Washington DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
244th Aviation Brigade
U.S. Army Reserve Command
GS-2181-13
Lakshmi Bouchard
Classification Appeals and FLSA Claims Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
10/09/2018
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).
As discussed in this decision, our findings 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 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), Agency Compliance and Evaluation, Washington, DC, office.
Introduction
The appellant’s position is currently classified as Supervisory Helicopter Pilot, GS-2181-13, but he believes it should be classified at the GS-14 grade level. The position is assigned to 11th Aviation Command, 244th Aviation Brigade, U.S. Army Reserve Command, at the Aviation Support Facility (ASF) in Fort Worth, Texas. OPM accepted a group classification appeal filed by the appellant along with other individuals occupying identical additional positions. Even though he performs essentially identical duties and is assigned to the same PD number DE11371, as the group, the appellant’s ASF organization is sufficiently different to warrant our adjudicating his appeal separately. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
Background and general issues
In response to the group’s filing a classification appeal with OPM, the office with classification authority over the position (hereinafter referred to as “agency”) conducted a review of the classification of the appealed position based on application of the General Schedule Supervisory Guide (GSSG). The agency’s evaluation, dated May 14, 2017, proposed raising the levels assigned to the position for Factor 2, Organizational Setting, from Level 2-1 to 2-2; Factor 3, Supervisory and Managerial Authority Exercised, from Level 3-2c to 3-3b; and Subfactor B, Purpose of Contacts, for Factor 4, Personal Contacts, from Level 4B-2 to 4B-3. In addition, the agency’s evaluation proposed lowering the levels assigned to the appealed position for Factor 5, Difficulty of Typical Work Directed, from Level 5-8 to 5-4 and Factor 6, Other Conditions, from Level 6-5a to 6-3b. The agency’s evaluation concluded the appellant’s position is appropriately classified as GS-2181-12. However, no action was taken to downgrade the position.
When initially filing a classification appeal with OPM, the appellant, along with the others, did not contest any of the factor levels assigned by the agency in its September 1, 1998, evaluation of the position. They all requested classification to the GS-14 grade level based on the adjustment provision provided for by the GSSG, which applies to positions when the supervisory work does not fall at least one grade above the base level of work supervised as determined under Factor 5. That provision allows adjusting the final grade for the supervisory work to one grade above the “base” grade of work directed. The agency originally determined the GS-13 grade level as the base level of work supervised by the position. Because their delegated supervisory authorities and responsibilities met the minimum level of authority and responsibility described at Level 3-2 as required for application of the adjustment provision, all the appellants asserted the final grade of their position should be GS-14, i.e., one grade above the base level of work supervised. Subsequent to the agency’s May 2017 evaluation, they disagreed with the levels assigned to Factors 4A, 5, and 6.
The appellant makes various statements about the classification review process conducted by the agency. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appealed position. By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards (PCS) 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.
The appellant forwarded PD, number 0644000, for a Supervisory Aircraft Pilot, GS-2181-14, position with the National Guard Bureau (NGB). Implicit in their rationale is a concern that their position is classified inconsistently with other positions. Since comparison to OPM’s PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the current duties of the appealed position to another, which may or may not be classified properly, as the basis for deciding the appeal. Regardless, we noted similarities between the appealed position and the work described by the NGB PD, including the responsibility for management and direction of an aviation support facility providing flight operations, proficiency training to aviators and crewmembers, aviation safety, and support maintenance for assigned aircraft. Because the NGB PD does not identify any position locations, there is no evidence it is currently assigned to an actual position and we thus lack sufficient information to warrant tasking a classification consistency report on the position cited by the appellant.
The Defense Civilian Personnel Advisory Service has responsibility for classification consistency within Defense components. By copy of this certificate, we are informing that office of our classification concerns regarding inconsistencies in the evaluation of the similarly described duties and responsibilities. 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. 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 our decision.
Position information
The appellant’s ASF manager position is assigned to the U.S. Army Reserve Aviation Command (ARAC), which provides command and control for all Army Reserve aviation units and individuals. The ASF provides aviation units with support in areas including rotary wing aviation operations, training programs and pilot evaluations, aircraft maintenance, supply, safety, aviation life support equipment, and standardization. The appellant’s position is supervised by the Aviation Program Manager, a GS-0301-14 position that reports to the Commanding General of the ARAC.
