Introduction

On October 6, 2014, the U.S. Office of Personnel Management’s (OPM) Agency Compliance and Evaluation (ACE) Atlanta office accepted a classification appeal from Ms. Alice F. Love.  The appellant’s position is currently classified as Natural Resources Specialist, GS-401-11 (organizational title Agricultural Outreach Liaison), and is located in the Communications, Marketing and Outreach (CMO) Staff, Alabama State Conservation Office, Natural Resources Conservation Service (NRCS), U.S. Department of Agriculture (USDA), in Auburn, Alabama.  The appellant believes her position should be classified at the GS-12 grade level.  On November 5, 2014, we received the agency administrative report (AAR).  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background

In February 2010, the appellant and her then immediate supervisor submitted a desk audit request to the NRCS servicing human resources office to review her position, which was then classified as Soil Conservationist, GS-457-11.  A desk audit was completed by a private contractor resulting in no change in classification.  In June 2010, the appellant appealed the result of the desk audit to the NRCS headquarters Human Resources Management Division (HRMD) because she did not believe the evaluation considered her “skills in successfully working with various conservation partners to increase USDA underserved participation” or her “expertise in the arena of outreach and liaison duties.”  HRMD issued a decision dated April 25, 2011, changing the classification of the appellant’s position to Natural Resources Specialist, GS-401-11.  Still in disagreement with the classification of her position, sometime in July or August 2011 the appellant filed a classification appeal with the USDA.  In December 2012, HRMD forwarded information requested by the USDA, Office of Human Resources Management, needed to adjudicate the appeal.  The USDA issued a decision dated July 2, 2014, sustaining the classification of the appellant’s position.  The appellant subsequently filed a classification appeal with OPM. 

General Issues

The appellant makes various statements about her agency’s evaluation of her position.  By law, we must make our decision solely by comparing the appellant’s current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position.  Because our decision sets aside any previous agency decisions, the appellant’s statements regarding the classification practices used by her agency to classify her position are not germane to the classification appeal process. 

The appellant also asserts that the “evaluation materials interpreted and used by prior auditors/classifiers” are outdated because they do not address “administering an outreach program addressing today’s environmental concerns and challenges of the historically underserved and general public.” (The agency used the Job Family Standard (JFS) for Professional Work in the Natural Resources Management and Biological Sciences Group, GS-400, dated September 2005, to grade the appellant’s position.)  However, the adequacy of grade-level criteria in OPM PCSs is not appealable (5 CFR 511.607).  All OPM General Schedule PCSs are consistent with the grade level definitions of work established by law.  These definitions are based on the difficulty and responsibility of the work at each level and the qualifications required to do that work.  Although all occupations change over time, the fundamental duty and responsibility patterns and qualifications required in an occupation normally remain stable.  Regardless, as is discussed in the below series determination section, the appellant’s outreach and liaison duties are more appropriately addressed within the context of another occupational series rather than the GS-400 JFS.

A position is the duties and responsibilities that make up the work performed by the employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position, and not simply a position description (PD).  This decision is based on the work currently assigned and performed by the appellant. 

Contrary to what is stated in the appellant’s PD, the appellant was not supervised by the NRCS Director of Communications, Marketing and Outreach, but rather by a Public Affairs Specialist, GS-1035-12, who retired during the adjudication of this appeal.  The appellant and her former supervisor certified to the accuracy of the appellant’s PD (# 90492843) of record.  The appellant’s current supervisor is the State Conservationist, GS-401-15 (who formerly was the appellant’s second-level supervisor).  A request for an interview with the former supervisor was made; however, the supervisor declined to participate in the appeal fact-finding process. 

Our review disclosed the appellant’s PD is not completely accurate.  The PD describes duties which overstate the level of expertise required and actually exercised by the appellant.  Specifically, under Factor 1, Knowledge Required by the Position, the appellant’s work does not require “knowledge of agronomy, soil science, forestry, biology, hydrology, and practical engineering techniques sufficient to provide expertise to socially disadvantaged farmers and ranchers.”  Rather, her work requires knowledge of agency programs and the associated processes, methods and principles to convey the benefits, services, or requirements of such programs to prospective audiences.  Also, under Factor 4, Complexity, the PD indicates “the work requires making decisions concerning a variety of natural resource duties relating to interdependent resource and socioeconomic issues.”  Although the appellant functions as a staff resource on NRCS programs, she is not vested with the authority to represent or commit USDA or any of its components on program decisions (e.g., approve grants).  Instead, she plans and carries out activities to meet defined NRCS program policies and goals.

