BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1164
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          Date of Hearing:  April 23, 2013

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                  AB 1164 (Lowenthal) - As Amended:  March 21, 2013

                              As Proposed to be Amended
           
          SUBJECT  :  Liens: Employees and Workers

           KEY ISSUE  :  SHould an EMPLOYEE be authorized to record and  
          enforce a lien against an employer's real or personal property,  
          and other property as specified, for unpaid wages? 

           FISCAL EFFECT  :  As currently in print this bill is keyed fiscal.  


                                      Synopsis 

          This bill would permit an employee to record and enforce a lien  
          against an employer's real or personal property for unpaid  
          wages, and against any property upon which the employee has  
          bestowed labor.   Under existing law, a person who contributes  
          labor, skill, or services to a work of improvement has the right  
          to record a "mechanic's lien" on the improved property.  This  
          bill would effectively extend this law by permitting an employee  
          to record a lien against any property that the employer owns for  
          failure to pay wages.  The lien could attach to any property,  
          real or personal, that the employer owns, and it would not  
          necessarily be restricted to the property upon which the  
          employee's labor was bestowed.  (However, the author will take  
          an amendment in this Committee that will generally exempt  
          residential properties.)  The wage lien would be extinguished if  
          the employee did not record notice of the lien within one year  
          of ceasing to work for the employer.  With regard to a lien on  
          real property, the employee must record notice of the lien in  
          the county in which the property is situated; with regard to a  
          lien on personal property, the employee must file notice of the  
          lien with the Secretary of State.  In either case, the notice  
          must be executed under penalty of perjury and explain the basis  
          of the amount owed.  Finally, the wage lien would take  
          precedence over all other liens, claims, or encumbrances  
          perfected after the filing or recording of notice, and, as to  
          the first $50,000 of the amount claimed, the wage lien would  
          take precedence over all other liens, claims, or encumbrances  








                                                                  AB 1164
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          perfected prior to the date of filing or recording notice of the  
          lien.  However, under this latter "super priority" provision  
          (taking precedence over prior perfected liens, the wage lien  
          would not take precedence over a tax or other government lien, a  
          purchase money mortgage, or other liens that arise of the  
          performance of labor, including mechanics liens.  The bill is  
          supported by several labor groups and opposed by employer and  
          business groups.  The author will take amendments in this  
          Committee which will exempt residential properties, as  
          specified, for the reasons described below.  The summary below  
          reflects these amendments.  While these amendments address some  
          of the concerns raised by the opposition, they do not remove the  
          opposition. 

           SUMMARY  :  Authorizes an employee to record and enforce a wage  
          lien upon an employer's property, as specified.  Specifically,  
           this bill  :  

          1)Provides that an employee shall have a lien for the full  
            amount of any wages, other compensation, and related penalties  
            and damages owed to the employee on the following property:

               a)     All property of the employer, including any  
                 after-acquired property.  However, as proposed to be  
                 amended a lien shall not apply to the employer's personal  
                 residence, except as specified. 

               b)     The property upon which the employee bestowed labor,  
                 provided that the amount of the lien on this property  
                 shall be equal to the amount of wages, compensation, and  
                 related penalties and damages accrued during the time the  
                 employee bestowed labor on that specific property.   
                 However, as proposed to be amended, the lien would not  
                 apply to the personal residence of a person who is not  
                 the employer.

          1)Specifies that the lien amount shall include unpaid wages,  
            other compensation, penalties and damages available under the  
            Labor Code, prejudgment interest, and the costs of filing and  
            serving the lien.  The amount of compensation that may be  
            claimed as a lien includes all wages agreed to be paid to the  
            employee, but not less than the amount required by law,  
            including "employer payments" as described in Labor Code  
            Section 1773.1.  An employee's lien upon personal property  
            shall be limited to a security interest, as defined. 








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          2)Specifies who shall have standing to bring an action and  
            provides that the lien authorized by this bill is in addition  
            to any other lien rights held by the employee and shall not be  
            construed to limit these rights. 

          3)Provides that the lien authorized by this bill shall be  
            permanently extinguished unless a notice of lien is recorded  
            and served within one year of the date that the employee  
            ceased working for the employer.  Requires the employee to  
            commence action to enforce the lien within 180 days of filing  
            or recording notice of the lien. 