The ASF is divided into three work centers, i.e., flight operations, maintenance, and quality control/safety. The Flight Operations Work Center, staffed with instructor pilot and dispatcher positions, manages aviator training programs by planning and conducting flight training and instruction for rated pilots and non-rated crewmembers to include basic and advanced instrument flight, tactics, terrain flight, night vision devices, and special unit mission tasks. The center also evaluates instructor pilots in the conduct of qualification, mission, and continuation training; maintains a centralized flight planning area; and ensures flight records and individual aviator training folders are maintained according to applicable regulations and directives. The Maintenance Work Center is staffed with maintenance mechanics, production control technicians, and supply technicians. The work center receives maintenance work orders, schedules and performs aircraft maintenance, monitors maintenance work, coordinates inspections, conducts maintenance test flights, manages the supply function, and maintains maintenance records and reports. Supervised by a GS-2181-13 Supervisory Maintenance Test Pilot, the Quality Control/Safety Work Center enforces maintenance and safety standards, conducts safety inspections of the work and shop areas, maintains the master technical library, and ensures all safety, hazardous material, and other program requirements are met.
Both the appellant and his supervisor certified to the accuracy of the official PD. However, the agency states in its administrative report to OPM:
Upon review of PD DE11371 and the ASF structures the appellants manage, it was determined that each is different in terms of workload and number of subordinate employees assigned, which affects the base level of work performed. Therefore, the use of one PD for all of the appellants is not appropriate.
Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities currently assigned by management and performed by the employees. An OPM appeal decision is based on the work currently assigned to and performed by the appellant. An OPM appeal decision classifies a real operating position and not simply the PD. This decision is based on the work currently assigned to and performed by the appellant.
Nonetheless, a PD is the official record of the major duties and responsibilities assigned to a position or job by an official with authority to assign work. OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures. Major duties are normally those occupying a significant portion of the employee’s time. They should be only those duties currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time. Although the agency’s May 14, 2017, evaluation proposed changing the levels assigned to the position for Factors 2, 3, 4, 5, and 6, no further action was taken to update the PD at the time. We find the PD contains incorrect, inadequate, and/or misleading descriptions for Factors 2, 3, 4, 5, and 6. For example, the PD states the appellant’s supervisor reports to a position two reporting levels below a general officer, crediting the position with Level 2-1. However, the appellant’s supervisor reports to a position one reporting level below a general officer or equivalent position. The PD must be revised to correct the reporting levels, in addition to its failure to describe responsibility for supervision of subordinate supervisors, the purpose of his contacts, the base level of work supervised, and other inaccuracies. Therefore, the appellant’s PD does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and the agency must revise the PD to reflect our findings.
In reaching our classification decision, we carefully considered all information provided by the appellant and his agency including the official PD which, although not completely accurate, we have incorporated by reference into this decision. Following a telephone audit with the group, we conducted a telephone audit with the appellant to gain more information unique to his ASF. We also conducted a telephone interview with his immediate supervisor.
Series, title, and standard determination
The agency classified the appellant’s position in the Aircraft Operation Series, GS-2181, titling it Supervisory Helicopter Pilot, and the appellant does not disagree. We concur with the agency’s title and series determination, noting the appellant’s supervisory responsibilities fully meet the coverage requirements for titling as a supervisor addressed in the GSSG. As discussed in the titling instructions in the GS-2181 PCS, the prefix “Supervisory” is appropriately added to the basic title of “Helicopter Pilot” prescribed for pilots operating rotary wing aircraft. Because the appellant spends nearly all his work time performing supervisory and related managerial responsibilities, we have solely applied the criteria in the GSSG to evaluate the grade of those duties. Our application of the grading criteria of the GSSG follows.
Grade determination
The GSSG is used to determine the grade of supervisory positions in grades GS-5 through GS-15. The GSSG employs a factor-point evaluation method that assesses six factors common to all supervisory positions. To grade a position, each factor is evaluated by comparing the position to the factor-level description for that factor and crediting the points designated for the highest factor level which is fully met, in accordance with the instructions specific to the factor being evaluated. The total points assessed under all factors are then converted to a grade by using the grade conversion table in the GSSG.
The appellant disagrees with the agency’s May 2017 evaluation, seeking to credit his position with Levels 4A-3, 5-8, and 6-5. We reviewed the agency’s evaluation for Factors 1, 2, 3, and 4-B, concur, and have credited the position accordingly. Our evaluation with respect to the three factors in question follows.