With regard to the accuracy of the appellant’s PD, her current supervisor indicated he did not know whether the appellant performed certain duties stated in the PD.  For instance, in regard to duty #6, he indicated he did not know if the appellant served on departmental and university- wide committees and provided expert guidance on soil and water conservation to faculty, staff, and students.  Regarding duty #7, he indicated he is not aware of the appellant having conducted soil and water conservation seminars and workshops herself.  Our fact-finding disclosed the appellant organizes informational workshops with subject matter experts targeting the underserved to educate them in technically sound conservation practices offered by NRCS.  However, she does not conduct subject matter seminars or provide expert guidance on topics in soil and water conservation herself.  These seminars are conducted by subject matter experts with whom she partners to increase participation of the underserved in NRCS programs.  Therefore, the appellant’s PD of record 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.  

Position information

The mission of the NRCS outreach program is to provide leadership to ensure that its programs and services are made accessible to all NRCS customers, fairly and equitably, with emphasis on reaching the "underserved."  The CMO office is responsible for developing, coordinating, and carrying out a public information program to communicate agency policies, programs and services throughout the state of Alabama.

As part of the CMO staff, the appellant is responsible for conducting small farm outreach activities to increase participation in programs (i.e., Farm Bill conservation programs) and benefits administered by the NRCS to underserved and non-traditional customers such as small- scale and minority farmers within 13 counties in south and central Alabama.  She carries out outreach activities by attending small farm conferences and making presentations or conducting other meetings with audiences such as Community Based Organization leaders and new farmers and ranchers.  For technical program information, she refers her contacts to the appropriate USDA technical and program specialist.  Further, the appellant promotes program outreach through newsletter articles, success stories, and informational flyers. 

The appellant also serves as a liaison between the College of Agricultural, Environment, and Natural Science at Tuskegee University (TU) in the area of student recruitment and placement, and to coordinate programs of mutual interest between the university, NRCS and other USDA components.  For example, she plans and carries out activities to meet defined USDA 1890 Scholars Program goals and objectives; i.e., increase the number of minorities studying agriculture, food, natural resources sciences or other related disciplines.  She does this by engaging in student recruitment and mentoring selectees who attend TU.  

Further, the appellant serves as technical liaison for cooperative agreements with conservation partners in delivery of program and services.  She ensures all designated cooperative agreements are implemented as outlined and makes recommendations to her supervisor for payment. 

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

Series, title, and standard determination

The agency has placed the appellant’s position in the General Natural Resources Management and Biological Sciences Series, GS-401, titled it Natural Resources Specialist, and evaluated it by application of the GS-400 JFS.  The appellant does not dispute these determinations.  

The GS-401 series covers positions that manage, supervise, lead, or perform professional research or scientific work in biology, agriculture, or natural resources management that is not classifiable to another more specific professional series in the Natural Resources Management and Biological Sciences Group, 0400.  Work within this series involves professional work in more than one series, or work not covered by a specific series, in the 0400 group.  The natural resources that are most relevant to the 0400 JFS are water, land, food, plants, animals, and soils.  Natural resources work may involve administrative or managerial duties, such as controlling, preserving, and/or evaluating a natural resource or natural resources function, such as conservation, forest, rangeland, fisheries, and wildlife.  The work may have specific geographic boundaries (for example, management of a national wildlife refuge).  The natural resources management work covered by this JFS requires knowledge and skill sufficient to interpret and apply biological science and research.

