International Association of Machinists And Aerospace Workers

And

City of Milton

Interest Arbitration

Arbitrator:      John H. Abernathy

Date Issued:   05/18/1999

 

 

Arbitrator:         Abernathy; John H.

Case #:              13396-I-97-00285

Employer:          City of Milton

Union:                IAM; Local 160

Date Issued:      05/18/1999

 

 

 

IN THE MATTER OF THE INTEREST                            )           INTEREST

            ARBITRATION                                                        )           ARBITRATOR'S

                                                                                                )

            BETWEEN                                                                 )           OPINION

                                                                                                )

THE CITY OF MILTON, WASHINGTON                        )           AND

                                                                                                )

                                                (City)                                       )           AWARD

AND                                                                                       )           ON THE FOLLOWING

                                                                                                )

INTERNATIONAL ASSOCIATION OF                            )           SUBMITTED ISSUES:

MACHINISTS AND AEROSPACE WORKERS,  )           1.  Wages for Police LODGE NO. 160                                                                                             )                 Officers and Sergeants

                                                                                                )           2.   Retroactivity of any

                                                (Union.)                                   )                 Wage Increase

                                                                                                )           3.   Educational Incentives

                                                                                                )           4.   Overtime work/7(K)

_____________________________________                      )                 Exception.

 

HEARING SITE:      9315 15th Place South Seattle, Washington

 

HEARING DATE:    May 13 and 14, 1998

 

ARBITRATOR:        John H. Abernathy

                                    207 Enders Alley

                                    Ashland, OR 97520

 

 

APPEARING FOR THE CITY:

 

                                    Bruce E. Heller, Attorney at Law

                                    Reed McClure Law Firm, Seattle

 

APPEARING FOR THE UNION:

 

                                    Don Hersey, Business Representative

 

 

BRIEFS RECEIVED:

                                    June 25, 1998

 

 

 

                                                            INTRODUCTION

 

            Pursuant to RCW 41.56.450, the Executive Director of the Public Employment

Relations Commission for the State of Washington declared that in the police bargaining

negotiations between The City of Milton ("City") and International Association of

Machinists and Aerospace Workers, Lodge 160 ("Union") there remained four unresolved

issues (wages, retroactivity, education incentives and overtime work/7(k) exception). The

Executive Director then directed those four issues be submitted to interest arbitrati on.

The parties selected John H. Abernathy to serve as the interest arbitrator.

            Arbitrator Abernathy conducted an Interest Arbitration hearing in this matter on

May 14, 1998 in Seattle, Washington. Business Representative Don Hursey represented

the Union and Mr. Bruce Heller, Attorney at Law, represented the City. It was agreed at

the conclusion of the hearing that each parry would submit a post-hearing brief

postmarked no later than June 15, 1998, with a copy to the other party. This date was

extended to June 22, 1998, by mutual agreement of the parties. The Interest Arbitrator

declared this hearing closed upon the timely receipt of those briefs on June 25, 1998.

            Milton Washington is a city of 5,525 population in an area of 2.2 square miles,

with a total assessed valuation of $2417258,951. The City is located on the King-Pierce

County line, about 25 miles south of Seattle and five miles North of Tacoma The City is

operated under the Mayor-Council form of government, and has an overall employment

compliment of 39 full time and 11 part time employees.

            The Milton Police Department employs 11 full time employees. IAM Local 160

is a labor organization representing two bargaining units within the department: 1) two

non-commissioned support: services personnel who are part of a non-uniformed personnel

unit; and 2) nine commissioned employees in the Police Department - seven police

officers, one detective and one sergeant. Only these nine commissioned employees are

subject to interest arbitration, and it is that bargaining unit which is at impasse The

average length of service of employees in the police commissioned unit as of the date of

the hearing was nine years, excluding the one probationary police officer.

 

                                    SUMMARY OF CURRENT NEGOTIATIONS

 

            A labor agreement between the parties covering this unit of employees was set to

expire December 31, 1996. Negotiations toward a successor contract began in April 1996

with District Lodge 160 Business Representative Don Hursey bargaining for the Union

and then-Mayor Leonard Sanderson bargaining for the City. Historically, although the

parties had not been eligible for interest arbitration prior to July 1, 1997, they had

according to the union, employed methodology of comparing cities with one-half to twice

the population and total assessed valuation of the City of Milton. The City denies there

was an agreement to do so. To further narrow their differences, Don Hursey claimed that

he and then-Mayor Sanderson agreed to limit their comparables to a four county area in

Western Washington of Snohomish, King, Pierce, and Kitsap.

