# PUBLIC COMMENT ON PROPOSED REGULATIONS: Prevailing Rate Systems; Redefinition of the Raven Rock Mountain Complex to the Washington-Baltimore-Arlington Federal Wage System Wage Area

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-03801

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

> Federal Register, Volume 91 Issue 37 (Wednesday, February 25, 2026) [Federal Register Volume 91, Number 37 (Wednesday, February 25, 2026)] [Proposed Rules] [Pages 9170-9176] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-03801] ======================================================================== Proposed Rules Federal Register ________________________________________________________________________ This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. ======================================================================== Federal Register / Vol. 91, No. 37 / Wednesday, February 25, 2026 / Proposed Rules [[Page 9170]] ----------------------------------------------------------------------- OFFICE OF PERSONNEL MANAGEMENT 5 CFR Part 532 [Docket ID: OPM-2026-0133] RIN 3206-AP11 Prevailing Rate Systems; Redefinition of the Raven Rock Mountain Complex to the Washington-Baltimore-Arlington Federal Wage System Wage Area AGENCY: Office of Personnel Management. ACTION: Proposed rule. ----------------------------------------------------------------------- SUMMARY: The Office of Personnel Management (OPM) is proposing to redefine the Federal Wage System (FWS) wage area coverage of the Raven Rock Mountain Complex (RRMC), which spans small portions of Washington County, Maryland, which is in the Washington-Baltimore-Arlington wage area, and Adams County, Pennsylvania, which is in the Harrisburg-York- Lebanon, PA wage area. OPM proposes to redefine the RRMC portion of Adams County from the Harrisburg-York-Lebanon, PA wage area to the Washington-Baltimore-Arlington wage area so that all of the RRMC is in the same wage area. Portions of Adams County outside of RRMC would continue to be defined to the Harrisburg-York-Lebanon, PA, wage area. This change would align wage area coverage for installations within the Pentagon Reservation and prevent pay disparities among FWS employees working at the RRMC. DATES:…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T21:02:50.227483+00:00._