Our fact-finding does not support placement of the appellant’s position in the GS-401 series.  The record shows the reason for the position’s existence is to function as a staff resource to people in USDA organizations and programs by providing information on NRCS programs to underserved communities (e.g., minority and small farmers), assist in recruiting students for USDA and related educational programs (e.g., 1890 Scholars Program), and assess the degree of understanding or interest the public has in these programs.  The paramount knowledge required by the position is a practical understanding and knowledge of NRCS functional programs to facilitate communication between the agency and its publics on program-related problems, activities, or issues.  Much of this program knowledge is obtained from specialists in NRCS functional program areas or through review of agency-developed materials.  Thus, the work assigned to and performed by the appellant does not require knowledge of biological science and natural resources to provide expert advice to prospective clients or the application of such knowledge to interpret and apply biological science and research as covered by the GS-401 series.  As indicated by the appellant’s supervisor, an employee in the appellant’s position would require some degree of program knowledge which could be gained from job experience, and the employee could confer with appropriate subject matter experts for specific guidance.  Thus, recruitment sources as described by the appellant’s supervisor would include individuals who possess oral, written communication, and interpersonal skills.  For instance, the appellant is not required to explain the science that underpins the Farm Bill, but rather how to become eligible to participate in NRCS programs.  The supervisor stated the appellant is not engaged in technical farm planning issues.  Rather, the appellant refers farmers to the appropriate technical specialist; e.g., a wetland specialist who can advise on how to restore a wetland. 

Although the appellant’s work does not require education in a specialized scientific field, it does involve application of a number of critical skills; e.g., analytical, research, writing and judgment typical of two-grade interval administrative work.  These duties are closely related to and properly evaluated by application of the Public Affairs Series, GS-1035, PCS.  This PCS contains criteria for evaluating work involved in establishing and maintaining mutual communication between Federal agencies and pertinent publics and carrying out communication requirements inherent in disseminating policy decisions.  The work covers identifying communication needs and developing informational materials that inform appropriate publics of the agency’s policies, programs, and services.  Also, it requires planning, executing, and evaluating the effectiveness of information and communication programs in furthering agency goals.  These functions track the nature of the work performed by the appellant and represent the primary and paramount purpose of her position.  Thus, the appellant’s position is properly placed in the GS-1035 series and titled Public Affairs Specialist, which is the basic title authorized for all nonsupervisory positions in this series.

Grade determination

The GS-1035 PCS is written in the Factor Evaluation System (FES) format.  Under the FES, positions are evaluated by comparing the duties, responsibilities, and qualifications required with nine factors common to nonsupervisory General Schedule positions.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  If a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level unless an equally important aspect that meets a higher level balances the deficiency.  Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.  The total points assigned for the nine factors are converted to a grade by reference to the grade conversion table in the PCS.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or facts which the public affairs specialist must understand to do acceptable work and the nature and extent of the skills necessary to apply that knowledge.

At Level 1-7, the employee applies knowledge applicable to a wide range of duties involving oral and written communication principles, practices, techniques and methods; analytical methods; and interpersonal relations practices.  At this level, the employee uses skill in applying such knowledge in the modification of standard methods and adaptation of approaches in developing new information materials aimed at enhancing the understanding of groups or individuals of the significant issues of an agency's program.  The employee uses knowledge applicable to and skill in assessing public reaction and identifying extent of understanding achieved to evaluate the effectiveness of information programs.  At this level, the employee also applies knowledge and skill to explain significant issues to generally responsive groups or individuals interested in the agency's programs.

At Level 1-8, the employee applies a mastery of communication principles, methods, practices and techniques, analytical methods and interpersonal relations practices.  The employee uses skill in applying such mastery in developing and applying new approaches to the most difficult and complex public affairs problems of an agency by developing or evaluating information programs enhancing understanding among publics opposed or indifferent to agency programs.  At this level, the employee also applies knowledge and skill to analyze public reaction to agency programs and policies in developing recommendations that significantly modify an agency's major programs or policies; and integrating diverse points of view in a communication plan in establishing and maintaining mutual understanding with various agency publics.

The appellant’s position meets Level 1-7.  Like this level, the appellant performs a wide range of outreach duties to various audiences applying oral and written communication principles, practices, techniques and methods; analytical methods; and interpersonal relations practices, e.g., when she provides farmers with program information, such as eligibility requirements contained in the Farm Bill.  Similar to this level, the work requires skill in modifying standard methods and adapting approaches in conveying information aimed at enhancing the understanding of groups or individuals of the significant issues of NRCS programs.  For instance, a farm and tract number issued by the Farm Service Agency (FSA) is needed to apply for conservation programs offered by the NRCS.  The appellant developed a standard operating procedure with easy-to-understand instructions on how to apply for a farm and tract number and the documentation needed to facilitate the application process for conservation programs offered by the NRCS.

