MEMORANDUM FOR THE PRESIDENT

 

SUBJECT: Annual Report on Locality-Based Comparability Payments for the General Schedule

 

Under current law, the President’s Pay Agent must submit a report each year showing the locality-based comparability payments we would recommend for General Schedule employees in the following fiscal year if the adjustments were to be made in accordance with section 5304 of title 5, United States Code.  In keeping with this statutory requirement, this report shows the adjustments we would recommend for January 2003 if the methodology and rates required by current law were to be implemented.  For the reasons explained below, however, we do not recommend implementation of these adjustments in 2003.  A final decision on the 2003 locality payments is not needed at this time.

Our plans for locality pay area boundaries in 2003 and our decisions on the methodology for comparing Federal and non-Federal rates of pay (as required by current law) also are contained in this report.  Our work on these matters has been greatly facilitated by the Federal Salary Council.

The Pay Agent is mindful of the fact that, once again this year, Congress has enacted legislation that provides an overall General Schedule pay increase in January 2002—including locality payments—that is considerably smaller than the amount that would have been required by current law.  (The January 2002 pay increase will, however, be larger than originally proposed in the Administration’s budget request for fiscal year 2002.)  Given the current national emergency situation and the nearly $10 billion cost of the locality pay increases that would be required under current law, we believe it would be imprudent and unwise to allow the locality pay increases shown in this report to take effect in January 2003.  The Pay Agent also has serious concerns about the utility of a process that focuses too much attention on locality payments and not enough attention on the differing labor markets for major occupational groups or the performance of individual employees.  We believe it is time to consider alternative approaches to the compensation of Federal employees that will lead to a Government that is citizen-centered, results-oriented, and market-based.  

The President’s Pay Agent:

 

                                                                                         

Elaine L. Chao                                     Mitchell E. Daniels, Jr., Director

Secretary of Labor                         Office of Management and Budget 

 

 

Kay Coles James, Director

Office of Personnel Management 

  INTRODUCTION

The Federal Employees Pay Comparability Act of 1990 (FEPCA) replaced the nationwide General Schedule (GS) with a method for setting pay for white-collar employees that uses a combination of across-the-board and locality pay adjustments. The policy for setting General Schedule pay contained in 5 U.S.C. 5301 is that-

(1) there be equal pay for substantially equal work within each local pay area;

(2) within each local pay area, pay distinctions be maintained in keeping with work and performance distinctions;

(3) Federal pay rates be comparable with non-Federal pay rates for the same levels of work within the same local pay area; and

(4) any existing pay disparities between Federal and non-Federal employees should be completely eliminated.

The across-the-board pay adjustment provides the same percentage increase to the statutory pay systems (as defined in 5 U.S.C. 5302(1)) in all locations. This adjustment is linked to changes in the wage and salary component, private industry workers, of the Employment Cost Index (ECI), minus 0.5 percentage points. Locality-based comparability payments for GS employees, which are in addition to the across-the-board increase, are mandated for each locality having a pay disparity between Federal and non-Federal pay of greater than 5 percent.

As part of the annual locality pay adjustment process, the Pay Agent prepares and submits a report to the President which—

(1) compares rates of pay under the General Schedule with rates of pay for non-Federal workers for the same levels of work within each locality pay area, based on surveys conducted by the Bureau of Labor Statistics;

(2) identifies each locality in which a pay disparity exists and specifies the size of each pay disparity;

(3) recommends appropriate comparability payments; and

(4) includes the views and recommendations of the Federal Salary Council (FSC), individual members of the FSC, and employee organizations.

The President’s Pay Agent consists of the Secretary of Labor and the Directors of the Office of Management and Budget and the Office of Personnel Management.

This report fulfills the Agent’s responsibility under 5 U.S.C. 5304(d), as amended. It recommends locality pay adjustments for 2003 if they were made under 5 U.S.C. 5304.

 

ACROSS-THE-BOARD AND LOCALITY ADJUSTMENTS

Under FEPCA, General Schedule salary adjustments, beginning in January 1994, consist of two components:  (1) a general increase linked to the Employment Cost Index (ECI) and applicable to the General Schedule, Foreign Service pay schedules, and pay schedules established under title 38, United States Code, for Veterans Health Administration employees, and (2) a General Schedule locality adjustment that applies only to specific areas of the continental United States where non-Federal pay exceeds Federal pay by more than 5 percent. 

