International Association of Fire Fighters, Local No. 1805

And

Clark County Fire Protection District No. 6

Interest Arbitration

Arbitrator:            Michael H. Beck

Date Issued:         12/14/1990

 

 

Arbitrator:               Beck; Michael H.

Case #:                    08346-I-90-00188

Employer:    Clark County Fire Protection District #6

Union:                      IAFF; Local 1805

Date Issued:            12/14/1990

 

 

 

 

            IN THE MATTER OF INTEREST       )             

            ARBITRATION BETWEEN                 )          

                                                                              )               OLYMPIA WA

            CLARK COUNTY FIRE                        )

            PROTECTION DISTRICT NO. 6         )           PERC NO.: 8346-1-90-188

                                                                              )

                   and                                                     )           Date Issued: December 14, 1990

                                                                              )

            INTERNATIONAL ASSOCIATION    )

            OF FIRE FIGHTERS, LOCAL              )

            NO. 1805                                                  )

                                                                              )

            ______________________________      )

 

 

 

INTEREST ARBITRATION

OPINION AND AWARD

OF

MICHAEL H. BECK

 

FOR THE ARBITRATION PANEL

            Michael H. Beck        Neutral Chairman

            Bud Seifert                 Employer Member

Frank Spickelmire      Union Member

 

 

Appearances:

 

CLARK COUNTY FIRE PROTECTION

DISTRICT NO. 6                                                                                    A. K. Baird

 

INTERNATIONAL ASSOCIATION OF

FIRE FIGHTERS, LOCAL NO. 1805                                                   James H. Webster

 

 

IN THE MATTER OF INTEREST )          

ARBITRATION BETWEEN                       )

                                                                        )

CLARK COUNTY FIRE                              )

PROTECTION DISTRICT NO. 6               )     PERC NO.: 8346-1-90-188

                                                                        )

       and                                                           )     Date Issued: December 14, 1990

                                                                        )

INTERNATIONAL ASSOCIATION          )

OF FIRE FIGHTERS, LOCAL                    )

NO. 1805                                                        )

                                                                        )

________________________________        )

 

INTEREST ARBITRATION OPINION

 

 

PROCEDURAL MATTERS

 

            RCW 41.56.450 provides for arbitration of disputes

involving uniformed personnel when collective bargaining

negotiations have resulted in impasse.  Accordingly, a

tripartite arbitration panel was formed with respect to the

instant matter.  The Employer, Clark County Fire protection

District No. 6, appointed Bud Seifert as its member of the

Panel and the Union, International Association of Fire

Fighters, Local 1805, appointed Frank Spickelmire as its

member of the Panel.  The undersigned was selected to serve

as Neutral Chairman of the Panel.

 

            A hearing in this matter was held on May 16, 1990 in

Vancouver, Washington.  The Employer was represented by A.

K. Baird of Allied Employers, Inc. and the Union was repre-

sented by James H. Webster of the law firm of Webster, Mrak

and Blumberg.

 

            At the hearing, the testimony of witnesses was taken

under oath and the parties presented substantial documentary

evidence.  A court reporter was present at the hearing and a

verbatim transcript of the proceedings was made available to

the Chairman for his use in reaching his determination in

this case.

 

            The parties agreed upon the submission of simultaneous

posthearing briefs which were filed by each party and

received by the Neutral Chairman on July 9, 1990.  The

parties agreed to waive the statutory requirement that the

Chairman issue his decision within thirty days following the

conclusion of the hearing.

 

            The Panel agreed that the Chairman would prepare a

draft Decision and provide a copy to each of the other panel

Members for comment.  A draft Decision was mailed to each of

the other Panel Members on October 30, 1990.  In response,

the chairman received a letter from Panel Member Seifert.

Additionally, the Panel Members agreed that the Chairman

should meet with counsel to further discuss this matter.

This meeting, held December 11, 1990, was attended by Mr.

Baird, Mr. Webster and myself.  I have carefully considered

all of the comments I received in response to the Draft

Decision.  What follows, based on the record and after

consultation as described above, is my findings of fact and

determination of the issues.

 

 

ISSUES IN DISPUTE

 

            The following issues were presented to the Panel for

arbitration:

 

                                    Salaries

                                    Workweek

                                    Holidays

                                    Sick Leave

                                    Medical Insurance

 

            One remaining issue, Prevailing Rights, was not

resolved by the parties prior to the hearing in this matter.

However, as explained in my letter to counsel dated October

18, 1990, the Arbitration Panel does not have authority to

consider the Prevailing Rights issue at the present time.