Comparable to Level 1-7, the appellant assesses public reaction and identifies the extent of understanding achieved to evaluate the effectiveness of her outreach program efforts.  For example, she identifies wording in program guidelines that may be a barrier to the understanding of specific groups and recommends changes to program staff.   Like this level, the work requires knowledge and skill sufficient to explain significant issues to generally responsive groups and individuals interested in USDA/NRCS programs; e.g., potential students who may be willing to work full time for the USDA upon graduation and beginning or socially disadvantaged farmers.  Further, like this level, the appellant is responsible for developing informational materials that increase communication with her various audiences.  For example, she writes success stories about farmers who have been identified as belonging to an underserved group and who qualified for financial assistance through an NRCS program which are published in the Alabama NRCS website newsroom section.  She also writes articles that are published in the NRCS- Alabama Current Developments Newsletter (under outreach news) such as one titled, “Outreach News from Alice Love,” in which she has presented such topics as how partnerships help prepare the next generation of conservationists, outlining outreach activities in which she is engaged and their outcomes.  Similar to this level, her work also requires knowledge and skill sufficient to conduct workshops, seminars and other meetings with nonprofit organizations, schools and landowners to stimulate interest in USDA/NRCS programs.  Illustrative of such work is the appellant’s outreach to landowners and small farm organizations to enhance their knowledge of USDA programs, explain program requirements, and refer them to appropriate USDA component staff members.  Also like this level, the appellant provides representatives of associations and societies with timely and accurate explanations of agency policies and regulations, and shares small farmer and other group concerns about program issues with her supervisor and/or program staff. 

The appellant’s position does not meet Level 1-8.  Unlike this level, the appellant’s outreach efforts are not inherently controversial and do not normally generate negative publicity.  Also unlike this level, she does not regularly make on-the-spot presentations to audiences with opposing points of view or erroneous understanding of agency positions to achieve a more balanced perspective among these publics.  Her work does not require her to establish and maintain effective working relationships with individuals having opposing points of view and conflicting interests to explain a position while not criticizing other views.  Instead, the appellant deals with audiences who are interested in receiving information about and/or using USDA/NRCS programs and resources; e.g., potential applicants for 1890 scholarships and small farmers looking for financial assistance through NRCS programs.  Her audiences at small farm groups and conferences, community and other organizations are receptive to the programs and benefits that she discusses. 

This factor is evaluated at Level 1-7 and 1, 250 points are assigned.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

At Level 2-4, the supervisor determines the overall objectives and resources available for the employee's assignment.   However, specific activities may stem from the employee's contacts with program managers, although final clearance of such requests are approved by the supervisor. The employee and supervisor jointly develop deadlines, projects and the nature of the planned assignments.  The employee is responsible for planning and carrying out the project or assignment including resolving most problems, coordinating the work with others, interpreting policy in terms of established objectives, determining approach to be taken, and the methods and techniques to be employed.  The employee keeps the supervisor informed of progress, potential controversies, or wide-ranging implications.  Completed work is reviewed in terms of satisfying expected results of projects or assignments, responsiveness, and conformance with agency policy.  Completed work may also be subject to clearance procedures from higher levels in the agency.

At Level 2-5, the supervisor provides administrative direction to the employee by making assignments in terms of the broadly defined mission or function of the organization's public affairs program.  The employee is responsible for independently planning, designing, and carrying out public affairs programs, campaigns, projects, studies or other major program functions, informing the supervisor of progress as appropriate.  Results achieved are considered technically authoritative and are normally accepted without significant change.  Work involving particularly sensitive or controversial issues may be reviewed by public affairs officials at headquarters levels.  If the work is reviewed, the review concerns such matters as fulfillment of program objectives or the effect of the employee's advice in facilitating achievement of the functional program's objectives.  Recommendations for new projects and shifts in public affairs program objectives are evaluated in terms of resources available, program goals, or agency-wide priorities.