The formula for the general increase (defined in section 5303 of title 5, United States Code) provides that the pay rates for each statutory pay system be increased by a percentage equal to the 12-month percentage increase in the ECI, minus one-half of one percentage point.  The 12-month reference period ends with the September preceding the effective date of the adjustment by 15 months. 

The ECI reference period for the January 2003 increase is the 12-month period ending on September 30, 2001.  During that period, the ECI increased by 3.6 percent.  Therefore, the January 2003 general increase, if granted, would be 3.1 percent (3.6 percent minus 0.5 percentage points). 

The locality component of the pay adjustment is mandated under FEPCA to be phased in over a 9-year period.  In 1994, the minimum comparability increase was two-tenths of the “target” pay disparity (i.e., the amount needed to reduce the pay disparity to 5 percent).  For each successive year, the comparability increase was scheduled to be at least an additional one-tenth of the target pay disparity.  For 2003, the law authorizes the full amount necessary to reduce the pay disparity in each locality pay area to 5 percent.

 

LOCALITY PAY SURVEYS

In the past, the Bureau of Labor Statistics (BLS) conducted a new survey of non-Federal pay each year in each locality pay area using survey methods approved by the Pay Agent. Commencing with the 1996/97 surveys, BLS implemented a new survey design for its salary surveys. The new survey program, called the National Compensation Survey (NCS) program, was used in all BLS salary surveys started after September 1996.

The Pay Agent deferred a decision on the use of data from the NCS program for locality pay purposes until receiving the views and recommendations of the Federal Salary Council. After careful examination and review of BLS tests and pilot surveys, the Federal Salary Council concluded that the NCS program is not suitable for use in the locality pay program and that the Pay Agent should direct BLS to reinstate the previous survey methodology, which had been approved by the Pay Agent. Some of the Council’s concerns included:

• Whether the NCS grade leveling approach assigns the correct General Schedule grade equivalent to both supervisory and non-supervisory jobs;

• Whether a probability sampling approach adequately represents Federal jobs without over-representing female-dominated jobs, and whether results will be stable over time; and
 
• Whether probability sampling results in differences in jobs surveyed among cities that may cause differences in pay disparities.

The Pay Agent agreed with the Council’s conclusion that the NCS program, as currently configured, should not be used for the locality pay program, but it did not ask BLS to reinstate the previous methodology. The Pay Agent has concluded that the NCS program has several advantages over the previous salary survey program. These include offering greater occupational coverage, being less costly, and being less burdensome on respondents. However, the Pay Agent also concluded that certain major aspects of the NCS program, including some of those raised by the Council, would have to be improved before it would be prudent to use NCS data for making pay comparisons under the locality pay program. During the past year, Pay Agent staff have continued to work with BLS staff to design, test, and begin implementing improvements in the surveys. We are hopeful that the NCS program improvements now under way will permit us to use the survey data delivered next year.

The Council has recommended and we have agreed to use the most recent BLS survey under the previous survey methodology to calculate pay disparities for this report. Because no new surveys have been conducted under the old methodology, the survey data used here are the same as used previously. However, the data have been updated (aged) to March 2001 for this report.
 

Industrial and Establishment Size Coverage

As required by FEPCA, BLS salary surveys used for the locality pay program include the collection of salary data from private industry and State and local governments, which have large numbers of workers, especially in certain occupations that are unique to government functions. Before 1991, BLS surveys for the pay comparability process covered only private sector goods-producing and service-producing industries.

The industry scope of the surveys included mining, construction, and manufacturing; service-producing industries, including transportation, communications, electric, gas, and sanitary services; wholesale trade; retail trade; finance, insurance, and real estate; services industries; and State and local governments. Households, agriculture, and the self-employed were excluded. The survey covered establishments with 50 or more workers.

Occupational Coverage

In the surveys used for this report, BLS surveyed 115 work levels distributed over 26 occupations, as shown in Table 1, below.