          4)Requires, with regard to a lien on real property, the employee  
            to record notice of the lien with the county recorder in the  
            county in which the property is located, and further requires  
            the lien to be executed under penalty of perjury and include  
            specified information. 

          5)Requires, with regard to a lien on personal property, the  
            employee to file a notice of lien with the Secretary of State,  
            as specified, and further requires the notice to be executed  
            under penalty of perjury and include specified information. 

          6)Specifies that in order to enforce a lien authorized by this  
            bill, the employee shall demonstrate in a civil action or in  
            an administrative proceeding before the Labor Commissioner,  
            that he or she is owed wages, compensation, or penalties and  
            damages. 

          7)Provides that the employee is entitled to court costs and  
            reasonable attorneys' fees for filing a successful action to  
            enforce the lien. 

          8)Grants to a lien authorized by this bill precedence over all  
            other liens, claims, or encumbrances perfected after the date  
            that the notice of the lien is filed or recorded and makes the  
            lien effective against the estate of the employer, or any  
            subsequent purchaser of the property subject to the lien.  In  
            addition, as to the first $50,000 of the amount claimed, the  
            lien authorized by this bill takes precedence over all other  
            liens, claims, or encumbrances perfected prior to the date of  
            filing or recording of the notice of lien, except for tax or  
            other government liens, purchase money mortgages, and liens  
            that arise from the performance of other labor, including  








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            mechanics liens. 

           EXISTING LAW  : 

          1)Gives mechanics, persons furnishing materials, artisans, and  
            laborers of every class the right to file a lien upon the  
            property upon which they have bestowed labor or furnished  
            material for the value of such labor and material.  Requires  
            the Legislature to provide, by law, for the speedy and  
            efficient enforcement of such liens.  (Article XIV Section 3  
            of the California Constitution.) 

          2)Sets forth the obligations, rights, and remedies of those  
            involved in a construction project with regard to mechanics  
            liens and generally regulates the conditions under which a  
            mechanics lien may be enforced.  (Civil Code Sec. 8400 et  
            seq.)

          3)Recognizes prejudgment wage liens against property as a remedy  
            in certain industries, including agriculture (Civ. Code   
            3061.5-3061.6), logging (Civ. Code  3065), and mining (Civ.  
            Code  3060).

          4)Permits an employee to file a claim with the Department of  
            Labor Standards Enforcement for unpaid wages, compensation,  
            and penalties.  Authorizes the State Labor Commissioner to  
            investigate complaints, hold hearings on a claim, and issue an  
            appropriate order, decision, or award, and allows either party  
            to appeal an order, decision, or award made by the  
            Commissioner to the appropriate civil court.  (Labor Code  
            Sections 98 through 98.2.) 

           COMMENTS  :  According to the author, "California has one of the  
          highest rates of wage theft in the country" and cites studies  
          which claim that 30% of low-wage workers in Los Angeles are paid  
          less than the minimum wage and that 80% are not paid for  
          overtime.  Making matters worse, the author claims, it can take  
          up to two years to go through the Labor Commissioner or civil  
          court to file a wage claim.  If the business closes or goes  
          bankrupt before the employee wins his or her case, there is  
          often nothing left to collect.  This bill would, subject to  
          certain exemptions, permit a worker who has not been paid his or  
          her wages to file a lien against the employer's real or personal  
          property, or a property upon which the employee bestowed labor  
          for the amount of wages or other compensation owed.  As proposed  








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          to be amended in this Committee, the lien would not apply to a  
          personal residence, except where the employee bestowed labor  
          that benefitted the personal residence of the offending  
          employer. 

           The Problem of "Wage Theft"  :  Various recent studies have  
          highlighted concerns about alleged widespread "theft of wages"  
          in the United States and in California, particularly in the  
          underground economy.  For example, in 2009 the Ford Foundation  
          sponsored a study that surveyed 4,387 workers in low-wage  
          industries in the three largest U.S. cities - Chicago, Los  
          Angeles and New York City.  The study revealed that 26 percent  
          of workers in the sample were paid less than the legally  
          required minimum wage, and 60 percent of these workers were  
          underpaid by more than $1 per hour.  In addition, 76 percent of  
          the respondents who worked overtime in the previous week were  
          not paid the legally required overtime rate by their employers.   
          (Broken Laws, Unprotected Workers: Violations of Employment and  
          Labor Laws in America's Cities, Center for Urban Economic  
          Development, National Employment Law Project, UCLA Institute for  
          Research on Labor and Employment (2009).)