The appellant’s position meets Level 2-4.  Like this level, the appellant works within a program framework and outreach activities may stem from her contacts, such as those flowing from her TU USDA1890 program liaison responsibilities.  Comparable to this level, she is responsible for planning and carrying out the project or assignment including resolving most problems, coordinating the work with others, interpreting policy in terms of established objectives, and determining the approach to be taken and the methods and techniques to be employed.  Although the appellant's supervisor does not provide technical guidance to the appellant, he is responsible for determining whether her performance meets defined goals and is responsible for accepting or rejecting her work.  This includes determining how well her outreach efforts are meeting defined management needs.  Comparable to Level 2-4, the appellant’s completed work is reviewed in terms of satisfying expected results of projects or assignments, responsiveness, and conformance with agency policy.  Also like this level, she keeps her supervisor informed of progress, potential controversies, or wide-ranging implications; e.g., when discussing with her supervisor the implications of the Pathways Program and its potential impact on the 1890 Scholars Program.

The appellant’s position does not meet Level 2-5.  Decisions made by employees under administrative direction at Level 2-5 are generally afforded the full weight of agency policy once they are implemented.  In contrast, the appellant implements the policies, priorities, and procedures directed by the NRCS program framework.  Unlike this level, the appellant is not responsible for designing the plans and strategies by which broad projects will be undertaken, including campaigns, projects, studies, or other major program functions.  This work is performed at higher levels in the agency.  Unlike review for such broad considerations as impact on the overall program and achieving the functional program’s objectives, the appellant’s work receives review for feasibility of approach so as to meet defined program objectives and priorities.  Unlike Level 2-5, the appellant is not delegated responsibility for major programs; e.g., developing new or substantially revised outreach programs, like the 1890 Scholars Program, including the allocation of staff and monetary resources.  The appellant does not direct or control a staff or other resources integral to the broad program managed at Level 2-5.  Instead, she implements initiatives and continuing functions at the operating level to achieve outreach objectives and priorities determined at higher levels of the organization.  Also unlike Level 2-5, the appellant is not responsible for dealing with particularly sensitive or controversial issues.  Rather, officials at NRCS headquarter offices which have lead responsibility for small farms outreach and for the other programs supported by the appellant retain authority for dealing with any controversial or sensitive program issues, shifting program directions or objectives, and planning changes in program direction as found at Level 2-5. 

This factor is evaluated at Level 2-4 and 450 points are assigned 

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment needed to apply them. 

At Level 3-3, guidelines include operating instructions, public affairs manuals, agency or local policies and regulations.  Standard agency public affairs practices and precedents are readily available and generally applicable to situations encountered, although some gaps exist in specific areas.  For routine work situations, the employee independently selects, interprets and applies the guides, modifying and adapting them to suit specific situations not directly covered by the guidelines.  In addition, the employee is typically beginning to interpret and apply guidelines and precedents in some unusual situations without assistance from others.

At Level 3-4, guidelines consist of policy statements or broad precedents and are applicable to establishing general program direction or setting tone, but are not totally sufficient for dealing specifically with the more complex, intricate or unusual situations, issues or problems encountered on a recurring basis.  The employee is required to deviate from standard approaches in developing new ways to communicate the agency’s message on controversial and sensitive issues where public reaction has been negative or indifferent and the understanding of agency publics is essential to the agency mission.

The appellant’s position meets Level 3-3.  Like this level, guidelines available and regularly used by the appellant consist of policies, regulations, State and local directives, reference manuals such as the NRCS General Manual, university handbooks (i.e., human resource section) and supplemental instructions developed by the USDA and its components (e.g., Farm Bill Guide Sheets).  These guidelines are generally applicable to situations encountered and cover the program represented to the public; e.g., the 1890 Scholars application process and NRCS program procedures on applying for financial assistance.  Comparable to this level, although the appellant uses established outreach methodologies when visiting minority landowners, interest group organizations, and career fairs to reach targeted USDA audiences, she must analyze situations or gaps in the specificity of guidelines to develop methods and procedures effective in communicating with her audiences which conform to the intent of the guidelines and meet program objectives.  Similar to Level 3-3, she is responsible for determining when to seek additional guidance from her supervisor or subject matter experts regarding specific program criteria. 