Factor 4, Personal Contacts
This is a two-part factor assessing the nature and purpose of personal contacts related to supervisory and managerial responsibilities. The nature of contacts, credited under subfactor 4A, and the purpose of those contacts, credited under subfactor 4B, must be based on the same contacts.
Subfactor 4A: Nature of Contacts
This subfactor covers the organizational relationships, authority or influence level, setting, and difficulty of preparation associated with the personal contacts. 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 are comparable to any of the following: (1) members of the business community or the general public; (2) 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; (3) representatives of local public interest groups; (4) case workers in Congressional district offices; (5) technical or operating level employees of State and local Governments; and (6) 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, frequent contacts are comparable to any of the following: (1) high ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency; with agency headquarters administrative support staff; or with comparable personnel in other Federal agencies; (2) key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage; (3) journalists representing influential city or county newspapers or comparable radio or television coverage; (4) Congressional committee and subcommittee staff assistants below staff director or chief counsel levels; (5) contracting officials and high level technical staff of large industrial firms; and (6) 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 nature of the appellant’s contacts meets Level 4A-2. As at this level, his frequent contacts are with higher ranking managers, supervisors, and staff of program, administrative, and other offices throughout the ARAC; general officers and other military officials for aviation units serviced; members of the general public and business community; and operating level employees of local, State, and Federal agencies. Because the ASF supports rescue and other domestic emergency operations, the appellant regularly has contact with operating-level employees of the Federal Emergency Management Agency and other components of the Department of Homeland Security, Federal Bureau of Investigation, National Park Service, and the Department of Public Safety at the State and local levels as described at Level 4A-2. Also similar to this level, his contacts require special preparation in order to explain operations, problems, and available options.
The group of appellants sought to credit their position at Level 4A-3, stating in part that they communicate with and conduct briefings for Congressional committees and members, as well as with local and State representatives. The Aviation Program Manager states all ASF managers have contact with members of the U.S. Congress at least three to four times a year for visits and other purposes. In addition, the appellant has contact with local journalists to promote recruitment, retention, and community involvement efforts, e.g., at major airshows and other community events. Regardless, the various contacts with journalists and Congressional members are not frequent and do not often require the extensive preparation of briefing materials or up-to-date familiarity with complex subject matter described at Level 4A-3. Even if, assuming arguendo, the appellant has frequent contact with Congressional members and journalists, classification principles require us to use the same personal contacts that serve as the basis for the level selected for Level 4B, Purpose of Contacts, when selecting the appropriate level for Level 4A. We agree with the agency’s crediting of Level 4B-3, as we found the purpose of most of his contacts is to justify, defend, or negotiate in representing the ASF, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts. In contrast, the appellant’s contacts with journalists and Congressional members are typically for the purpose of exchanging factual information typical of Level 4B-1, and not for the purpose of obtaining or committing resources on a regular and recurring basis as described at Level 4B-3. Since we are required to use the same personal contacts serving as the basis for the level selected under Factor 4A, when selecting a level for Factor 4B, crediting the position with Levels 4A-3 (75 points) and 4B-1 (30 points) would result in a total of 105 points, a decrease of 45 points from the 150 points derived from the crediting of Level 4A-2 (50 points) and 4B-3 (100 points).
Unlike Level 4A-3, the appellant’s contacts are not with high ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency; with agency headquarters administrative support staff; or with comparable personnel in other Federal agencies. The appellant controls ASF resources and is delegated with the requisite authority necessary to gain support and compliance on policy and other matters, specifically exercising such authority in communication with battalion/company commanders of supported aviation units. He advises and assists unit commanders in the development, management, and execution of individual and collective unit training programs, routinely negotiating with them on provisions relating to facilities and equipment, maintenance support, flight training, and other assistance when requested. Although the appellant has regular contact with high ranking military and civilian managers throughout the ARAC, that organization is a functional command within the U.S. Army Reserve and is thus not equivalent to a bureau level as described at Level 4A-3.
Level 4A-2 is credited for 50 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.