          Another study focused on a survey of 1,815 workers in Los  
          Angeles County.  The survey found that low-wage workers in Los  
          Angeles regularly experience violations of basic laws that  
          mandate a minimum wage and overtime pay and are frequently  
          forced to work off the clock or during their breaks.  Other  
          violations documented in the survey include lack of required  
          payroll documentation, late payments, stealing tips, and  
          employer retaliation.  (Milkman, Gonzalez and Narro, Wage Theft  
          and Workplace Violation in Los Angeles: The Failure of  
          Employment and Labor Law for Low-Wage Workers, UCLA Institute  
          for Research on Labor and Employment (2010).)  The survey also  
          revealed that the various forms of nonpayment and underpayment  
          of wages take a heavy monetary toll on workers and their  
          families.  Respondents who experienced a pay-based violation in  
          the previous work week lost an average of $39.81 out of average  
          weekly earnings of $318.00 (or 12.5 percent).  Assuming a  
          full-year work schedule, these workers lost an average of  
          $2,070.00 annually out of total earnings of $16,536.00.  The  
          survey estimated that, in a given week, 654,914 workers in Los  
          Angeles County suffer at least one pay-based violation.   
          Extrapolating from this figure, front-line workers in low-wage  
          industries lose more than $26.2 million per week as a result of  
          employment and labor law violations.








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           Effectiveness of Existing Methods of Recovering Unpaid Wages  :   
          Under existing law, when an employer fails to pay wages due, the  
          employee has the right to file a claim against his or her  
          employer (or former employer) with the Department of Labor  
          Standards Enforcement (DLSE), which is directed by the State  
          Labor Commissioner. The Labor Commissioner has jurisdiction over  
          most private sector employees, except those that are bona fide  
          independent contractors.  In some cases, according to case law,  
          the Commissioner does not have jurisdiction over those working  
          under collective bargaining agreements.  Existing law requires  
          an employee who feels that his or her wages have been wrongly  
          withheld must go through DLSE and according to statutorily  
          prescribed procedures.  (Labor Code Section 98 et seq.)  After  
          conducting an investigation, the Labor Commissioner may hold an  
          administrative conference or hearing, or both.  If a party is  
          unhappy with the Commissioner's decision, it can appeal to the  
          appropriate civil court.  (Labor Code Section 98.2.)  However,  
          the author contends that even where a worker wins a favorable  
          decision, the process of collecting the award is often difficult  
          and ineffective.  Irresponsible employers may have already  
          hidden their cash assets, declared bankruptcy, or otherwise  
          become judgment-proof.  According to the author, state agencies  
          simply do not have the resources to collect wages even where a  
          decision has been rendered in favor of the employee.  Giving  
          employees a "wage lien" - similar to but in many ways broader  
          than the customary "mechanic's lien" - would provide an  
          additional and arguably more effective tool for an employee to  
          recover unpaid wages. 

           Mechanic's Lien Not Available to Most Workers  :  In addition to  
          permitting claims to be filed with the DLSE and Labor  
          Commissioner, the California Constitution gives "mechanics,  
          persons furnishing materials, artisans, and laborers of every  
          class the right to file a lien upon the property upon which they  
          have bestowed labor or furnished material for the value of such  
          labor and material."  To further this end, the state  
          constitution requires the Legislature to provide, by law, for  
          the speedy and efficient enforcement of such liens.   
          Accordingly, provisions of the Civil Code set forth the  
          obligations, rights, and remedies of those involved in a  
          construction project. However, the author claims that the  
          mechanic's lien is inadequate for most workers.  For example, it  
          is generally only available to construction workers (and a few  
          others specially provided for by statute) and it only allows the  








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          worker to place a lien on the property upon which labor was  
          bestowed.  An employee who performed labor that did not entail  
          construction or making an improvement to real property - such as  
          service work, for example - cannot make use of a mechanic's  
          lien.  