The appellant’s position does not meet Level 3-4.  Unlike this level, she is not responsible for applying agency policy statements or broad precedents in establishing general program direction or in setting a tone for dealing with more complex, intricate or unusual situations, issues or problems for which such guidelines are not totally sufficient.  Officials at higher levels in the organization are responsible for interpreting USDA policy statements and their impact on the public affairs program as it relates to the appellant’s assigned programs and dealing with such unusual, intricate, and similarly demanding issues.  While the appellant must tailor her responses depending on the degree of knowledge of her audience, some of whom may be uninformed about NRCS programs and/or misunderstand their purposes, her work does not involve having to routinely respond to controversial and sensitive issues where audiences are hostile or indifferent as found at Level 3-4. 

This factor is evaluated at Level 3-3 and 275 points are assigned.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work. 

At Level 4-4, work requires the application of advanced communication and analytical practices, methods and techniques to solve complex public affairs problems such as developing and presenting informational material to achieve understanding of various points of view or concepts from publics with varying levels of understanding and different interests and perspectives on the subjects; employing a number of information gathering techniques in collecting and analyzing public reaction to information programs; and developing recommendations for management in improving the agency's communication with the general public and specialized groups.  Decisions regarding what needs to be done are based upon an analysis of the need for modifying standard communication practices and approaches such as analyzing reaction to information programs from a variety of groups having different interests and goals from the agency; and determining the feasibility of using various information gathering techniques in obtaining reaction from agency publics and evaluating the effect of various information program approaches to the development of communication interchanges with agency publics.  The work requires making decisions on which oral and written communication methods and approaches to employ in presenting and explaining programs and policies in a logical and clarifying manner, in a structured setting, in achieving understanding from the agency's publics, some with differing interests, on the programs or policies advocated by the agency.

At Level 4-5, the work includes the development of new methods, strategies and communication plans covering the complete spectrum of the organization's programs.  This involves presenting information on a wide variety of subjects using the full array of written and oral presentation formats and techniques; establishing and maintaining effective working relationships in achieving understanding with groups indifferent to or having opposing points of view to programs and policies; and developing, from an analysis of varied and conflicting reaction from the agency's publics, recommendations on the formulation and articulation of agency policy in communicating agency programs more effectively.  Decisions regarding what needs to be done include evaluating the appropriateness of existing strategies and plans in light of changes in program emphasis or content, including statutory or technological changes, and shifts in public reaction to or understanding of the programs. The work requires developing new ways of gathering input from a variety of individuals and groups with conflicting views and interests, and developing and initiating varied approaches and strategies in communicating the agency's objectives to groups opposed or indifferent to agency programs.

The appellant’s position meets Level 4-4.  Like this level, the appellant applies advanced communication and analytical practices, methods and techniques to explain NRCS program criteria and requirements to underserved and minority groups with varying levels of knowledge and understanding and different interests in conservation and USDA supported educational programs.  Typical of Level 4-4, she uses information gathering techniques in collecting and analyzing public reaction to NRCS programs and develops recommendations for management in improving the agency's communication with targeted groups.  For example, she shares issues and concerns uncovered at small farm conferences with management and requests participation of technical experts in areas such as forestry and vegetation production to promote NRCS programs from different perspectives.  Comparable to this level, she makes decisions on which oral and written communication methods and approaches to employ when she discusses program eligibility requirements to ensure she presents and explains this information in a logical and clear manner in order to achieve understanding of and develop audience interest in NRCS program opportunities, which is vital to achieving program outreach goals.

The appellant’s position does not meet Level 4-5.  Unlike this level, the appellant’s activities do not require her to develop new methods, strategies and communication plans covering the complete spectrum of the organization's programs.  Rather, these outreach planning and development functions are vested in higher levels of the agency.  For example, the USDA Office of Outreach and Advocacy (OAO) has overall USDA responsibility for programs available to small farmers.  It is the OAO that develops and implements plans for outreach activities and services provided by USDA by working collaboratively with the district offices, continually assessing the effectiveness of those outreach programs.  Unlike Level 4-5, the appellant’s outreach is not routinely to groups opposed or indifferent to agency programs, as discussed previously.  This responsibility is vested in program or policy analysts at higher levels in her organization. 