Table 1.  Full Job List for Locality Surveys

Occupational Category:  Professional	GS-1	GS-2	GS-3	GS-4	GS-5	GS-6	GS-7	GS-8	GS-9	GS-10	GS-11	GS-12	GS-13	GS-14	GS-15
Accountant					I		II		III		IV	V	VI
Accountant, Public							I		II		III	IV
Attorney									I		II	III	IV	V	VI
Engineer					I		II		III		IV	V	VI	VII	VIII
Buyer/Contracting Specialist  (Levels I and II cover Federal employees in both professional and technical categories.)					I		II		III		IV
Scientist					I		II		III		IV	V	VI	VII	VIII
Occupational Category:  Administrative	GS-1	GS-2	GS-3	GS-4	GS-5	GS-6	GS-7	GS-8	GS-9	GS-10	GS-11	GS-12	GS-13	GS-14	GS-15
Budget Analyst					I		II		III		IV
Computer Programmer					I		II		III		IV	V
Computer Systems Analyst									I		II	III	IV	V
Computer Sys Analyst Supv/Mgr												I	II	III	IV
Personnel Specialist					I		II		III		IV	V	VI
Personnel Supervisor/Mgr											I	II	III	IV	V
Tax Collector					I		II		III
Occupational Category:  Technical	GS-1	GS-2	GS-3	GS-4	GS-5	GS-6	GS-7	GS-8	GS-9	GS-10	GS-11	GS-12	GS-13	GS-14	GS-15
Computer Operator				I	II	III	IV	V
Drafter			I	II	III		IV
Engineering Technician			I	II	III		IV		V		VI
Engineering Technician, Civil			I	II	III		IV		V		VI
Occupational Category:  Clerical	GS-1	GS-2	GS-3	GS-4	GS-5	GS-6	GS-7	GS-8	GS-9	GS-10	GS-11	GS-12	GS-13	GS-14	GS-15
Clerk, Accounting (Levels III and IV cover Federal employees in both clerical and technical categories.)		I	II	III	IV
Clerk, General	I	II	III	IV
Key Entry Operator		I	II
Personnel Assistant (Level IV covers Federal employees in the technical category.)			I	II	III	IV
Secretary				I	II	III	IV	V
Word Processor (Level  III covers Federal employees in both clerical and technical categories.)			I	II	III
Occupational Category:  Officers, Protective	GS-1	GS-2	GS-3	GS-4	GS-5	GS-6	GS-7	GS-8	GS-9	GS-10	GS-11	GS-12	GS-13	GS-14	GS-15
Corrections Officer							I
Firefighter					I
Police Officer, Uniformed					I	II

 

LOCALITY PAY AREAS

Under 5 U.S.C. 5304(e)(2)(A), the Federal Salary Council made a recommendation to the Pay Agent on the composition of locality pay areas for 2003.  This recommendation was transmitted to the Pay Agent in a memorandum dated October 31, 2001.  (See Appendix I.)  The Council recommended the continuation of the 32 locality pay areas already established, which, with the exception of the “Rest of U.S.” (RUS) area and certain “areas of application” described below, correspond to the most recent metropolitan area definitions set forth by the Office of Management and Budget (OMB).

Pay Disparities Below the RUS Pay Disparity

The Council continued its previous recommendation that the data for any area with a pay disparity below that for the RUS locality pay area should be combined with the data for the RUS area in a cost-neutral fashion.  The pay disparity in three of the survey areas is below the RUS pay disparity of 28.64 percent:

Area	Pay Disparity	GS Payroll
Huntsville	26.41%	$605,802,522
Indianapolis	26.81%	$289,197,226
Kansas City	27.84%	$694,385,843
RUS	28.64%	$21,133,262,981
AVERAGE\TOTAL	28.53%	$22,722,648,572

In the past, the Council has recommended that locations with low levels of published data and a pay disparity 2/10 of a percentage point or more below the RUS pay disparity, or with a pay disparity below the RUS pay disparity in three surveys, be dropped and the resources used to survey a new location. More recently, the Council recommended that locations with pay disparities below the RUS pay disparity continue as locality pay areas for the following reasons:

• It is not feasible to reallocate resources to survey new locations because BLS’ new surveys are not yet suitable for use in the locality pay program;

• The reliability of all the pay disparities can be questioned because BLS has not resurveyed any location using the Pay Agent-approved survey methodology since 1996, and the RUS locality pay area has not been resurveyed using this methodology since 1994/1995; and

• The relatively smaller pay disparity in some cities is due, in part, to Government downsizing and removing agencies or groups of employees from the General Schedule.