The agency proposed crediting Level 5-4 for the appellant’s position, identifying GS-8 as the base level of work for his organization. However, the group of appellants asserts the GS-13 as the base level of work for their organizations and that Level 5-8 is appropriate for the appealed position. They state in comments to the agency administrative report:
We also find that the formula to determine the “base level of work” is flawed and does not include all positions that are authorized within the ASF’s. In addition it doesn’t not [sic] give the GS-13 supervisory [instructor pilots] or [maintenance test pilots (MTP)] any credit at the GS-13 level for non-supervisory work performed. We would also point to the fact that the Supervisory Instructor Pilot (PD DEASF006) is given credit under factor 5 for “At least 25% of the work load is at the GS-13 level” while the Supervisory MTP (PD DEASF007) under factor 5 is given credit for “50% of the work-load is at the GS-12 level.” Based on the formula used by [the agency] in their review the Appellant’s are penalized for having a larger workforce.
In evaluating second (and higher) level supervisors like the appellant under this factor, the GSSG instructs to first use the 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); and
• lower-level support work that primarily facilitates the basic work of the unit.
The group of appellants raised various issues regarding the agency’s evaluation of Factor 5, specifically the grade levels credited to nonsupervisory work performed by subordinate supervisors and other positions; the equivalent GS grades determined by the agency for Federal Wage System (FWS) work; and the comparison to the Job Family Standard (JFS) for Administrative Work in the Equipment, Facilities, and Services Group, GS-1600, to determine the FWS to GS work equivalencies. Furthermore, the appellants’ characterization of the FWS work as “support work” implicitly raises the question of their inclusion into the workload calculation. However, we considered the maintenance, repair, and trades work performed by the mechanics and other FWS jobs as reflective of the ongoing work of the Maintenance Work Center. Their work does not facilitate (aid) the basic work of the ASF, but rather directly and significantly serves the ASF mission of providing maintenance and supply services to United States Army Reserve aviation units. Additionally, although we normally assume the agency’s classification of a position is accurate when assessing the base level of an organization’s work, the agency states that ARAC managers exercised delegated classification authority to override the agency’s classification determination for positions including the Maintenance Test Pilot, GS-2181-13, position assigned to PD number DE271118. For these and other reasons, we evaluated the ASF PDs relevant to the appellant’s unit to make our own determination concerning workload calculation. Our analysis of the base levels assigned to his ASF follows the findings relating to our evaluation of the PDs.
Grade levels credited to Aircraft Pilot, GS-2181-13, position assigned to PD number DE181871. Our workload calculations normally credit the grade levels associated with the various duties performed by a position as documented in the official PD, rather than assume the entire workload of the position is at the same grade level. The agency states the position performs GS-13 work for 30 percent of the time and GS-11 work for 70 percent. Although we assume the agency’s classification of a position is accurate when assessing the base level of an organization’s work, the agency provided no evaluation statement for the position. The PD shows the pilot operates heavy single- or multi-engine airplanes and/or helicopters with some flights flown over unfavorable terrain, at low altitudes, and airspeeds outside of the recommended flight envelope for 30 percent of the time. The remaining 70 percent is spent on one or more major duties including serving as a rotary and/or fixed wing instructor pilot, rotary and/or fixed wing maintenance test pilot, aviation safety officer, Government flight representative, or other duties as assigned. The pilot’s flying and flight instruction work is characteristic of that described by the GS-2181 PCS at the GS-13 level. The appellant, in addition to stating the pilot’s position is heavily involved with flight instruction, estimates spends 75 percent of the time on GS-13 work and 25 percent on GS-12 work, which we find plausible based on our review of the PD and other information of record.
(75% at the GS-13 and 25% at the GS-12)
Grade levels credited to Supervisory Maintenance Test Pilot, GS-2181-13, position assigned to PD number DEASF0007. The agency states the position spends 25 percent of the time on supervisory work and 75 percent on GS-11 work. According to the PD, the incumbent conducts maintenance test flights and operational checks following maintenance, repair, and/or replacement of parts, components, or systems to assure airworthiness of aircraft. This work is characteristic of that described by the GS-2181 PCS for a maintenance test pilot at the GS-12 grade level, which the PCS describes as work “[t]o conduct functional flight checks of light airplanes or helicopters following repair, maintenance, or the installation of approved modifications to aircraft systems.” The GS-2181 PCS does not describe any assignments characteristic of maintenance test pilots at the GS-13 level. We thus credited the maintenance test pilot work personally performed by the supervisory position at the GS-12 level. The PD shows the position performs supervisory work for 25 percent of the time, maintenance test pilot work for 70 percent, and maintenance of aviator proficiency work creditable at the GS-11 level for 5 percent.