This factor is evaluated at Level 4-4 and 225 points are assigned.

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work (i.e., the purpose, breadth, and depth of the assignment) and the effect of work products or services both within and outside the organization.  Only the effect of properly performed work is considered. 

At Level 5-3, the work involves performing duties of a recurring nature in dealing with precedented public affairs matters such as responding to media questions on standard agency policies, explaining the benefits of program-developed research to interested groups, or developing parts of a communication plan for an organization.  The work affects the development or operation of the organization's communication plan or impacts the social or economic well-being of individuals served or affected by agency programs or policies.

At Level 5-4, the purpose of the work is the development of complete communication plans for an organization and provision to program officials of advisory, planning, and technical services in designing approaches resolving public affairs problems in various program areas.  The work contributes to the achievement of program objectives by clarifying the issues and alternatives facing agency managers in achieving a meaningful communication between the agency and the various publics affected by its programs or policies.

The appellant’s position meets Level 5-3.  Comparable to this level, her work involves dealing with precedented outreach matters on behalf of NRCS, such as engaging with its conservation partners to explain the benefits of program-developed research to underserved landowners interested in technical and financial assistance programs.  Like this level, her work affects the economic well-being of individuals served by agency programs and policies and the operation of 1890 program objectives. 

The appellant’s position does not meet Level 5-4.  Unlike this level, the appellant is not responsible for designing approaches resolving public affairs problems in various program areas.  Rather, she implements OAO and other approaches developed and authorized by higher level USDA and similar higher level USDA officials and components.  In addition, unlike this level, her work does not require her to clarify issues and alternatives faced by agency managers in achieving a meaningful communication between the agency and the various publics affected by its programs.  Rather, these responsibilities and the development of complete communications plans for the appellant’s organization rest with individuals at higher echelons within the agency.

This factor is evaluated at Level 5-3 and 150 points are assigned.

Factor 6, Personal contacts

This factor includes face-to-face contacts and telephone and radio dialogue with persons not in the supervisory chain.  Levels of this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place (e.g., the degree to which the employee and those contacted recognize their relative roles and authorities).

At Level 6-3, personal contacts are with specialized groups or individuals from outside the employing agency where the contact is not routinely established, the purpose of each contact is different, and the roles of the employee and the other person are established during the contact.  Typical of such contacts are representatives of the news media, organized groups desiring to provide input to agency decisions, or professional or trade organizations affected by agency programs. 

At Level 6-4, personal contacts are with nationally or internationally known groups or individuals from outside the employing agency where the contact is not routinely or easily established and each contact is conducted for different reasons and under different circumstances.  Typical of these contacts are meetings with nationally known members of the news media, national leaders of civic or trade organizations having an interest in or affected by agency policies or programs, State governors, mayors of large cities, or high-level county or regional governmental officials.

The appellant’s work meets Level 6-3.  Like this level, her initial contacts are with groups outside the NRCS; e.g., landowners, farmers, schools, community-based organizations, and college and university officials, and require that each party establish their respective roles during the contact.  For example, the appellant may contact groups to provide general briefings or to recruit for specific positions and/or employment programs.  Most of her contacts are with staff members typical of Level 6-3.  Similar to Level 6-3, contacts with higher-level officials are relatively easy to establish; e.g., contacts during conferences and meetings structured to cover program issues and initiatives.  

The appellant’s work does not meet Level 6-4.  While the appellant may meet with some officials typical of Level 6-4; e.g., regional and national chapter representatives of Minorities in Agriculture, Natural Resources and Related Sciences (MANRRS), unlike Level 6-4, these contacts are easily established for the purpose of having NRCS participate in scheduled career fairs and training conferences hosted by MANRRS.  Further, such contacts do not occur with sufficient regularity to control the evaluation of this factor.

This factor is evaluated at Level 6-3 and 60 points are assigned.

