Public, Professional & Office-Clerical Employees and Drivers, Local Union No. 763

And

Snohomish County

Interest Arbitration

Arbitrator:      Alan R. Krebs

Date Issued:   01/26/1987

 

 

Arbitrator:         Krebs; Alan R.

Case #:              06360-I-86-00146

Employer:          Snohomish County

Union:                Teamsters; Local 763

Date Issued:     01/26/1987

 

 

 

IN THE MATTER OF

SNOHOMISH COUNTY

 

PUBLIC, PROFESSIONAL & OFFICE-CLERICAL EMPLOYEES

AND DRIVERS, LOCAL UNION NO. 763

 

PERC No.: 6360-I-86-146

Date Issued: January 26, 1987

 

INTEREST ARBITRATION

OPINION AND AWARD

OF

ALAN R. KREBS

 

Appearances:

SNOHOMISH COUNTY

J. David Andrews and

Nancy Williams

 

PUBLIC, PROFESSIONAL & OFFICE-CLERICAL

EMPLOYEES AND DRIVERS, LOCAL UNION

NO. 763

Heal L. Wacker

 

IN THE MATTER OF

SNOHOMISH COUNTY

AND

PUBLIC, PROFESSIONAL & OFFICE-CLERICAL EMPLOYEES

AND DRIVERS, LOCAL UNION NO.763

 

OPINION OF THE ARBITRATOR

 

PROCEDURAL MATTERS

      The Arbitrator was selected by the parties in accordance

with RCW 41.56.450 and Article XVI, Section 16.2.1 of their

1985-87 collective Bargaining Agreement. The first day of

hearing was held in Marysville, Washington, on October 7,

1986. The second day of hearing was held in Everett,

Washington, on November 14, 1986. Snohomish county was

represented by J. David Andrews and Nancy Williams of the law

firm, Perkins Coie. Public, Professional & Office-Clerical

Employees and Drivers, Local Union No. 763 was represented by

Herman L. Wacker of the law firm, Davies, Roberts, Reid &

Wacker.

      At the hearing, the testimony of witnesses was taken under

oath and the parties presented documentary evidence. A

reporter was present during the proceedings, and a transcript

was prepared and made available to the Arbitrator for his use

in reaching a decision.

      The parties agreed upon the submission of simultaneous

post hearing briefs. The briefs were received by the

Arbitrator on December 26, 1986.

 

BACKGROUND

      The County and the Union are parties to a collective

bargaining agreement which expires on December 31, 1987. The

bargaining unit is comprised of 120 law enforcement officers

of the county Sheriff's Department including 98 deputies, 17

sergeants, and 5 lieutenants. The median length of service is

about 7 years for deputies, and considerably longer for

sergeants and lieutenants. Article XVI, Section 16.2 of the

labor agreement permits either party to reopen the agreement

as of January 1, 1986 in order to negotiate amendments

relating to wages, educational incentive pay, longevity pay,

and health and welfare. Article XVI, Section 16.2.1 provides

that in the event that the parties are unable to reach

agreement on these issues, the dispute shall be submitted for

interest arbitration in accordance with RCW 41.56.

 

ISSUES

      The parties were unable to reach an agreement on the

reopened issues despite their efforts in negotiations and the

efforts of a mediator. In accordance with RCW 41.56.450, the

Executive Director of the Public Employment Relations

Commission certified that the parties were at impasse with

regard to wages, educational incentive pay, longevity pay, and

health and welfare. Since that certification, the efforts of

the parties in collective bargaining negotiations have

resulted in an agreement with regard to health and welfare.

The parties agree that the issues remaining unresolved relate

to wages, educational incentive pay, and longevity pay.

 

APPLICABLE STATUTORY PRINCIPLES

      Where certain cities and counties and their uniformed

personnel are unable to reach agreement on new contract terms

through negotiations and mediation, RCW 41.56.450 calls for

the interest arbitration of their disputes. RCW 41.56.030

defines "uniformed personnel" for whom interest arbitration is

available as encompassing law enforcement officers of cities

with a population of at least 15,000, or of counties of the

second class or larger. The parties agree that Snohomish

County, with a population of 366,700, meets the statutory

standard for interest arbitration.

      RCW 41.56.460 sets forth certain "basis for determination"

which must be considered by this Arbitrator. It provides:

 

 41.56.460 Uniformed personnel-

Arbitration panel-Basis for

determination. In making its

determination, the panel shall be mindful

of the legislative purpose enumerated in

RCW 41.56.430 and as additional standards

or guidelines to aid it in reaching a

decision, it shall take into consideration

the following factors:

      (a) The constitutional and statutory

authority of the employer.

      (b) Stipulations of the parties.

      (c) Comparison of the wages, hours and

conditions of employment of personnel

involved in the proceedings with the wages,

hours, and conditions of like personnel of

like employers of similar size on the west

coast of the United States.