We accept the Council’s recommendation and have continued Huntsville, Indianapolis, and Kansas City as separate locality pay areas for the 2003 locality payments. However, under therecommendations contained in this report, employees in these locations would receive the same locality rate as authorized in the RUS locality pay area.

Existing Areas of Application

As of 2001, there are seven approved “areas of application.” These locations are not formally a part of the metropolitan statistical area as defined by OMB that the Pay Agent has included in the area for locality pay purposes. The State of Rhode Island and a small portion of Bristol County, MA, are included in the Boston locality pay area; New London County, CT, is included in the Hartford locality pay area; Edwards Air Force Base and Santa Barbara County, CA, are included in the Los Angeles locality pay area; Monterey County, CA, is included in the San Francisco locality pay area; and St. Marys County, MD, is included in the Washington, DC-Baltimore locality pay area. With the exception of a small portion of Bristol County, MA, each of these locations passed the applicable area of application criteria proposed by the Council and approved by the Pay Agent at the time it was added to the locality pay area. The Pay Agent included a small portion of Bristol County, MA, in the Boston locality pay area at the same time it added Rhode Island to that area. It did so because adding Rhode Island otherwise would have resulted in leaving a small portion of Bristol County completely surrounded by the newly expanded Boston locality pay area.

New London County, CT, with 1,277 GS employees, and Santa Barbara County, CA, with 1,917 GS employees, no longer meet the criterion that counties have 2,000 or more GS employees. Edwards Air Force Base, with 919 GS employees, no longer meets the 1,000 employee criterion for installations crossing locality pay area boundaries.

The Council believes it is not prudent management or sound compensation policy to drop locations previously approved as areas of application precipitously while the Government is downsizing and experiencing pressure to exempt agencies from title 5, United States Code. The Council recommended that these areas continue to be included in their respective locality pay area at the very least until new census data are available and new metropolitan statistical areas are defined in 2003. We agree with the Council’s assessment.

Using Commercial Salary Surveys, BLS Surveys, or Both to Establish New Locality Pay Areas

Section 637 of the Treasury and General Government Appropriations Act, 2001, authorized the President’s Pay Agent to use salary survey data compiled by organizations or entities for private sector businesses, BLS surveys, or both, to set locality pay for Federal employees in up to five additional metropolitan areas in January 2002. The five metropolitan areas meeting the criteria in Section 637 (those not previously surveyed for locality pay purposes that have the highest levels of non-farm employment and at least 2,500 GS employees) are Las Vegas, Nevada; Nashville, Tennessee; Raleigh, North Carolina; Austin, Texas; and Louisville, Kentucky. Section 637 required the Pay Agent to submit a report to Congress summarizing our findings.

Our report to Congress (dated November 29, 2001) concluded that no currently available commercial salary survey data are accurate and complete enough to establish locality pay rates for these five areas. Commercial salary surveys are not designed to yield data that represent jobs and pay levels for all employers in a given locality. In addition, commercial salary surveys use job definitions that cannot be matched to levels of work under the General Schedule with sufficient precision to enable us to feel confident about calculating the disparity between Federal and non-Federal pay in any of the metropolitan areas under consideration. The Federal Employees Pay Comparability Act of 1990 requires that we compare GS pay to rates generally paid for the “same levels of work” in the non-Federal sector. Off-the-shelf commercial salary surveys do not provide a suitable foundation for making these comparisons.

While private sector firms routinely use commercial salary surveys as a guide to setting pay, these firms also routinely consider other relevant factors (including ability to pay, turnover rates, and the unemployment rate) and may exercise significant judgment and discretion in determining pay increases based on their interpretation of commercial salary survey data. Private sector pay rates typically are not derived from a formula-driven process.

In response to the mandate in Section 637, we also evaluated the possibility of using data from BLS’ NCS program for the purpose of establishing new locality pay areas. Our report concluded, however, that NCS data are not yet ready to be used to set locality pay rates. The Pay Agent agreed with the Federal Salary Council in 1999 on the kinds of improvements needed in the NCS methodology and again in 2000 on the details of a plan for making these improvements. While Pay Agent staff have made significant progress toward improving the NCS salary survey methodology, the surveys available for use at this time do not reflect any of these improvements.