(70% at the GS-12 and 5% at the GS-11)
Grade levels credited to FWS jobs. All nonsupervisory trade jobs perform mission essential work and must be included in workload calculations. Since this factor measures the difficulty of work supervised in terms of GS grades, the work performed by non-GS employees must be converted to the appropriate GS equivalent grades for the purpose of applying these criteria. The grades of FWS positions do not correspond to GS grades, e.g., an FWS position classified as WG-12 is not considered equivalent to GS-12 because GS positions involve the application of knowledge and skills that are not required for FWS positions. FWS positions must be converted to their GS equivalent grades by comparing them to GS classification standards for occupational series involving the performance of similar or related activities. We approached the conversion of FWS positions to GS equivalent grades, as follows.
The agency states the Electronic Integrated Systems Mechanic, WG-2610-12 (PD number DEASF014), and Aircraft Repair Inspector, WG-8852-12 (PD numbers DE16966), jobs are equivalent to the GS-9 grade level. The PD shows the WG-2610 mechanic is responsible for installing, troubleshooting, testing, repairing, and analyzing malfunctions on complex integrated electronic avionics systems, subsystems, and aircraft electrical power control and distribution systems. The PD for the WG-8852 job shows the inspector is responsible for performing quality assurance inspections and evaluations of ASF- or contractor-performed aircraft maintenance and repairs, inspecting aircraft fuselage and airframes, landing gears, tires and/or skids, fuel, electrical, hydraulic, flight controls, instruments, and other systems required to make aircraft mission capable. We find the jobs are involved in maintenance and inspection work requiring judgment and interpretation of technical guides, schematics, or blueprints in carrying out the work. Work in these occupations are equivalent in nature to GS technical work, defined as requiring extensive practical knowledge gained through experience and/or training and involving the carrying out of tasks, methods, procedures, and computations laid out in published instructions and covered by established guidelines. Technical work typically follows a one-grade interval pattern and does not require the application of knowledge and skills equivalent to those required for two-grade interval work. These jobs can be converted to GS equivalent grades by comparing them to criteria contained in the JFS for Technical Work in the Engineering and Architecture Group, GS-800, which covers related installation, maintenance, operating, and testing work. At the GS-9 level and above in the series, duties begin to resemble work performed by beginning professional employees in the same general occupational field.
The GS-800 JFS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors with Factor 1 (Knowledge Required by the Position) carrying the most weight. Given the incumbents of the WG-12 jobs are responsible for the most complex maintenance and inspection work performed at the ASF and the accompanying level of knowledge and skills required, we will credit their work at Level 1-6, which requires practical knowledge of a wide range of technical methods, principles, requirements, work techniques, and practices of an area of specialization, and skill in applying standardized, analytical, and evaluative methods and techniques sufficient to, e.g., perform installation, maintenance, operations, and testing duties and to advise on and/or resolve difficult but well-precedented factual, procedural, and/or recurring issues. By reference to The Classifier’s Handbook (which provides tables illustrating how FES factors are typically used in positions, helping to understand how the most common factor levels are used at various grades for different kinds of work), the factor-level relationships described for technical work identify Level 1-6 as the common factor level assigned to GS-9 positions, which is the highest grade identified by the table for technical work. However, as a result of the specialized nature of the work performed in the highly regulated and unique aviation environment, and because the WG-12 PDs state the mechanic works “without technical supervision” and the inspector with only “general supervision,” we conclude the resulting factor-level assignments by comparison to the GS-800 JFS would result in GS-10 as the highest potential GS equivalent grade for the WG-12 mechanics and inspectors.
(GS-10 equivalent grade)
Regarding the Aircraft Mechanic Supervisor, WS-8852-11, job assigned to PD number DEASF008, the agency states the incumbent spends 75 percent of the time on supervisory work and 25 percent on GS-9 equivalent work. The PD, however, describes mostly supervisory-related duties divided into categories identified as management, planning, and work direction. Because we are unable to identify any nonsupervisory work or the percentage of time any such work is performed by the incumbent based on our PD review, we excluded the entire position for workload calculation purposes.