 

STATUTORY CRITERIA

 

            RCW 41.56.460 directs that the following criteria shall

be taken into consideration as relevant factors in reaching

a decision:

 

            ...(T]he panel shall be mindful of the leg-

islative purpose enumerated in RCW 41.56.430 and as ad-

ditional standards or guidelines to aid it in reaching

a decision, it shall take into consideration the fol-

lowing factors:

 

                        (a)        The constitutional and statutory authority of

                        the employer;

 

                        (b)        Stipulations of the parties;

 

* *

 

            (c)(ii)   For employees listed in RCW 41.56.030(7)(b),

            comparison of the wages, hours, and conditions of em-

            ployment of personnel involved in the proceedings with

            the wages, hours, and conditions of employment of like

            personnel of public fire departments of similar size on

            the west coast of the United States.  However, when an

            adequate number of comparable employers exists within

            the state of Washington, other west coast employers

            shall not be considered;

           

            (d)        The average consumer prices for goods and ser-

            vices, 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 forego-

                        ing, which are normally or traditionally taken into

                        consideration in the determination of wages, hours and

                        conditions of employment. . .

 

            The legislative purpose which your Chairman is directed

to be mindful of in applying the statutory criteria is set

forth in RCW 41.56.430 as follows:

 

            The intent and purpose of this . . .  act is to

recognize that there exists a public policy in the

state of Washington against strikes by uniformed per-

sonnel as a means of settling their labor disputes;

that the uninterrupted and dedicated services 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. . .

 

COMPARABLE EMPLOYERS

 

            Pursuant to RCW 41.56.460(c)(ii), it is common in these

proceedings for the arbitration panel to select an appropri-

ate number of comparable employers.  On June 15, 1989, the

parties executed a document entitled, "Ground Rules Meeting

for 1990 Contract Negotiations Between the Clark Co. Fire

Dist. #6 and IAFF Local 1805."

 

            Paragraph No. 9 of that document provided as follows:

 

If comparables are to be used, criteria for the compa-

rables must not exceed 200%, or be less than 50% of

that of Fire District I 6.

 

            The record does not indicate the extent to which compa-

rables were discussed during negotiations.  Furthermore,

although the outer limits of the comparables were defined by

the parties, nothing in the record indicates whether the

parties discussed the basis upon which the comparables were

to be selected.

 

            The Union determined to review four criteria.  These

four were: population served, assessed value, total depart-

ment manpower (paid) , and department budget.  Next the Union

reviewed all of the Employers in Washington State which

operate fire departments and found that twenty-one employers

maintain fire departments, which, with respect to popula-

tion, assessed value, number of employees and budget were

within the agreed upon range, that is, none of these twenty-

one exceeded the Employer here by 200% or was less than the

Employer here by 50%.

 

By letter dated January 19, 1990, the Employer advised

the Union that it contemplated using eighteen specific

comparable employers during the upcoming interest arbitra-

tion.  The Employer's list included fourteen employers

located in Washington and four employers located in Oregon.

This list was substantially similar to that presented by the

Employer to the Arbitration Panel chaired by Arbitrator

Kenneth M. McCaffree with respect to the interest arbitra-

tion between the parties regarding the 1987-89 agreement.

Mr. McCaffree's decision is in the record in this case but

it does not indicate the basis upon which the Employer

selected its comparables in that case.

 

            In response to a letter from the Union dated January

27, 1990 requesting that the Employer provide the Union with

the criteria it used in establishing its list of compara-

bles, the Employer on March 12, 1990 provided the Union with

a new list of eighteen comparable employers.  This list

contained only three Washington employers with the remaining

fifteen being located in Oregon.

 

            As the Union points out, RCW 41.56.460(c) (ii) makes

clear that when an adequate number of comparable employers

exist within the State of Washington, "other west coast

employers shall not be considered."  Here, the Union has

provided for an adequate number of comparable employers in

the State of Washington.  It has done so in an appropriate

fashion in that it has, using four different size-related

criteria, included each of the employers located in

Washington State which come within the percentage range

agreed upon by the parties at the beginning of negotiations

in June of 1989.  Therefore, I agree with the Union that the

Arbitration Panel is precluded from including as comparators

employers located in the State of Oregon.

 

            The Employer contends that even if Oregon employers

cannot be included as comparators pursuant to

41.56.460(c)(ii), those employers may be considered pursuant

to subsection (f) of RCW 41.56.460.  However, subsection (f)

refers to:

 

Such other factors, not confined to the foregoing,

which are normally or traditionally taken into consid-

eration in the determination of wages, hours and condi-

tions of employment.

 

            Thus, the language of RCW 421.56.460(f) is clear in

that it refers to the consideration of factors other than

comparable employers.  It would make no sense to construe

the statute so as to preclude the consideration of Oregon

employers in one subsection, but permitting them to be

brought in the backdoor, so to speak, through another

subsection.

 

            However, considerations of labor market raised by the

Employer are appropriately considered by the Arbitration

Panel pursuant to RCW 41.56.460.  This is because labor

market considerations have traditionally been taken into

consideration in the determination of wages, hours and

conditions of employment and, in fact, have been raised by

numerous unions and employers before arbitration panels in

the State of Washington.  In particular, the Employer points

to the fact that the Employer comparables selected by the

Union are heavily weighted to what it describes alterna-

tively as the "Seattle-King/Snohomish County" area or the

"Seattle/Puget Sound Basin area."  It is not clear from the

Employer's brief exactly which