            Shortly after the Union presented a set of contract proposals in July 1996, the City

advised the Union that then-Mayor Sanderson would not be conducting the negotiations

on behalf of the City. Thereafter, negotiations were suspended while the City selected a

new negotiator and a new negotiating team; a process which was not completed until

December 1996. The City's new negotiator, Attorney Bruce Heller, met with Don Hursey

in December of 1996. Productive bargaining began in earnest at the turn of the year after

the then pending labor agreement had expired.

            Once negotiations between Hursey and Heller were underway, the City began

proposing comparators beyond the four county area agreed to by Don Hursey and

then-Mayor Sanderson - including cities in Eastern Washington. This altered approach

was employed by the City for the remainder of the negotiations, including mediation, and

remained so until the interest arbitration hearing. At the interest arbitration hearing, the

City no longer offered Eastern Washington Jurisdictions as comparators.

            In addition, after HelIer became the City's chief spokesman, the City began to

utilize a methodology of 33% plus or minus in population and total assessed valuation to

select comparable cities.

            When the parties were unable to reach agreement through their own efforts on all

issues, mediation was requested from PERC and a mediator was assigned. After

mediation and at the recommendation of PERC Mediator Katrina L Boedecker, four

issues were directed to interest arbitration by PERC Executive Director Marvin Schurke

by letter dated September 12, 1997. This interest arbitration resulted.

 

                                                STATUTORY GUIDELINES

 

            Interest arbitration in Washington State is governed by Title 41 RCW: Public

Employment, Civil Service and Pensions. Relevant portions of Title 41 for this interest

arbitration are:

 

            RCW 41.56.030 Definitions - which defines public employees as:

 

            ". . .any officer, board, commission, council, or other person or body acting on

            behalf of any public body governed by this chapter, or any subdivision of such

            public body."

 

            and specifics where interest arbitration for law enforcement officers may be

            used as:

 

            "(a)(i) Until July 1, 1997, law enforcement officers as defined in RCW 41.26.030

            employed by the governing body of any city or town with a population of seven

            thousand five hundred or more and law enforcement officers employed by the

            governing body of any county with a population of thirty-five thousand or more

            (ii) beginning on July 1, 1997, law enforcement officers as defined in RCW

            41.26.030 employed by the governing body of any city or town with a population

            of two thousand five hundred or more and law enforcement officers employed by

            the governing body of any county with a population of ten thousand or more; . . ."1

 

1              This means that the City of Milton (pop. 5525) was not subject to interest

arbitration in its law enforcement bargaining unit prior to July 1, 1997, but was after that

date.

 

            RCW 41 .56.465 requires interest arbitrators to consider the following factors in

making their determination:

 

". . . the legislative purposed enumerated in RCW 41.56.430 and, as additional

standards or guidelines to aid it in reacting 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)(i)    For employees listed in RCW 4156.030(7)(a) through (d),

comparison of the wages, hours, and conditions of employment 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 may not be

considered,

            (d)        The average consumer prices for goods and services, commonly

known as the cost of living;

            (e)        Changes in any of the circumstances under (a) through (d) of this

subsection during the pendency of the proceedings; and

            (f)        Such other factors, not confined to the factors under (a) through (e) of

this subsection, that are normally or traditionally taken into consideration in the

determination of wages, hours, and conditions of employment. For those

employees listed in RCW 41.56.030(7)(a) who are employed by the governing

body of a city or town with a population of less than fifteen thousand, or a county

with a population of less than seventy thousand, consideration must also be given

to regional differences in the cost of living.

            (2)        Subsection (1)(c) of this section may not construed to authorize the

panel to require the employer to pay, directly or indirectly, the increased employee

contributions resulting from chapter 502, Laws of 1993 or chapter 517, Laws of

1993 as required under chapter 41.26 RCW. (1995 c 273 paragraph 2; 1993 c 398

paragraph 3.)"

 

                        APPLICABLE STATUTORY FACTORS IN THIS CASE

 

            Not all of the statutory factors in RCW 41.56.465 were in dispute in this case. For

example the parties agree that the City has the constitutional and statutory authority to

enter into negotiations with the Union and since July 1, 1997, has the authority to submit

unresolved issues to interest arbitration for a binding decision. Therefore, statutory factor

(a) is not in dispute.