The agency states the Aircraft Mechanic, WG-8852-10 (PD numbers DEASF016 and DEF0450) and Sheet Metal Mechanic, WG-3806-10 (PD number DE16438), jobs are equivalent to the GS-8 grade level. A review of the WG-10 mechanic PDs show similarities in the work performed, as well as how work is assigned, supervised, and reviewed. In general, the WG-8 mechanics perform a variety of work involving maintenance and repair tasks. Their work can be converted to a GS equivalent grade by comparison to criteria in the GS-800 JFS and is characteristic of positions at Level 1-5, which require practical knowledge of, and skill in applying, standardized rules or operations requiring substantial training or experience in methods and practices sufficient to perform limited projects involving specialized or complicated procedures; interpret drawings, plans, and specifications; identify and correct deficiencies; ensure appropriate interaction between components; and employ a variety of complex precision instruments, gauges, and methods. By reference to The Classifier’s Handbook, the factor-level relationships described for technical work identify Level 1-5 as the common factor level assigned to GS-7 and GS-8 positions. Because the PDs show the shop foreman generally assigns, prioritizes, and oversees the work of the WG-10 mechanics, we conclude GS-8 would be the highest potential GS equivalent grade based on the resulting factor-level assignments.
(GS-8 equivalent grade)
The agency states the Aircraft Mechanic Leader, WL-8852-10, job assigned to PD number DE11380, spends 85 percent of the time on leader work and 15 percent on GS-9 equivalent work. The PD shows the incumbent spends 77 percent of the time on leader work and 23 percent on performing work along with the mechanics led, which we considered equivalent to the GS-8 level as explained previously. For workload calculations, we excluded the leader work and credited 23 percent at the GS-8 level.
(23% at the GS-8 equivalent grade)
The appellant states his ASF’s workforce is currently comprised of 23 authorized FTEs, in contrast to the 17 FTEs reported by the agency. Army Regulation 140-1, dated January 20, 2004, requires the ASF’s staffing levels to be maintained at 100 percent of authorizations. In the event staffing levels drop below 85 percent of requirements exceeding 120 days, the ARAC must obtain a waiver in order for the ASF to continue flight operations. The supervisor confirmed the information reported by the appellant is a more accurate reflection of the workforce as it is currently configured. Since the appellant’s information includes positions in the process of being filled, we will consider all FTEs reported by him for workload calculation purposes in order to maintain the relevancy of our analysis by reflecting the organization as it will be in the near future. Regardless, we note that GS-10 would be fully representative of the highest level of nonsupervisory work performed by the ASF even if we had only considered the 17 FTEs reported by the agency.
Of the 23 FTEs reported by the appellant, 5 positions are under the GS and 17 positions are under the FWS. The appellant had also reported two contractor positions assigned to the ASF (i.e., one contractor performing supply technician work and the other performing work, as stated by the appellant and his supervisor, consistent with duties classified to the Administrative Work in the Information Technology Group, 2200). Although he determines whether contractor-performed work meets standards of adequacy, the appellant does not exercise the supervisory responsibilities identified under Factor 3 over the contractors (e.g., approve leave, give advice and instruction on both work and administrative matters, and interview candidates). Such responsibilities fall on the contractor or the Aviation Program Manager. The contractors are thus excluded from base level consideration. The total staff for purposes of workload calculation after the supervisor and leader work is excluded is 20.21 FTEs. The base level of work for the ASF follows.
GS-13
.75 Aircraft Pilot, GS-2181 (PD number DE181871)
GS-12
.70 Supervisory Maintenance Test Pilot, GS-2181 (PD number DEASF007)
.25 Aircraft Pilot, GS-2181 (PD number DE181871)
.95
GS-11
.05 Supervisory Maintenance Test Pilot, GS-2181 (PD number DEASF007)
GS-10
2.0 Aircraft Repair Inspector, WG-8852-12 (PD number DE16966)
2.0 Electronic Integrated Systems Mechanic, WG-2610-12 (PD number DEASF014)
4.0
GS-8
1.0 Aircraft Dispatcher, GS-2151 (PD number DEASF030)
.46 Aircraft Mechanic Leader, WL-8852-10 (PD number DE11380)
8.0 Aircraft Mechanic, WG-8852-10 (PD number DEASF016)
1.0 Aircraft Mechanic, WG-8852-10 (PD number DEF0450)
2.0 Sheet Metal Mechanic, WG-3806-10 (PD number DE16438)
12.46
GS-7
1.0 Production Controller (Aircraft), GS-1152 (PD number DEASF022)
GS-6
1.0 Supply Technician, GS-2005 (PD number DEASF024)
The total nonsupervisory mission-oriented workload is 20.21 FTEs. The percentage of nonsupervisory mission-oriented workload at each grade level is as follows:
GS-13: 3.71%
GS-12: 4.70%
GS-11: 0.25%
GS-10: 19.79%
GS-8: 61.65%
GS-7: 4.95%
GS-6: 4.95%
At 19.79 percent, the GS-10 grade level work constitutes less than 25 percent of the nonsupervisory workload. However, when combined with the 8.66 percent expended on the GS-13, 12, and 11 workload performed by the ASF, we find the GS-10 work fully representative of the highest level of nonsupervisory work performed by the ASF.
