HomeMy WebLinkAbout12, IBEW 1245 Grievance Letter of ReferralAgenda Item #12
To:
From:
Date:
Subject:
Board of Directors
Brian Wright
May 20, 2020
Consideration of Letter of Referral Submitted by IBEW 1245
Regarding MOU Grievance
ACTION
1. WHY THIS MATTER IS BEFORE THE BOARD
Step 3 of Section 14.4, Grievance Procedure Steps, of Title 14, Grievance Procedure
of the Memorandum of Understanding (MOU) between the District and the
International Brotherhood of Electrical Workers (IBEW) Local 1245 includes provisions
for the Board's written response to a grievance submitted by an employee or an
employee organization official if desired by the employee.
2. HISTORY
The majority of the District's operations, maintenance and administrative staff (non-
exempt employees) is a bargaining unit that is represented by the IBEW Local 1245.
The District and IBEW 1245 have maintained an MOU since May 1, 1967. The
previous MOU with IBEW Local 1245 became effective on January 1, 2016 and
expired on December 31, 2019.
In November and December of 2019, the District's labor negotiating team met with
IBEW business representatives and the Local 1245 negotiating committee (District
bargaining unit employees) to negotiate the terms of the new MOU. On December 12,
2019 the District and IBEW arrived at a tentative agreement on all proposed
modifications, pending ratification by majority vote from IBEW Local 1245 membership
and approval by the Board. In the interest of honoring the tentative agreement, all of
the new provisions within the MOU were implemented and made effective January 1,
2020.
On February 5, 2020, IBEW 1245 submitted a grievance to the District on the grounds
that the District failed to uphold the terms of Title 19, Employee Benefit Program. The
grievance reveals a material difference in interpretation by the District and IBEW Local
1245 as to the applicability of the MOU to previously retired employees of the District.
District staff holds the position that during negotiations, compensation and benefits are
provisions that were negotiated on behalf of current employees only. IBEW 1245
represents the bargaining unit, which is comprised of current employees. It does not
include former employees, including those who have retired from the District.
Therefore, District staff had no expectation or reasonable basis upon which to believe
that in negotiating with IBEW 1245 that it was negotiating compensation and benefits
for anyone other than those persons who are members of the bargaining unit. In other
words, there was no expectation or basis upon which to believe that it was bargaining
for benefits for anyone who is not a member of the bargaining unit, i.e. - retirees..
At no point during the negotiations did the IBEW 1245, the District's negotiating team
or the Board of Directors indicate or suggest that any of the negotiations were being
conducted on behalf of non-bargaining unit or previous employees. IBEW 1245's
assertion, as stated in the attached Letter of Referral, that it was the parties' mutual
intent at the bargaining table is not supported by either parties' documentation. In the
context of the grievance submitted by IBEW 1245 on April 14th, this includes
increases in the District's monthly contribution to post retirement benefits. This holds
true with other negotiated provisions such as wage increases, increases in employee
monthly contributions to group medical insurance plans and other economic benefits.
On February 20, 2020, the District and IBEW 1245 held an informal meeting to
discuss the difference in interpretation of Title 19, and its potential impact on the
timely approval of the MOU. Neither party conceded its position in terms of the
applicability of newly negotiated benefits to previously retired employees. Subsequent
to this meeting, a second informal meeting was held between the District and IBEW
1245 with the intent of finding resolution to the disputed item and proceed with the
timely approval of the new MOU. In this meeting both parties agreed that advisory
arbitration, as provided in Title 14 of the MOU, was the appropriate means for seeking
resolution.
The parties entered into a "Side Letter Agreement" whereby they agreed to resolve
their difference without further meet and confer and by allowing the Board to adopt the
proposed MOU without either party waiving its respective position on the disputed
issue. The Side Letter Agreement has been included with this staff report as
Attachment 2. Following final review, IBEW ratified the proposed MOU on February
25, 2020.
At the March 18, 2020 meeting, the Board approved the MOU and acknowledged the
Side Letter Agreement.
3. NEW INFORMATION
On April 14, 2020 the District received a second grievance from IBEW 1245 that was
substantially the same as the grievance received on February 5, 2020. The Grievance
substantially the same as the grievance received on February 5, 2020. The Grievance
received from IBEW 1245 on April 14, 2020 has been included with this Staff Report
as Attachment 1. In accordance with Step 2 of the Grievance Procedures outlined in
Title 14 of the MOU, the District responded to IBEW 1245 on April 15, 2020, stating
that the District's position on the disputed item had not changed and that subsequent
to the initial grievance submitted on February 5, 2020, both parties had agreed to find
resolution through advisory arbitration.
On May 5, 2020, in accordance with Step 3 of the Grievance Procedures outlined in
Title 14 of the MOU, IBEW 1245 submitted to the Board a Letter of Referral for
consideration of the grievance submitted on April 14, 2020. The Letter of Referral has
been included with this Staff Report as Attachment 2. Not only was the Letter of
Referral submitted in contravention of the Side Letter Agreement, it was submitted the
day before the May 6, 2020 Board meeting and after the agenda for the meeting had
been posted. Therefore, the Board would not have been able to hear and decide on
the Letter of Referral within 10 days as required by the MOU.
Regardless of the fact that it was submitted in contravention of the Side Letter
Agreement, the District informed IBEW 1245 that if it wanted the Board to consider the
Referral Letter, it would need to waive the 10-day period in writing. IBEW 1245
waived the 10-day period. A copy of the District's letter and IBEW 1245's response
are included with this Staff Report as Attachments 3 and 4, respectively.