            Nor is factor (b). The parties stipulated: 1) to waive the tripartite panel called for

in RCW 41.56.450; 2) that only the four issues certified for interest arbitration remain in

dispute; and 3) that the agreed upon general wage increases for 1997, 1998, and 1999

would be 3%, 3%, and 4% respectively. This stipulation as to the negotiated wage

increases for the three contract years largely renders factor (d) cost of living, of lesser

importance than under circumstances where the general wage increase is an issue in

interest arbitration

            The remaining factors - (c) comparability, (e) changes in circumstances, and (f)

other factors - are the most relevant factors for this dispute. Factors (e) and (f) were not

relied upon to any great degree by either party except for the controversy over what was

the relevant year for comparative data. The most hotly debated of these three factors was

comparability. Each party had a different methodology for arriving at comparable

jurisdiction and each party was critical of the other's methodology and list of comparables.

            The section below summarizes the comparability dispute: first, by presenting

Methodology (the Union's and the City's); Supporting Arguments (Union and City); and

Criticisms (of the other's methodology). Then I shall analyze the comparability evidence

and make findings. These findings will later be applied to the four issues in dispute.

            In addition to these statutory factors I have found it useful in my experience in

factfindings and interest arbitrations over the past 28 years to place the burden of

proof/persuasion on the party seeking a change. To prevail, the party seeking change

must be able to prove that a problem exists and that the proposed change will correct this

problem. I shall use this assignment of burden in this case.

 

                                                            PRELIMINARY ISSUE

                                                COMPARABLE JURISDICTIONS

 

            Statement of the Issue: What jurisdictions should be adopted by the Arbitrator for

comparison to the City of Milton?

 

                        Union's MethodoIogy Used in the Selection of ComparabIes

 

            The Union utilized: (1) population; (2) assessed valuation; and (3) jurisdictions

within close proximity to Milton to select comparable jurisdictions. The Union searched

for all jurisdictions within one-half to twice the population of Milton (-50% to +200%),

the same range in assessed valuation and local geographical proximity to Milton, i.e. cities

within Snohomish, King, Pierce and Kitsap Counties The following table provides the

Union's first list of 17 possible comparable jurisdictions.

 

Rank   Jurisdiction                 County            1995 Assessed Valuation                  1995 Population

1          Enumclaw                   King                $453,253,013                                      10,170

2          Bonney Lake              Pierce              $380,528,732                                      9.085

3          Sumner                       Pierce              $363,969,796                                      7,700

4          Snohomish                  Snohomish      $357,876,663                                      7,495

5          Port Orchard              Kitsap             $257,629,361                                      6,240

6          Stellacoom                  Pierce              $424,849,253                                      6,120

7          Monroe                       Snohomish      $345,276,752                                      6,095              

8          Brier                           Snohomish      $309,127,765                                      6,030              

9          Poulsbo                       Kitsap             $311,817,476                                      5,765  

10        Fircrest                       Pierce              $263,650,746                                      5,375              

11        Arlington                     Snohomish      $336,665,539                                      5,350

12        Milton                         Pierce              $241,258,951                                      5,270

13        Lake Stevens             Snohomish      $228,943,105                                      4,955

14        Fife                              Pierce              $464,886,415                                      4,250

15        Gig Harbor                 Pierce              $327,234,425                                      3,890

16        Buckley                      Pierce              $129,322,203                                      3,870

17        Duvall                         King                $180,383,137                                      3,490              

18        Clyde Hill                   King                $473,081,072                                      3,000

                                                                        $324,986,356                                      5,786

 

 

            The Union narrowed this list to 12 jurisdictions by selecting the 6 entries

immediately greater and the 6 entries immediately smaller than Milton. That resulted in

the following list of 12 possible comparable cities

 

 

Rank   Jurisdiction                 County 1995               Assessed Valuation               1995 Population

1          Stellacoom                  Pierce                          $424,849,253                          6,120

2          Monroe                       Snohomish                  $345,276,752                          6,095

3          Brier                           Snohomish                  $309,127,765                          6,030

4          Poulsbo                       Kitsap                         $311,817,476                          5,765

5          Fircrest                       Pierce                          $263,650,746                          5,375

6          Arlington                     Snohornish                  $336,665,539                          5,350

7          Milton                         Pierce                          $241,258,951                          5,270

8          Lake Stevens             Snohomish                  $228,943,105                          4,955

9          Fife                              Pierce                          $464,886,415                          4,250

10        Gig Harbor                 Pierce                          $327,234,425                          3,890

11        Buckley                      Pierce                          $129,322,203                          3,870

12        Duvail                         King                            $180,383,137                          3,490

13        Clyde Hill                   King                            $473,081,072                          3,000

                                                                                    $335,498,707                          4,881

 

            The Union further refined this list by deleting Stellacoom (because police officers