Even though the GSSG states the method applied above for evaluating first-level supervisors will be the correct one for many second-level supervisors, it provides an alternative method for evaluating second (and higher) level supervisors under this factor in those cases where a heavy supervisory or managerial workload related to work above the base level (as identified by application of the first method) is present. It involves determining the highest grade of nonsupervisory work directed which requires at least 50 percent of the duty time of the supervisory position under evaluation.
The appellant believes this alternative method is applicable to his situation, but this method is not applicable for most second- and higher-level supervisors and is particularly inapplicable to the appellant’s position. Aside from there being no practical means of determining how much time he devotes to supervising these specific workloads, the appellant supervises minimal staff of nonsupervisory/non-leader positions above the GS-10 base level identified using the first method. The number of FTEs at the GS-11, 12, and 13 grade levels are 1.75 at ASF Fort Worth, rendering it unlikely he would devote 50 percent or more of his time overseeing the work performed by these particular positions. As such, the alternative method is not applicable to the appellant’s position and the base grade level derived through use of the first method is appropriate.
Furthermore, the adjustment provision provided for by the GSSG, which the appellant had originally asserted to in his initial request to OPM, is not relevant to this situation as it applies to positions only when the supervisory work does not fall at least one grade above the base level of work supervised as determined under Factor 5. Because we found the ASF’s base level of work is the GS-10 level, the adjustment provision is inapplicable to the appellant’s position because his supervisory work is classified more than one grade above the base level of work supervised.
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 appellant’s position meets Level 6-3a, where supervision and oversight requires coordination, integration, or consolidation of administrative, technical, or complex technician or other support work comparable to GS-9 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. As at Level 6-3a, the appellant’s supervisory work requires coordination, integration, and consolidation of administrative, technical, or complex technician work equivalent to the GS-10 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 ASF is the GS-10 level, not the GS-11 level 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-9 or 10 level. The Supervisory Maintenance Test Pilot, GS-2181-13, position over the ASF’s Quality Control Work Center directs a staff of aircraft repair inspectors performing work equivalent to the GS-10 level; however, the Aircraft Mechanic Supervisor, WS-8852-11, over the far larger Maintenance Work Center directs a staff comprised of mostly mechanics performing work equivalent to the GS-8 level. Because he does not direct subordinate supervisors who are responsible for substantial workloads comparable to the GS-9 or 10 level, the appellant’s position cannot be credited with Level 6-4b.
We found the appellant’s position meets three of the eight special situations: variety of work, physical dispersion, and special hazard and safety conditions. We found the remaining special situations are inapplicable to his position (i.e., shift operations, fluctuating workforce or constantly changing deadlines, special staffing situations, impact of specialized programs, and changing technology), and we will therefore not address those conditions.
Variety of Work. 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 4 GS and 3 FWS occupations requiring distinctly different bodies of knowledge, this situation is credited to his position.
Physical Dispersion. This situation 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.