      (d) The average consumer prices for

goods and services, commonly known as the

cost of living.

      (e) Changes in any of the foregoing

circumstances during the pendency of the

proceedings; and

      (f) Such other factors, not confined

to the foregoing, which are normally or

traditionally taken into consideration in

the determination of wages, hours and

conditions of employment.

 

RCW 41.56.430, which is referred to in the above-quoted

language, provides as follows:

 

41.56.30 Uniformed personnel-

Legislative declaration. The intent and

purpose of this 1973 amendatory act is to

recognize that there exists a public policy

in the state of Washington against strikes

by uniformed personnel as a means of

settling their labor disputes; that the

uninterrupted and dedicated service of

these classes of employees is vital to the

welfare and public safety of the state of

Washington; that to promote such dedicated

and uninterrupted public service there

should exist an effective and adequate

alternative means of settling disputes.

 

Comparables

      One of the primary standards or guidelines enumerated in

RCW 41.56.460 upon which the Arbitrator must rely in making

his determination is:

 

***

      (c) Comparison of the wages, hours

and conditions of employment of personnel

involved in the proceedings with the wages,

hours, and conditions of like personnel of

like employers of similar size on the west

coast of the United States.

***

 

In order to make such a comparison, one must first determine

which like employers on the west coast should be selected as

similar in size to Snohomish County for the purposes of this

proceeding.

      The parties were unable to agree upon a list of like

employers. The County proposes that the Arbitrator consider

the following three counties as appropriate for comparison:

Spokane County, Washington; Klackamas County, Oregon; and

Stanislaus County, California. These counties were selected

from among all the counties in the three west coast states,

Washington, Oregon, and California, based on an examination of

each county's total population, population in nonincorporated

areas, total square miles, nonincorporated square miles, and

miles of county-maintained roads. A county was considered

similar to Snohomish County for any of these criterion which

was within 25 percent of that for Snohomish County. If a

county came within the similar range on nonincorporated

population and on at least two of the other size criteria, it

became one of the County's comparators.

      The Union suggests that the Arbitrator should consider

three types of employers as comparable jurisdictions. It

urges that all ten of the Washington counties that are subject

to statutory interest arbitration be considered. It also

asserts that all 17 counties in Washington, Oregon, and

California which have a population between 200,000 and 525,000

are comparable. As additional comparable employers, the

Union points to all 23 cities in Washington which are subject

to statutory interest arbitration and which are situated

within counties which are subject to interest arbitration.

      Whatever the merits of the County's methodology, the

sample that it came up with is just too small. With only

three comparators, any one of them will have an enormous

influence on the conclusions reached. One or two of them may

have unusual contract terms reflecting unique circumstances or

an atypical labor relations relationship. A larger sample is

necessary in order to reflect a meaningful norm of like-sized

jurisdictions. No larger sample can be gleaned from the

information supplied by the County.

      The Union's position has the opposite flaw. It is too

broad. First, its suggestion to use all counties subject to

interest arbitration would result in using comparators that

are not of similar size. That would not comply with the

requirement of RCW 41.56.460(c) that "similar size" employers

be compared. Counties such as Cowlitz, with a population of

79,000, and King, with a population of 1,326,600, cannot be

considered to be of similar size to Snohomish County, with its

population of 366,700.

      The same reasoning can be applied to the Union's reliance

on Washington cities with a population of over 15,000. Such

cities are not of like size to Snohomish County. The only

Washington city with a population between 200,000 and 525,000

is Seattle, which has a population of 490,900. Seattle and

Snohomish County can hardly be said to be comparable, since

Seattle employs 1,004 fully-commissioned law enforcement

officers, whereas Snohomish County employs 127. Moreover, the

statute calls for a comparison of "like employers." While

there are many similarities in the nature of law enforcement

supplied by counties and cities, counties and cities are

distinguishable entities. They generally serve different

purposes and have different taxing authorities. An adequate

sample can be obtained by using counties alone, and counties,

after all, are more like counties than they are like

cities.1

__________________

 1    The County cited several interest arbitration

decisions in which the arbitrator declined to find that cities

and counties are like employers, including City of Walla Walla

and Walla Walla police Guild (Thomas F. Levak, 1986) , and

Whatcom County and General Teamsters Local Union No. 231

(Carlton J. Snow, 1986).

 

      The Union argues that the compensation paid by Washington

cities have added significance because that compensation has

been influenced by the statutory interest arbitration

procedure, whereas, interest arbitration is new for most

counties. Thus, the Union argues, the compensation paid by

cities reflects the product of impartial dispute resolution,

while compensation paid by counties reflects a former

bargaining process which favored the employer. The statute

does not indicate that any special weight should be given to

those employers who are subject to interest arbitration. The

nature of their labor relations does not determine whether two

employers are alike for the purpose of the statute. Rather,

the statute focuses the selection of comparators on "like

employers of similar size on the west coast."

