Snohomish County, Department of Corrections

And

Teamsters Local Union No. 763

Interest Arbitration

Arbitrator:      Gary L. Axon

Date Issued:   07/30/1996

 

 

Arbitrator:         Axon; Gary L.

Case #:              11976-I-95-00260

Employer:          Snohomish County

Union:                Teamsters Local Union No. 763

Date Issued:      07/30/1996

 

 

 

            IN THE MATTER OF                                              )

                                                                                                )

            INTEREST ARBITRATION                                   )                       PERC CASE 11976-1-95-260

                                                                                                )

            BETWEEN                                                                 )                       ARBITRATOR'S AWARD

                                                                                                )

            TEAMSTERS LOCAL UNION NO. 763,               )           1996 INTEREST ARBITRATION

                                                                                                )

                                                            Union,                         )

            and                                                                              )

            SNOHOMISH COUNTY, WASHINGTON,           )

            DEPARTMENT OF CORRECTIONS,                   )

                                                            County.                       )          

                                   

HEARING SITE:                                                                  County Administrative Building

                                                                                                Everett, Washington

 

HEARING DATES:                                                              May 25, 26, 1996

 

POST-HEARING BRIEFS DUE:                                        Postmarked May 28, 1996

 

RECORD CLOSED ON RECEIPT OF BRIEFS:              May 31, 1996

 

REPRESENTING THE UNION:                                         Michael R. McCarthy

                                                                                                Davies Roberts and Reid

                                                                                                Suite 550

                                                                                                101 Elliott Avenue West

                                                                                                Seattle, WA 98119

 

REPRESENTING THE COUNTY:                                     Thomas E. Platt

                                                                                                Perkins Cole

                                                                                                40th Floor

                                                                                                1201 Third Avenue

                                                                                                Seattle, WA 98101-3099

 

ARBITRATOR:                                                                    Gary L. Axon

                                                                                                1465 Pinecrest Terrace

                                                                                                Ashland, OR 97520

                                                                                                (541) 488-1573

 

                                                            TABLE OF CONTENTS

ISSUE                                                                                                 Page

 

Introduction                                                                                        2

1 - Wages                                                                                           6

2 - Pension                                                                                          40

           

I.          INTRODUCTION

 

            This case is an interest arbitration conducted pursuant

to the Public Employees Collective Bargaining Act.  The parties to

this dispute are Teamsters Local 763  (hereinafter "Union") and

Snohomish County, Washington (hereinafter "County") . The Union and

the County are parties to a Collective Bargaining Agreement which

covered the period from January 1, 1992, through December 31, 1994.

The  parties  entered  into  negotiations  to  reach  a  successor

Agreement to the 1992-94 Collective Bargaining Agreement.   The

parties were successful in resolving most of the issues that

divided them in contract negotiations.  Three fundamental issues

were certified by the Public Employee Relations Coxnmission for

interest  arbitration.     The  issues  certified  for  interest

arbitration were wages, shift differential and pension. During the

course of the interest arbitration proceeding, the parties were

able to reach agreement on the shift differential issue.

 

            Snohomish County, Washington, stretches from Puget Sound

on the west to the crest of the Cascade Mountains on the east.

Skagit County is located immediately to the north, with King County

immediately to the south, and Kitsap and Island Counties to the

west.   The County is located on the I-5 corridor.   The County

serves a resident population of 525,600.  The largest city in the

County is Everett.  The County has approximately 2,083 employees.

 

            Snohomish County provides detention and correctional

services to all municipalities as well as unincorporated areas

within its boundaries.  All persons charged with serious crimes and

misdemeanor violations under the state code are booked and detained

at the County jail.  The arrestees sentenced to one year or less

are also by law housed at the County Correctional Facility for the

period of their sentence.  William Harper has served as Department

Director since 1982.  During 1995 the average daily population at

the correctional facilities was 548.   Over 16,000 persons were

booked and processed through the facilities during 1995.   The

majority of the persons were detained for four days or less.  In

1995 the average length of stay for all bookings was 12.3 days.

 

            The Corrections Department employs 195 staff.  The Union

represents 105 employees in the Corrections Department in the

classifications  of custody and corrections  officers  that are

subject to this interest arbitration.  Approximately 58 support

personnel,  5  corrections  supervisors,  10  corrections  support

supervisors and 45 sheriff's support personnel are also represented

by the Union.

 

            The hearing in this case took two days for the parties to

present a substantial amount of testimony,  and extensive and

comprehensive documentary evidence.  The parties were unable to

agree on the appropriate jurisdictions with which to compare

Snohomish County for the purpose of establishing thewage level for

the members of this bargaining unit.  A considerable amount of

hearing time was devoted to receiving evidence on the issue of

comparability.  The hearing was recorded by a court reporter and a

transcript was made available to the parties and the Arbitrator for

the purpose of preparing the post-hearing briefs and the Award.

 

Testimony of witnesses was taken under oath.  At the hearing the

parties  were  given  the  full  opportunity  to  present written

evidence, oral testimony and argument.  The parties provided the

Arbitrator with substantial written documentation in support of

their respective positions. Comprehensive and lengthy post-hearing

briefs were submitted to  the Arbitrator along with interest

arbitration awards previously issued by arbitrators in the state of

Washington.

 

            This Arbitrator carefully reviewed and evaluated all of

the evidence and argument submitted pursuant to the criteria

established by RCW 41.56.460.  This is the first year that interest

arbitration has been available to corrections officers.   RCW

41.56.030(7) (C) .  The approach of your Arbitrator in writing this

Award will be to summarize the major and most persuasive evidence

and argument presented by the parties on each issue.  After the

introduction of the issue and positions of the parties, I will then

state the basic findings and rationale which caused the Arbitrator

to make the award on the individual issue.