           Property Subject to Lien  :  This bill would permit an employee to  
          file a lien for unpaid wages and other compensation against any  
          real or personal property of the employer - though this would  
          not include a personal residence as proposed to be amended -  
          whether the worker bestowed any labor on the subject property or  
          not.  The wage lien provided by this bill, in other words, is  
          not, like a mechanic's lien, a lien against the improvement made  
          to the property.  Rather, it is more akin to a lien against  
          property for an unpaid debt.  In addition - and most  
          controversially from the point of view of the opponents of this  
          measure - the employee could also place a lien on any property  
          upon which he or she bestowed labor, even if that property was  
          not owned by the offending employer.  For example, opponents  
          cite as a possible scenario a situation in which a cable company  
          employee installs cable service in the home of a cable  
          subscriber but then is not paid by the cable company.  In that  
          scenario, the subscribing homeowner would be subject to a lien  
          against his or her property because of the wrongdoing of the  
          cable company.  (As discussed below, as proposed to be amended,  
          this bill would clarify that a lien could not be recorded  
          against a personal residence of someone who was not the  
          offending employer.  However, even as proposed to be amended,  
          the lien could be applied to commercial property, even though  
          the commercial property owner was not the wrong-doing employer.)  
           Finally, the lien could be filed upon both personal and real  
          property.  In the case of real property, the lien would be filed  
          with the county recorder; in the case of personal property, the  
          lien would be filed with the Secretary of State. 

           "Super-Priority" Lien Provisions  :  In addition to giving an  
          employee the right to file a lien to recover unpaid wages, the  
          bill would also give the wage lien precedence over all other  
          liens, claims, or encumbrances  perfected  after the date that the  
          notice of the lien is filed or recorded.  This could mean that a  
          wage lien would take precedence over a notice of another lien  
          that was filed before the wage lien but not yet perfected.   
          Moreover, at least as to the first fifty thousand dollars, the  
          wage lien would take precedence over all other liens, claims, or  
          encumbrances that were perfected  prior to  the filing or  








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          recording of the notice of the wage lien.  However, the wage  
          lien would not have super-priority over a tax lien or other  
          government loan, a purchase money mortgage, or other liens that  
          arise from the performance of labor, including a mechanic's  
          lien.  As noted below, opponents contend that granting  
          super-priority status to wage liens will negatively affect the  
          real estate market and mortgage contracts.  The author and  
          proponents of the bill, on the other hand, argue that priority  
          status is necessary because, unlike other creditors, such as  
          banks, an employee generally has no duty to perform due  
          diligence to make sure the debtor has the capacity to pay a  
          debt.  In addition, the author contends, workers, unlike banks  
          and other business creditors, cannot afford delay in payment of  
          their wages, which are needed to pay rent, buy food, and provide  
          for other necessities. 

           ARGUMENTS IN SUPPORT  :  The Wage Justice Center (WJC), one of the  
          bill's co-sponsors, describes its first-hand experience in the  
          difficulties of attempting to collect wage judgments.  Under  
          existing law, WJC claims, workers either never recover wages or  
          only recover after a period of up to two years.  And this is  
          true even though they have been awarded a favorable ruling from  
          the Labor Commissioner.  WJC points out that the concept of a  
          prejudgment wage lien is not a novel concept, noting that this  
          is afforded to under current California law for construction  
          workers, farm workers, and loggers.  WJC contends that there is  
          "no justifiable reason for limiting this right to only these  
          industries."  

          The California Federation of Labor (CFL) claims that "one of the  
          greatest challenges [it faces] is the widespread wage theft  
          faced by low-wage workers."  Not only do studies suggest that  
          wage theft is becoming more common, CFL claims, but that it has  
          also "become harder to effectively enforce [wage violations] in  
          recent years.  With the rise of subcontracting and the explosion  
          in the use of temporary agencies, it has become harder to track  
          who the real employer is and who to hold accountable."  CFL also  
          contends that businesses in the underground economy have become  
          more adept at hiding assets, and that state agencies lack  
          resources to match ever more sophisticated means of evasion.  In  
          support of this contention the CFL cites a 2004 California State  
          Auditor report which concluded that the Franchise Tax Board was  
          only able to collect about 20% of the worker wage claims it had  
          been assigned. 









