Civilian Acquisition Workforce Personnel Demonstration Project

The commenter requests the removal of any links or references to STRL federal registers in the final publication. They argue that such linkages could unfairly restrict the STRL's ability to amend or rescind federal registers in the future.

The commenter provides technical guidance on the legal authorities and waivers required for the Civilian Acquisition Workforce Personnel Demonstration Project. They recommend establishing new flexibilities under 5 U.S.C. 4703 and including all necessary waivers to ensure the project aligns with existing legislative frameworks.

The commenter opposes the proposed amendment to include NH-IV broadband levels in the Accelerated Compensation for Developmental Positions (ACDP) program. They argue that NH-IV represents senior leadership and expert-level roles rather than the entry-level or developmental positions the program is intended to support.

The commenter opposes the proposed action because it attempts to "adopt" personnel flexibilities from Science and Technology Reinvention Laboratory (STRL) notices rather than establishing them as standalone AcqDemo authorities. They argue that this approach introduces systemic vulnerabilities and fails to comply with specific federal codes requiring explicit legal waivers and operational text for each authority.

The commenter points out inconsistencies and lack of clarity in the "Out-of-Cycle Within-Broadband Pay Increase" section of the proposal. They request that the document clearly define the specific mechanisms (such as CCAS or reassignment) through which internal within-band pay increases may occur.

The commenter opposes the integration of NH-IV broadband levels into the Accelerated Compensation for Developmental Positions (ACDP) authority. They argue that these are senior roles that should be rewarded via Out-of-Cycle Within-Broadband Pay Increases instead of developmental pay structures, which they believe should be reserved for early-career talent.

The commenter argues that the proposed action's reference to Science and Technology Reinvention Laboratories (STRLs) personnel demonstration project plans is confusing and complicates the AcqDemo authorities. They request that the section be revised to remove the link to STRL authorities to prevent potential misuse or misunderstanding within the AcqDemo community.

The commenter points out a technical inconsistency in the "Summary of Changes" section regarding the adoption of authorities from the STRL demo. They argue that the current language lacks the necessary authority to allow such an adoption and request a revision of that section.