 

            The Arbitrator is directed by the statute to take into

consideration a number of standards or guidelines to assist in

making an Award to resolve this dispute.  The statutory factors to

be considered by the Arbitrator may be summarized as follows:

 

(a)        the  constitutional  and  statutory

            authority of the employer;

 

(b)        the stipulations of the parties;

 

(c)        the wages,  hours  and conditions  of

employment 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.

 

ISSUE 1 - WAGES

 

A.        BackGround

 

            The 1992-94 Collective Bargaining Agreement for custody

and corrections officers provides for a six-step salary schedule.

The final year of the 1992-94 contract provided a salary range as

follows:

 

CLASS            Step 1              Step 2              Step 3              Step 4             Step 5              Step 6

                        2283.25           2396.58           2516.17           2643.00           2776.42           2913.25

 

            The parties have agreed to retain the existing six-step

schedule for three years with agreed on cost of living wage

increases.   The parties agreed to adjust the salary schedule

effective January 1,  1995,  by 3.15% and an additional 2.88%

increase on January 1, 1996.  The third year increase would be

controlled by a CPI formula.  Effective January 1, 1997, the salary

schedule would be increased by an amount equal to 90% of the CPI-W.

 

            The agreed on adjustments for the first two years will

result in a salary schedule providing wages as follows:

 

CLASS            Step 1              Step 2              Step 3              Step 4              Step 5              Step 6

 

CO 1995         2355.17           2472.07           2595.43           2726.25           2863.88           3005.02

CO 1996         2423.00           2543.27           2670.18           2804.77           2946.36           3091.56

CO 1997         COLA             COLA             COLA             COLA             COLA             COLA

                                                             Jt. Ex.            9.

 

            The dispute before the Arbitrator on the wage issue is a

Union proposal to add another 5% increase to the agreed on wage

adjustment for both 1995 and 1996.  The County takes the position

the agreed on COThA adjustments establishes the appropriate levels

of compensation for the 1995-97 contract years.  The only remaining

issue for the Arbitrator is whether there will be further wage

adjustments for 1995 and 1996 in addition to the COLA.

 

B.        The Union

 

            The Union takes the position that Snohomish County

custody officers are entitled to a substantial wage increase in

addition to COLA increases.  According to the Union, after making

the statutorily required adjustments for cost of living, the data

from the comparable jurisdictions indicates a substantial increase

is necessary to "narrow the gap" between the under compensated

Snohomish County officers and their counterparts in the other

jurisdictions.  The Union submits its proposal for an additional 5%

raise for 1995 and 1996, in addition to the COLA adjustments is in

accord with the statutory standards.

 

            The Union asserts that even if the County's comparators

and methodology are adopted by the Arbitrator, the evidence shows

the custody officers are clearly entitled to a substantial raise.

In the view of the Union,  the statute expressly instructs an

arbitrator  to  take  "cost of  living"  into consideration when

formulating an award.   Arbitrators have traditionally adjusted

comparison studies to reflect different costs of living among the

comparison jurisdictions.  The Union and County are in substantial

agreement that the ACCRA Cost of Living Index provides a valid

basis  for  determining  differences  in  cost  of  living  among

Washington counties.   Un.  Exs.  16,  17.   When the Arbitrator

considers the cost of living data, he need not resolve all of the

parties methodological sub-disputes, because a substantial raise is

clearly  due  even  if  one  adopts  the  County's  comparison

jurisdictions and methodology.   The ACCRA Cost of Living Index

shows the Seattle-Bellevue-Everett Metropolitan Area having by far

the highest cost of living among the Washington cities.

 

            The ACCRA Cost of Living Index for the second quarter of

1995 shows the following composite cost of living comparisons:

 

Seattle-Bellevue-Everett 120.3

Spokane 105.9

Bellingham 103.2

Tacoma 102.6

Yakima 106.0

 

The Union cites Employer Exhibit 32, an exhibit adjusted for cost

of living differences, as further evidence Snohomish County has the

lowest paid corrections officers of any county in the state, after

the reguired adjustment for cost of living is calculated.  Employer

Exhibit 32 shows that Snohomish County officers lag fully 22%

behind Pierce County officers.

 

            Employer Exhibit 32 is extremely persuasive of the need

for a raise above COLA adjustments.  First, the Union asserts that

the Arbitrator must evaluate the County's economic exhibits by

keeping in mind they make no adjustments for differences in the

cost of living among the jurisdictions cited by the County.  Since

Snohomish County is part of a metropolitan area, it defies logic to

fail to take into account differences in the cost of living with

such communities as Yakima and Spokane.  Second, Employer Exhibit

4D assumes the County's position on every methodological dispute.

Even if the Arbitrator accepts the County's skewed data, their own

evidence still demonstrates a need to award custody officers a

substantial raise in addition to COLA increases.

 

            Turning to the factor of comparability, the Union submits

that Pierce County and King County are the most directly comparable

jurisdictions.  Pierce County is uniquely probative because it is

the County's southern twin.  Pierce County is a densely populated

part of the Tacoma-Seattle-Everett megalopolis centered around a

large second-tier city (Tacoma, Everett) .  Pierce and Snohomish

Counties play similar roles in the Seattle Metropolitan Area by

providing commuter employees to Seattle and at the same time act as

their