As part of its ongoing data collection for the Rest of U.S. (RUS) locality pay area, BLS conducts small-scale surveys in three of the five metropolitan areas under consideration (Raleigh, Austin, and Louisville). Because of the small sample sizes used in these areas, small-scale surveys cannot be expected to produce stable survey data suitable for calculating an overall pay disparity for an entire metropolitan area. Consequently, although we seriously considered the Federal Salary Council’s recommendation that we use data from small-scale NCS surveys to establish new locality pay areas in Austin, and Louisville and Raleigh, we have concluded that such use would be both premature and misleading.

Requests for New Areas

At its working group meetings of June 22 and October 12 and its public meetings of July 23 and October 22, 2001, the Council reviewed requests for special consideration from 49 additional areas. Employees in several of these areas had asked for their area to become a separate locality pay area. As noted elsewhere in this report, BLS’ current surveys are not yet suitable for use
in setting locality pay. Accordingly, we cannot add any new areas at this time.

None of the other areas requesting special consideration pass the existing area-of-application criteria shown below:

A. County-wide Areas of Application. To be included in the locality pay area, the affected county must—

1. Currently be included in the Rest of U.S. locality pay area and be contiguous to a locality pay area (exclusive of any other areas of application).

2. Contain at least 2,000 GS employees.

3. Have a significant level of urbanization, based on 1990 Census data. A “significant level of urbanization” is defined as a population density of more than 200 persons per square mile or at least 80 percent of the population in urbanized areas.

4. Demonstrate some economic linkage with the locality pay area, defined as commuting at a level of 5 percent or more into or from the county under consideration and the central core of the metropolitan area as identified by the Census Bureau.

B. Partial-county Areas of Application in New England. To be included in the locality pay area, the partial county must—

1. Currently be included in the Rest of U.S. locality pay area and be contiguous to the locality pay area (exclusive of any other areas of application).

2. Contain at least 2,000 GS employees.

In addition—

3. The entire county must have a population density of more than 200 persons per square mile or at least 80 percent of the population in urbanized areas.

4. The entire county must demonstrate some economic linkage with the pay locality, defined as commuting at a level of 5 percent or more into or from the county under consideration and the central core of the metropolitan area as identified by the Census Bureau.

C. Federal Facilities Crossing Locality Pay Area Boundaries. To be included in the locality pay area, the portion of a Federal facility which crosses locality pay area boundaries and which is not in the locality pay area must—

1. Contain at least 1,000 GS employees.

2. Have the duty stations of the majority of GS employees within 10 miles of the locality.

3. Have a significant number of its employees commuting from the locality pay area.

D. Full State Areas of Application. In order to be evaluated for area of application status, an entire State may be considered as one county for purposes of applying the County-wide Area of Application Criteria if—

1. No part of the State is already included in a separate metropolitan locality pay area.
.
2. The State is adjacent to the locality pay area (exclusive any other areas of application).

3. The State is smaller than 115 percent of the average county size in square miles in the lower 48 States plus Washington, DC, as determined by the Office of Personnel Management using land area data published by the Census Bureau, and the number of counties in the United States as determined by the Census Bureau. After application of the above criteria, the entire State must still pass the County-wide Area of Application Criteria before it can become an area of application.

In its recommendations, the Council reiterated its conclusion made in 2000 that since new population and commuting pattern data and new metropolitan area definitions will become available over the next several years, it would be disruptive to Federal employees and agencies to recommend any further modifications of locality pay areas at this time. The Council also recommended that the Pay Agent should continue to monitor areas and make minor adjustments if a particularly egregious situation justifies such action.

We are impressed by the Council’s diligence and agree with the Council’s reassessment that it would be premature and disruptive to make further modifications in locality pay area boundaries until new census data and metropolitan area definitions are available for review.

Accordingly, we approve continuation of the following areas of application for 2003 in the following Metropolitan Statistical Areas (MSAs) and Consolidated Metropolitan Statistical Areas (CMSAs):

Area of Application	Locality Pay Area
Bristol County, MA	Boston CMSA
Edwards Air Force Base, CA	Los Angeles CMSA
Monterey County, CA	San Francisco CMSA
New London County, CT	Hartford MSA
Santa Barbara County, CA	Los Angeles CMSA
State of Rhode Island	Boston CMSA
St. Mary's County, MD	Washington, DC CMSA

Metropolitan Statistical Areas

The metropolitan portions of locality pay areas currently are linked to Metropolitan Statistical Areas, as defined and published by OMB. If OMB modifies an MSA boundary, the boundary of the affected locality pay area changes automatically.