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          The California Employment Lawyers Association (CELA) supports  
          this bill for many of the same reasons cited by WJC and CFL, but  
          it adds that "this bill does not expand government or create new  
          wage and hour laws - it enforces what is already on the books.   
          The wage lien is a proven, simple legal tool that costs the  
          state next to nothing.  It creates no new bureaucracies and no  
          new agencies with complicated enforcement procedures."  Instead,  
          workers would simply file a notice with either the County  
          Recorder or the Secretary of State for a fee ranging from $10 to  
          $30.   Like any other prejudgment lien, the wage lien authorized  
          by this bill merely creates "a temporary hold on employer  
          property while a worker proves his or her claim for wages owed."  
           CELA echoes a point made by many other supporters of this  
          measure by noting that liens are not a new concept, but a  
          time-honored and time-tested remedy that are already used by  
          construction workers and farm workers. 

          Dozens of other labor organizations, policy centers, and  
          community groups support this bill for the substantially the  
          same reasons as those noted by WJC, CFL, and CELA. 
           
          ARGUMENTS IN OPPOSITION  :  The California Employment Law Council  
          (CELC) opposes this bill, claiming that it will "permit  
          employees to tie up employers' real and personal property over a  
          slight dispute over unpaid wages" and "will have a devastating  
          effect on the ability of employers to conduct business."  CELC  
          argues that while the bill appears to be patterned to some  
          degree on the existing mechanic's lien law, "the differences  
          between the long-established mechanic's lien and AB 1164 are  
          enormous.  The mechanic's lien law applies to a narrow class of  
          workers who provide labor on specific real property.  The  
          results of the labor almost always result in physical  
          improvements to property which can be seen and verified."  In  
          contrast, CELC contends, "AB 1164 appears to apply to all real  
          property owned by the employer, plus all personal property  
          subject to security interests under the Commercial Code."   
          According to CELC, this measure will allow employees to "impair  
                                                                               title to real and personal property for at least 18 months after  
          the employee ceases employment . . . over unproven allegations  
          of unpaid wages." 

          A broad coalition of business, financial, and employer groups,  
          apparently headed by the California Chamber of Commerce, claim  
          that this "job killer" bill would "cripple California businesses  
          by allowing any employee, employee representative, or Labor  








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          Commissioner to file super priority liens on an employer's real  
          property or any property where an employee 'bestowed labor' for  
          an alleged, yet unproven, wage claim."  The Chamber coalition  
          claims that this "bill would essentially destroy commercial and  
          personal real estate [by allowing] a wage lien to take  
          precedence over almost all other liens or judgments."  The  
          opponents contend that California wage and hour laws are  
          complex, and that the wages and benefits owed can depend upon a  
          number of factors (e.g. the classification of the employee).   
          Thus these disputes often go beyond the simple question of  
          whether the promised wage rate was paid, according to the  
          opposition.  Yet despite this complexity, opponents claim, an  
          employee can file a lien against an employer's property - or  
          even on property owned by someone other than the employer if  
          labor were bestowed upon the property - on the basis of  a mere  
          allegation without providing any evidence that employer violated  
          wage or hour laws.  (However, it should be noted that the bill  
          requires somewhat more than a mere allegation; the notice of  
          lien must be executed under penalty of perjury.)  Opponents  
          contend that because these liens take priority over most other  
          liens - except tax liens, purchase money mortgages, and other  
          wage or mechanic's liens - they will wreak havoc with the real  
          estate industry.  Finally, opponents contend that because this  
          bill permits an employee to record a lien against any property  
          upon which labor was bestowed, it will affect the property of  
          persons other than the employer.  For example, if an employee  
          who installs cable or internet service in a residence is not  
          paid by the cable or internet company, that employee could  
          record a lien against the home where the labor was bestowed,  
          even though the homeowner was not responsible for the employer's  
          failure to pay the employee the wages due.  (As proposed to be  
          amended, this latter concern should no longer be an issue.) 