      Your Arbitrator has selected seven counties to serve as

comparators. They are as follows:

_____________________________________________________

Washington State           Population

Clark County                  201,700

Pierce County                 514,600

Spokane County             349,400

 

Oregon

Marion County               210,000

Washington County        260,000

 

California

San Joaquin County       390,600

Stanislaus County           292,350

_____________________________________________________

      The three Washington State counties reflect all of the

counties in Washington, besides Snohomish County, which have a

population between 200,000 and 525,000. Oregon and California

have more counties falling within this population band than

does Washington. Only two counties were selected from each of

those west coast states, so that the experience of California

counties would not dominate.

      Oregon has four counties with a population of between

200,000 and 525,000. Those four counties each have a

population of between 210,000 and 268,500. Marion County and

Washington County were selected because their ratio of

reported part one criminal offenses to law enforcement

officers is very similar to that of Snohomish County. D.P.

Van Blaricom, former police chief of the Bellevue Police

Department, testified that such a ratio reflects the way that

he would measure work load. Since the populations of the four

Oregon Counties are fairly close, using the work load is the

most rational basis in the record to select the two most

comparable Oregon counties.

      According to the Union, California has ten counties with a

population of between 200,000 and 525,000. That number was

reduced to seven by considering only those counties which had

a population within 25 percent of the population of Snohomish

County. That eliminated Tulare, Mann, and Santa Cruz

Counties from consideration. Of the remaining seven counties,

San Joaquin and Stanislaus were significantly closest to

Snohomish County in the work load of their officers according

to the crime statistics. The following chart reflects all the

counties in Oregon and California with a population of between

200,000 and 525,000, as well as their rate of crimes per

officer:2

_____________________________________________________

 

                                                                  Crime Rate

                                    Population             Per Officer

 Oregon Counties

 Lane                           268,500                 33.9

 Washington*             260,200                 50.0

 Clackamas                 246,300                 82.7

 Marion*                     210,000                 56.6

 

 California Counties

 Kern                           400,506                 27.9

 San Joaquin*             390,600                 44.5

 Santa Barbara           320,362                 26.7

  Monterey                 316,179                 24.6

 Sonoma                      305,000                 37.2

 Stanislaus*                292,350                 53.3

 Solano                        282,350                 71.1

 Tulare                        249,000                 25.5

 Mann                         223,000                 30.1

 Santa Cruz                 200,300                 46.0

 

 Snohomish County    366,700                 52.6

_____

*reflects the counties selected

_____________________________________________________

2     This chart is derived from Union exhibits 25 and

26. The Union indicated that the crime statistics come from

the 1985-86 Personnel and Budget Study of Oregon Law

Enforcement Agency published by the Board on Police

Standards And Training, the 1985 Oregon Report of Criminal

Offenses and Arrests published by the Board on Police

Systems, and the 1984 California Criminal Justice Profile

published by the California Department of Justice. Union

Business Representative Richard Basarab testified that these

data sources indicated that uniform FBI reporting procedures

were used. Mr. Basarab further testified that the crime

figures used were those for part 1 crimes, such as homicide,

rape, aggravated assault, etc.

 

      The Union argues that in order to make a meaningful

comparison between the compensation of County personnel and

the compensation of personnel in other jurisdictions, each

element of compensation must be valued and the total in each

jurisdiction reduced to a single statistic. The Union

asserts that it is meaningless to compare only wages and to

ignore other nonwage compensation, such as health and

welfare benefits, longevity pay, educational incentive pay,

medical, dental, vision and life insurance contributions,

social security and/or benefit trust contributions,

retirement contributions, holiday and vacation pay, and

uniform allowances. Under the Union's model, the various

elements of compensation are each translated into a dollars

and cents cost per hour to the employer. All such itemized

costs are then totaled to determine the total hourly cost to

the employer for compensation for the law enforcement

officers.

      The County argues that the compilation and presentation

of compensation data in the manner proposed by the Union

improperly expands and distorts the focus of the issues

before the Arbitrator. The County points out that the

Arbitrator's jurisdiction is limited to wages, educational

incentive pay and longevity pay. The County asserts that it

would be an improper expansion of the scope of the

arbitration if the Arbitrator were to consider other items,

and, indirectly, make adjustments to those through an award

on the limited items properly before him. The County argues

that the Union's analysis ignores the possibility that in

collective bargaining, monetary components often are

subordinated to nonmonetary issues. Further, the County

argues, the Union's focus on monetary cost to the employer

ignores the actual benefits received by the employees. The

County points out that the same costs can supply differing

levels of insurance or retirement benefits. The County argues

that it would be inappropriate to reduce all compensation to

an hourly rate because the parties have historically</