OMB and the Census Bureau have announced plans to make changes in the way metropolitan areas are defined. Beginning in 2003, metropolitan areas will be redefined using new criteria and 2000 census data. The Council recommended in 2000 that the Pay Agent should not follow the new metropolitan area definitions until it has had an opportunity to assess their impact on the locality pay program.

The Pay Agent agreed with this recommendation last year, and we plan to publish a proposal in the Federal Register soon to address this issue.

Locality Pay Areas for 2003

The Pay Agent will continue the following 32 areas as locality pay areas in 2003:

Atlanta MSA

Boston CMSA +

Chicago CMSA

Cincinnati CMSA

Cleveland CMSA

Columbus, OH MSA

Dallas CMSA

Dayton MSA

Denver CMSA

Detroit CMSA

Hartford MSA +

Houston CMSA

Houston MSA

Huntsville MSA

Indianapolis MSA

Kansas City MSA

Los Angeles CMSA +

Miami CMSA

Milwaukee CMSA

Minneapolis CMSA

New York CMSA

Orlando MSA

Pittsburgh MSA

Portland CMSA

Rest of U.S. 

Richmond MSA

Sacramento MSA

San Diego MSA

San Francisco CMSA +

Seattle CMSA

St. Louis MSA

Washington, DC CMSA +

 

The symbol “+” indicates one or more areas of application.


COMPARING GENERAL SCHEDULE AND NON-FEDERAL PAY

How Local Pay Disparities Are Measured

Locality-based comparability payments are a function of local disparities between Federal and non-Federal pay. Pay disparities are measured for each locality pay area by comparing the annual scheduled rates of basic pay of workers paid under the General Schedule (GS) pay plan in an area to the annual rates generally paid to non-Federal workers for the same levels of work in the same area. (The annual scheduled rate of basic pay is the General Schedule rate of basic pay for the employee's grade and step (or relative position in the rate range), inclusive of a special rate under section 403 of FEPCA, but exclusive of a special rate under 5 U.S.C. 5305, a special law enforcement adjusted rate under subpart C of 5 CFR part 531, and a locality rate under subpart F of 5 CFR part 531.)  Non-Federal pay is represented by a survey of 115 jobs distributed over 26 occupations (as listed in Table 1). Each of the 115 surveyed jobs has been equated to a GS occupational definition and grade level and classified among 5 broad “PATCO” categories—professional (P), administrative (A), technical (T), clerical (C), and protective officer (O). (See Appendix IV for details.)

Non-Federal rates are estimated on a sample basis by BLS area surveys. The rate for each non-Federal job is an estimate of the mean straight-time earnings of full-time non-Federal workers in the job, based on the BLS survey sample. GS rates are determined from Federal personnel records for the relevant populations of GS workers. Each GS rate is the mean scheduled annual rate of all full-time permanent year-round GS workers in the relevant group.

The reference dates of the BLS surveys vary over the cycle of non-Federal salary surveys conducted for the GS locality pay program. To ensure that local pay disparities are measured as of one common date, it is necessary to “age” the BLS survey data to a common reference date before comparing it to GS pay data of the same date. March 2001 is the common reference and comparison date used in this report. The Employment Cost Index (ECI) based on wages and salaries for white-collar civilian workers, excluding those in sales, was used to age the BLS data.

Since 5 U.S.C. 5302(6) requires that each local pay disparity be expressed as a single percentage, the comparison of GS and non-Federal rates of pay in a locality requires that the two sets of rates be reduced to one pair of rates, a GS average and a non-Federal average. An important principle in averaging each set of rates is that the rates of individual survey jobs and job categories are weighted by Federal GS employment in equivalent classifications. Weighting by Federal employment ensures that the influence of each non-Federal survey job on the overall non-Federal average is proportionate to the frequency of that job in the Federal sector.

Table 2.  Number of Survey Jobs by Grade and PATCO Category

 

Grade	P	A	T	C	O	Total
GS-1				1		1
GS-2				3		3
GS-3			3	5		8
GS-4			4	5		9
GS-5	4	4	4	4	2	18
GS-6			2	1	1	4
GS-7	5	4	4	1	1	15
GS-8			1	1		2
GS-9	6	5	2			13
GS-10	6	5	2			13
GS-11	5	5				10
GS-12	4	4				8
GS-13	3	3