated by users within the terminal area, and making recommendations for that implementation or cessation of specific services depending upon determination of need; (b) Have a direct and substantial effect on basic internal program planning evaluation activities by making timely recommendations for the provision of additional services which will be required in the future; (c) Affect decisions on organizational improvements by determining and implementing an internal organizational structure necessary for the accomplishment of collateral duties by subordinates and by delegating authority necessary for their accomplishment; (d) Have an impact on relationships with other groups by establishing and maintaining an effective liaison program with user groups, taking action to implement or revise services to resolve deficiencies noted by user, and coordinating action by support units which could affect services being provided; (e) Affect the economy of operations by being directly responsible for reviewing the cost of facility operations and for revising operational methods as appropriate: for cost reduction and originating budgetary action for the provision of adequate equipment and staffing, and providing justification to appropriate staff officials. Determines the need for and develops specialized procedures to meet local requirements or recommends changes in standard procedures.

The Director of Aviation Operations, who serves as the first-level supervisor and occupies a position classified in the Program Management Series,0340, states that he relies on the appellant to serve as the subject-matter expert, providing input and recommendations on any/all matters affecting air traffic operations. The appellant and supervisor provided recent examples of such recommendations. The appellant participates in planning meetings for base and other projects or activities with potential impact on ATC operations. For example, he provided recommendations on a project involving a wind turbine farm, specifically identifying the project’s impact on ATC operations and providing recommendations to mitigate identifiable risks. In addition, he makes recommendations for costly equipment and technology, e.g., an air traffic control simulator to train personnel ($200,000), fiber optic cable installation ($2 million), and re-cabling of ATC radios ($525,000). The appellant makes recommendations on matters relating to the agency’s efforts to implement a special salary rate for air traffic controllers, the optimum size and structure of his organization to maintain current operations, and COVID-related contingency plans to ensure seamless ATC services. The first-level supervisor recently approved a recommendation made by the appellant, who suggested an Air Traffic Control Specialist (Staff), GS-2152-12, position that previously reported to the Director of Aviation Operations be reassigned to his ATC Division instead. In addition, the appellant enters letters of agreement relating to ATC matters, as well as implements policies regarding emergency call out rosters, noise abatement, loading zones, and other local procedures.

This and other work performed by the appellant are characteristic of Level 6-5a recommendations involving (1) determinations of projects or program segments to be initiated, dropped, or curtailed; (2) changes in organizational structure including the particular changes to be effected; (3) the optimum mix of reduced operating costs and assurance of program effectiveness including introduction of labor saving devices, automated processes, methods improvements, and similar; and (4) policy formulation and long range planning in connection with prospective changes in functions and programs. We conclude the appellant’s position makes recommendations in at least three of the seven areas listed, the minimum required for crediting Level 6-5a. We conclude the appellant’s position fully meets but does not exceed Level 6-5a.

Level 6-5a is credited for 1,225 points.

Summary

Table 1 Grade Determination

Factor	Level	Points
1.Program Scope and Effect	1-2	350
2. Organizational Setting	2-1	100
3. Supervisory and Managerial Authority Exercised	3-3b	775
4A. Nature of Contacts	4A-2	50
4B. Purpose of Contacts	4B-2	75
5. Difficulty of Typical Work Directed	5-7	930
6. Other Conditions	6-5a	1225
Total Points		3505

 

A total of 3,505 points falls within the GS-13 range (3155-3600) on the Point-to-Grade Conversion Chart in the GSSG.

Decision

The appellant’s position is properly classified as Supervisory Air Traffic Control Specialist (Terminal), GS-2152-13.

[1] As part of his appeal to OPM, the appellant provided a number of documents to explain his rationale for supporting the requested classification. We note that on a document dated October 4, 2021, he expressed disagreement with the levels assigned for Factors 1, 2, and 4; on a document dated March 31, 2022, he expressed disagreement with levels assigned for Factors 1 and 6; and on a document also dated March 31, 2022, he expressed disagreement with levels assigned for Factors 1, 2, and 4. However, during the telephone audit, the appellant confirmed that he specifically disagrees with DCPAS’s evaluation for Factors 1, 4, and 6.

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