Factor 7, Purpose of contacts

This factor covers the purpose of personal contacts, which may range from factual exchange of information to situations involving significant or controversial issues and differing viewpoints or objectives.

At Level 7-3, the purpose of contacts is to analyze, develop and present alternative approaches in developing communication strategies for misunderstood agency policies or programs; or present clarifications of agency activities or policies to specialized groups, the general population, industrial organizations, representatives of the news media, or individuals.

At Level 7-4, the purpose of contacts is to explain, relate and defend significant or controversial agency actions or decisions affecting the basic principles of the agency's program; or to negotiate or mediate among groups or individuals with divergent viewpoints concerning recommendations to alter programs in reaching a consensus; or to convince agency program managers to change or modify decisions involving significant or controversial issues to avoid public misunderstanding of agency programs or policies.

The appellant’s position meets Level 7-3.  Like at this level, the purpose of her contacts is to clarify agency activities and policies with specialized groups or other interested people.  Typical of this level, the appellant negotiates and coordinates matters of mutual interest, seeking to motivate groups to take advantage of NRCS programs under the Farm Bill, pursue careers in science and agriculture, and seek employment with the USDA.  Unlike Level 7-4, the appellant is not regularly required to defend significant or controversial agency actions, negotiate or mediate among groups or people with divergent viewpoints, or convince program managers to change or modify decisions involving significant or controversial issues.  Program issues of this nature are controlled and decided at higher echelons in the agency.

This factor is evaluated at Level 7-3 and 120 points are assigned. 

Factor 8, Physical demands

This factor covers the requirements and physical demands placed upon the employee by the work assignment.  This includes physical characteristics and abilities and physical exertion involved in the work.

At Level 8-1, the work is usually performed sitting at a desk, in news conferences, briefings, meetings, etc.; or riding in an automobile or public transportation.  There may be occasional brief visits to industrial or construction sites, national parks or forests, military equipment test sites, etc.  However, no special physical demands are involved in performing the work.

At Level 8-2, the work requires regular and recurring physical exertion such as long visits to outdoor sites in parks or forests which expose the employee to inclement weather or require movement over rough or uneven surfaces in natural or industrial settings.  Work requires specific but common physical characteristics such as above average resistance to fatigue.

The appellant’s position meets Level 8-1.  Like this level, her work is sedentary and does not present any special physical demands such as those described at Level 8-2.  The appellant indicates her position “requires the ability to work at stationary locations, walk over various types of landscapes, driving, exposure to various weather conditions, carrying, lifting and displaying promotional/information material at indoor or outdoor events.”  However, the record shows these activities, such as visiting landowners to encourage participation in NRCS programs, do not require her to have above average resistance to fatigue, require limited physical exertion, and do not meet the full scope of physical demands characteristic of Level 8-2.

This factor is evaluated at Level 8-1 and 5 points are assigned.

Factor 9, Work environment

This factor considers the risks and discomforts in the employee's physical surroundings or the nature of the work assigned and the safety regulations required.

At Level 9-1, the work environment involves everyday risks or discomforts requiring normal safety precautions typical of office settings or commercial vehicles such as planes, trains, buses or automobiles.  The work area is adequately lighted, heated and ventilated.

At Level 9-2, the work involves regular and recurring exposure to moderate risks, discomforts or unpleasant surroundings.  This includes duties performed in areas having high levels of noise and vibrations such as airfields; debris and wreckage such as accident sites; or areas where machinery or irritant chemicals are present such as industrial or construction sites or experimental areas with such dangers.

The appellant’s position meets Level 9-1.  Like this level, the appellant’s work is performed in an office setting.  When working at TU, the appellant has a private office located at Campbell Hall.  She also works in an office setting at NRCS State Office.  While the appellant may go to farms to meet with clients to discuss and encourage participation in NRCS programs, this does not require her to take special safety precautions. 

This factor is evaluated at Level 9-1 and 5 points are assigned. 

Summary of FES factors

The total of 2540 points falls within the GS-11 range (2355-2750) on the grade conversion table in the GS-1035 PCS.  Therefore, the appellant’s position is graded at the GS-11 level.

Decision

The position is properly classified as Public Affairs Specialist, GS-1035-11.