           PROPOSED AUTHOR AMENDMENTS  :  As noted above, the opposition  
          contends, and the Committee tends to agree, that this measure  
          should make an exemption for personal residences, especially in  
          regards to the provision that permits an employee to record a  
          lien against any property upon which the employee bestowed  
          labor.  This would mean that an innocent homeowner would be  
          subject to a lien because of the wrongdoing of the employer,  
          even though the homeowner had done nothing wrong and had no  
          control over the employer.  In addition, given the special  
          protection that the Legislature has often given to a person's  
          home (e.g. homestead exemptions), this bill would also exempt  
          the personal residence of the offending employer, unless the  








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          labor that was performed by the employee actually conferred a  
          benefit upon the employer's home.  In addition, the bill in  
          print allows the employee to recover all that is due under "the  
          entire compensation package."  Because the meaning of this  
          phrase is not entirely clear, the author will amend the bill to  
          make it specify the employee would have the right to claim all  
          wages promised and other compensation that would qualify as  
          "employer payments" as defined in existing law. 

          Therefore, the author will take the following amendments in this  
          Committee:

              -     On page 2 line 10 after "property." insert:  

                However, if the employer is a natural person, the lien  
                shall not apply to the employer's principal residence,  
                except to the extent that the employee provided labor for  
                the benefit of the employer's household or residence.
                 
                      On page 2 line 11 after "property" insert:  

              -     , other than the principal residence of a person who  
                is not the employer,"
               
               On page 2 line 21-22 delete "the entire compensation  
               package" and insert: 

              -     "all wages"  

           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Hayward Day Labor Center (co-sponsor)
          Koreatown Immigrant Workers Alliance (co-sponsor)
          San Diego Day Laborer Association (co-sponsor)
          SEIU (co-sponsor)
          Teamster's Local 396 (co-sponsor)
          United Service Workers West (co-sponsor)
          The Wage Justice Center (co-sponsor)
          California Employment Lawyers Association 
          California Federation of Labor 
          California Immigrant Policy Center
          California Pipe Trades Council 








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          California State Association of Electrical Workers 
          Center for Policy Initiatives 
          Central American Resource Center
          Centro Laboral de Graton (Graton Day Labor Center)
          Chinese Progressive Association 
          Garment Worker Center
          Institute of Popular Education of Southern California 
          La Raza Centro legal 
          Legal Aid Society - Employment Law Center 
          Maintenance Cooperative Trust Fund 
          National Day Laborer Organizing Network 
          National Employment Law Project 
          San Diego Day Laborers and Household Workers Association 
          UCLA Labor Center 
          Western States Council of Sheet Metal Workers 
          Worksafe 
          One Individual 

           Opposition 
           
          Air Conditioning Trade Association 
          American Council of Engineering Companies California 
          Associated General Contractors 
          Building Owners and Managers Association of California 
          California Association of Health Services at Home 
          California Association of Realtors
          California Bankers Association 
          California Building Industry Association 
          California Business Properties Association 
          California Chamber of Commerce 
          California Chapter of American Fence Association 
          California Farm Bureau Federation 
          California Grocers Association 
          California Independent Grocers Association 
          California Land Title Association 
          California Landscape Contractors Association 
          California League of Food Processors
          California Lodging Industry Association 
          California Manufacturing and Technology Association 
          California Mortgage Bankers Association 
          Camarillo Chamber of Commerce
          East Bay Rental Housing Association 
          El Centro Chamber of Commerce 
          Engineering Contractors Association 
          Flasher Barricade Association 








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          Fullerton Chamber of Commerce 
          Garden Grove Chamber of Commerce 
          Greater Conejo Valley Chamber of Commerce
          Greater Fresno Area Chamber of Commerce 
          Greater Riverside Chambers of Commerce
          International Council of Shopping Centers
          Irwindale Chamber of Commerce 
          Long Beach Area Chamber of Commerce 
          Marin Builders Association 
          NAIOP of California  
          National Federation of Independent Business
          Palm Desert Area Chamber of Commerce 
          Plumbing-Heating-Cooling Contractors Association of California 
          Redondo Beach Chamber of Commerce 
          San Gabriel Coalition of Chambers 
          Santa Clara Chamber of Commerce 
          Simi Valley Chamber of Commerce
          South Bay Association of Chambers of Commerce
          Southwest California Legislative Council 
          Tulare Chamber of Commerce
          Western Electrical Contractors Association 
           
          Analysis Prepared by  :  Thomas Clark / JUD. / (916) 319-2334