It should be noted that there are multiple inaccuracies within the Letter of Referral,
most significantly:
In paragraph 5 of the letter, IBEW 1245 Business Representative, Mike
Venturino indicates that during an informal meeting held on February 20, 2020
"Mr. Holley conveyed in confidence that the cancellation of payment to current
retirees was due to outside pressure from unrepresented retirees." This is
entirely inaccurate. During the meeting, IBEW 1245 was informed that the
previous retirees were never intended to receive the increased post retirement
benefit, that Staff had mistakenly distributed the increased contributions to
existing retirees in January 2020, and once the mistake was identified, the
contribution amounts were corrected. Furthermore, IBEW 1245 was informed
that former unrepresented retirees were in fact collaborating with former union
retirees to protest the action jointly.
The options under consideration by the Board include the following:
1.) Reject the grievance submitted by IBEW 1245 on April 14, 2020, at which point
IBEW 1245 would have the option, in accordance with Step 4 of the Grievance
Procedures outlined in Title 14 of the MOU, to submit the grievance to non-binding
advisory arbitration within twenty (20) days. The arbitrator shall then provide a written
recommendation to the Board. The Board would then have ten (10) days to provide a
final written decision; or
2.) Accept the grievance submitted by IBEW 1245 as valid, thereby affirming the
position that IBEW 1245 represents past employees and direct staff to increase the
District's post retirement medical benefit contributions for existing employees, effective
January 1, 2020.
In making a determination as to how to proceed in this matter, the Board may wish to
consider some of the following contributing factors:
Generally speaking, labor negotiations between the District and the employee's
collective bargaining unit are conducted under the pretext that newly agreed
upon provisions are intended for the benefit of retaining current employees and
the recruitment of future employees. The negotiation process includes
compromises in providing monetary increases to some provisions within the
compensation and benefits package as well as cost containment or employee
contributions to other provisions within the package. Past employees are not
represented at the table and therefore are not subject to either side of the
compromises agreed upon, whether those are increases in provisions or
additional costs to the employees. Employees who retire from the District are
subject to the compensation and benefits package, and all other provisions
available and which had been agreed upon and in place at the time of
retirement. Subsequent negotiations, agreements and MOUs do not apply to
individuals not employed by the District or in this case who are no longer
members of the collective bargaining unit at the time of the agreement unless
otherwise explicitly agreed upon. Former employees and retirees are not
members of IBEW 1245 and do not pay dues, so it is curious as to why IBEW
1245 takes the position that it bargained on behalf of them. Furthermore,
IBEW has not clarified as to whether its assertion of mutual intent at the
bargaining table is applicable solely to previous retirees who retired as
members of the collective bargaining unit, past employees who at one point in
their tenure with the District served as a member of the collective bargaining
unit but retired as an unrepresented employee, or all previous retirees
regardless of represented status.
4. FISCAL IMPACT
The direct fiscal impact associated with this item is not yet known, as it is dependent
upon the direction provided by the Board. The following potential fiscal impacts have
been outlined for consideration:
If the grievance is rejected there will be no direct fiscal impact associated with
this item. The District will be subject to equal share with the collective
bargaining unit for the cost of advisory arbitration should IBEW 1245 choose to
pursue that option. The actual cost of arbitration is not known at this time.
If the grievance is accepted and the Board determines it appropriate to apply
the negotiated increases in the District's contributions to post retirement
medical benefits to all past retirees, there will be an estimated annual increase
in the District's Other Post Employment Benefits (OPEB) of approximately
$91,000/year. This annual cost estimate does not include any additional
associated administrative costs, and is dependent upon the number of retirees
in the program and eligible contributions each year.
Title 14 of the MOU, Grievance Procedures stipulates that an employee, and/or
an employee organization official if desired by the employee, shall refer the
issue (grievance) in witting. The District contends that both the original
grievance received on February 5, 2020, and the second grievance received on
April 14, 2020 have been submitted by IBEW 1245 on behalf of ex-employees,
not current employees, who are no longer members of the collective bargaining
unit, and therefore not covered by the current MOU. In other words, the Union
had no standing to submit these grievances. During the informal meeting held
between the District's labor negotiating team and IBEW 1245 representatives,
Staff indicated that one of the contributing factors of the dispute is whether
IBEW 1245 had standing to submit the grievance, as it has been submitted on
behalf of a group IBEW 1245 does not represent. Moving directly to advisory
arbitration was recommended during this meeting to determine the validity of
the grievance and avoid re-opening negotiations which would have financial
implications to represented employees.
During the negotiations, the District's negotiating team received parameters
from the Board to include modest increases in the District's contribution to
employees monthly post retirement medical benefits in exchange for cost
containment measures in the form of monthly employee contributions to group
medical insurance plans. Neither of these provisions were intended to be
applied to previously retired employees.
The opptions and considerations presented in this Staff Report for the Board's
consideration have been reviewed and concurred with by District Counsel as well as
the District's outside labor counsel and lead labor negotiator, Joe Wiley.
Brian Wright Michael D. Holley
Water Utility Director/Assistant GM General Manager
in the program and eligible contributions each year.
5. RECOMMENDATION
Staff recommendation is to reject the grievance submitted by IBEW 1245 on April 14,
2020.