First and foremost, the ASF is a flying organization where both its staff and its assets are, by their very nature, regularly dispersed throughout the United States. Specifically, the Flight Operations and Quality Control Work Centers, i.e., two of the ASF’s three centers, primarily perform pilot work. When the instructor pilot flies helicopters and airplanes to other ASFs or other locations throughout the United States, typically two to four hours a day, he is inaccessible for the duration of the flight. While the subordinate pilot is engaged in both short- and long-range flights, the appellant monitors the pilot’s estimated time of arrival (ETA) based on the approved flight plan. When directed off course due to inclement weather or other reasons, the pilot contacts a flight service station who will, in turn, contact the appellant to communicate the updated ETA. If a pilot is late, the appellant is required to take almost immediate action regardless of whether the mission occurs during the workday, weekend, or after hours. As directed by the overdue aircraft procedures described by ARAC ASF’s Standard Operating Procedures, dated March 5, 2018, when an aircraft is overdue 30 minutes past the ETA without any updates, the appellant states he will conduct a visual search of the ramp and contact base operations to watch for the aircraft. If the aircraft is an hour late without updates, the appellant implements the pre-accident procedures which, in part, require he contact the Aviation Program Manager. In addition to the test runs typically performed within a 30-mile radius of the ASF’s base, the maintenance test pilot regularly assists other ASFs and aviation units, throughout the United States, requiring test pilot assistance. The ASF’s pilots also assist in firefighting and crash rescue services, medical evacuation services, and other disaster or emergency situations. The appellant is unable to communicate with subordinate pilots, who are inherently dispersed with their exact locations varying widely on a day-to-day basis, while they are in the air. We thus conclude the physical dispersion complicates the appellant’s ability to make staff assignments, coordinate tasks, evaluate work, and perform other day-to-day responsibilities for the pilots over which he has direct supervisory responsibility.
Furthermore, the ASF supports the approximately 600 soldiers assigned to the serviced aviation units. The appellant approves flight plans for military pilots. Although he does not serve as the supervisor for military pilots, the appellant similarly monitors the pilot’s ETA and will implement overdue aircraft and/or pre-accident procedures when necessary. He is responsible for the oversight of the six Beechcraft C-12 Hurons and three UC-35 Cessnas managed by the ASF. According to the appellant, the six C-12s (valued at 4 million dollars) and three UC-35s (valued at 18 million dollars) are each flown regularly, some daily, by the ASF staff, aviation units supported, and others. Because the pilots and aircraft are detached from the ASF in order to perform the mission, it is clear that demands are placed on the appellant to be vigilant at all times in the event appropriate procedures are to be implemented when necessary. Because the physical dispersion complicates the day-to-day supervision required, the appellant’s position is credited with this situation.
Special Hazard and Safety Conditions. This situation is credited when the supervisory position is regularly made more difficult by the need to make provisions for significant or hazardous conditions occurring during performance of the work of the organization.
The ASF presents two-fold dangers inherent with an airfield and a maintenance and repair facility. Almost all aspects of the ASF’s work pose a potential hazard, danger, or risk associated with moving rotor blades, toxic chemicals, working on elevated surfaces and confined spaces, noise, severe weather, electrical shocks, cuts and bruises, and other safety issues present on the ground and in the air. The appellant is responsible for the ASF’s safety functions, as his PD states his position is responsible for establishing and implementing a comprehensive flight and ground safety program and ensuring all safety and HAZMAT program requirements are met. The extent of such responsibilities are described by the ARAC ASF’s Standard Operating Procedures, which confirm the appellant’s position as ASF supervisor is delegated responsibility for safety management programs including, but not limited to, spill risks, fire prevention and protection, hazardous materials, environmental compliance, hearing conservation, radiological protection, confined spaces, and fall protection.
We also note the PD for the Aircraft Pilot, GS-2181-13, states the pilot operates aircraft under substantially hazardous conditions to fight fires, intercept aircraft suspected of smuggling, and other law enforcement activities. The PD for the Supervisory Maintenance Test Pilot, GS-2181-13, shows the pilot is responsible for performing the hazardous inspection work of testing the airworthiness of repaired aircraft. The appellant ensures the aircraft and maintenance test pilots and his other subordinate employees know and implement safety rules, complete safety and physical tests, maintain required certifications, and utilize the inventory of personnel protective equipment. He also ensures the staff complies with all safety directives on a day-to-day basis. The appellant’s position is therefore credited with this situation involving responsibility for making provisions for “significant unsafe or hazardous conditions.”
Since three special situations are credited to the appellant’s position, a single level is added to the Level 6-3 factor level assignment. Level 6-4 is credited for 1,120 points.
Summary
| Factor | 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-3 | 100 |
| 5. Difficulty of Typical Work Directed | 5-5 | 650 |
| 6. Other Conditions | 6-4 | 1120 |
| Total | 3,295 |
This point total falls within the GS-13 range (3,155-3,600) on the grade conversion table provided in the GSSG.
Decision
The appellant’s position is properly classified as Supervisory Helicopter Pilot, GS-2181-13.