BILL ANALYSIS Ó
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Date of Hearing: April 22, 2015
ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
Roger Hernández, Chair
AB 357
Chiu - As Amended April 16, 2015
SUBJECT: Employment: work hours: Fair Scheduling Act of 2015
SUMMARY: Enacts the Fair Scheduling Act of 2015 to provide
predictable work schedules to covered employees, as specified,
in addition to other requirements. Specifically, this bill:
1)Requires a "food and general retail establishment" to provide
its employees with at least two weeks' notice of their work
schedules.
2)Defines a "food and general retail establishment" to mean a
retail sales establishment that has a physical location with
in-person sales, including, but not limited to, a food retail
store, a grocery store, a general merchandise store, a
department store, and a health and personal care store, meets
all of the following:
a) Has 500 or more employees in this state.
b) Has 10 or more other such retail sales establishments
located in the United States.
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c) Maintains two or more of the following:
i) A standardized array of merchandise.
ii) A standardized facade.
iii) A standardized decor and color scheme.
iv) Uniform apparel.
v) Standardized signage.
vi) A trademark or a service mark.
3)Excludes from the definition of "food and general retail
establishment" an online retailer that does not have a
physical location with in-person sales in this state, or a
franchise that does not meet the aforementioned criteria.
4)Provides that this requirement does not apply to specified
employees who are exempt from the payment of overtime under
existing law.
5)Provides that a food and general retail establishment shall
provide an employee with the following compensation, per
shift, for each previously scheduled shift that the food and
general retail establishment moves to another date or time or
cancels, and each previously unscheduled shift that the food
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and general retail establishment requires an employee to work:
a) One hour of pay at the employee's regular hourly rate if
less than seven days' notice but at least 24 hours' notice
is given to the employee.
b) Two hours of pay at the employee's regular hourly rate
for each shift of four hours or less if less than 24 hours'
notice is given to the employee.
c) Four hours of pay at the employee's regular hourly rate
for each shift of more than four hours if less than 24
hours' notice is given to the employee.
6)Provides that the aforementioned compensation requirement
shall not apply for shifts for which the employee is
compensated with reporting time pay as required by any wage
order of the Industrial Welfare Commission.
7)Provides that the aforementioned compensation requirement
shall not apply to changes in the scheduling of rest periods,
recovery periods, or meal periods.
8)Requires a food and general retail establishment to provide an
employee with the following compensation for each on-call
shift for which the employee is required to be available but
is not called in to work:
a) Two hours of pay at the employee's regular hourly rate
for each on-call shift of four hours or less.
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b) Four hours of pay at the employee's regular hourly rate
for each on-call shift of more than four hours.
9)Provides that the aforementioned compensation requirement
related to on-call time shall not apply to on-call time that
is required to be compensated as hours worked for which the
employee is in fact compensated under existing law.
10)Establishes exceptions to these compensation requirements
under any of the following circumstances:
a) Operations cannot begin or continue due to threats to
employees or property, or when civil authorities recommend
that work not begin or continue.
b) Operations cannot begin or continue because public
utilities fail to supply electricity, water, or gas, or
there is a failure in the public utilities or sewer system.
c) Operations cannot begin or continue due to an act of God
or other cause not within the food and general retail
establishment's control, including, but not limited to, an
earthquake or a state of emergency declared by a local
government or the Governor.
d) Another employee previously scheduled to work that shift
is unable to work due to illness, vacation, or
employer-provided paid or unpaid time off required by
existing law when the food and general retail establishment
did not receive at least seven days' notice of the other
employee's absence.
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e) Another employee previously scheduled to work that shift
has not reported to work on time, is fired, sent home, or
told to stay at home as a disciplinary action.
f) The food and general retail establishment requires the
employee to work overtime, such as mandatory overtime.
g) The employee trades shifts with another employee or
requests from the food and general retail establishment a
change in his or her shift, hours, or work schedule.
11)Requires the Labor Commissioner shall promulgate all
regulations and rules of practice and procedures necessary to
carry out the provisions of this bill.
12)Specifies that this bill shall not be construed to prohibit a
food and general retail establishment from providing greater
advance notice of an employee's work schedule or changes in an
employee's work schedule than what is required by this bill.
13)Prohibits a food and general retail establishment from
discharging or discriminating against an employee because he
or she is any of the following:
a) A person who receives CalWORKs cash aid.
b) A parent, guardian, or grandparent who has custody of
one or more children who receive CalWORKs cash aid.
c) A person who receives CalFresh food assistance.
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14)Requires a food and general retail establishment to allow an
employee be absent from work without pay for up to eight hours
twice a year, upon request, to attend any required
appointments at the county human services agency.
15)Provides that as a condition of taking such time off, the
employee shall give the employer reasonable advance notice of
the employee's intention to take time off, unless the advance
notice is not feasible.
16)Prohibits an employer from taking any action against an
employee when an unscheduled absence occurs due to a required
appointment at the county human services agency if that
employee, within a reasonable time, provides documentation to
the employer documenting the required appointment.
17)Prohibits sanctions from being applied upon a recipient of
CalWORKs for failure or refusal to comply with CalWORKs
program requirements if the employment or offer of employment
fails to comply with these provisions.
18)Makes other related and conforming changes.
19)Contains legislative findings and declarations.
FISCAL EFFECT: Unknown
COMMENTS: According to the author, unpredictable scheduling
practices and last-minute work schedule changes cause workers
who are already struggling with low wages to live in a constant
state of insecurity about when they will work or how much they
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will be paid on any given day. Therefore, this bill will
provide food and retail workers in California with the right to
schedule predictability and protect workers in a number of
important ways.
This bill would enact the Fair Scheduling Act of 2015, and is
based on an ordinance recently enacted in San Francisco.
As an initial matter, the bill makes the following legislative
finding and declarations:
More than one-half of food and general retail store
employees nationally receive their work schedules one week
or less in advance.
According to a recent survey of employees at chain
stores and large stores, only 40 percent of those surveyed
have consistent minimum hours per week and the vast
majority of employees find out from a supervisor if they
are needed for the on-call shift a mere two hours before
the shift starts. Retail industry research in New York City
found that more than one-half of family caregivers in the
retail industry are required to be available for on-call
shifts, forcing them to arrange for child or elder care at
the last minute.
Women are also more likely than men to work part time
and experience unpredictability in their work schedules;
one study found that women were 64 percent of the frontline
part-time workforce among retail workers.
Unpredictable scheduling practices and last-minute work
schedule changes cause workers who are already struggling
with low wages to live in a constant state of insecurity
about when they will work or how much they will earn on any
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given day. These practices also make it hard for employees
to plan their finances and to plan for and obtain child
care. These practices also prevent part-time employees from
pursuing educational opportunities or holding a second or
third job that those workers may need to make ends meet.
According to census data, since 2006, the number of
"involuntary part time employees" in California nearly
tripled to 1,100,000 employees. According to the federal
Bureau of Labor Statistics, less than one-half of the
retail workforce nationwide works full time, and the number
of those working fewer than 20 hours per week has grown by
14 percent in the past decade.
According to a survey conducted in 2014 of workers who
sell food in California, the largest producer of food in
the United States, they are twice as likely as the general
populace to be unable to afford sufficient quantities of
the food they sell or the healthy kinds of food their
families need, despite the financial health of the food
retail industry. According to this same survey, workers who
were Black or Latino were far more likely to be sent home
early with no pay, to have a shift canceled on the same day
it is scheduled, to not be offered a lunch break, or not be
paid for all hours worked.
For these reasons, to ensure family and financial
stability for a vast segment of California's workforce,
those employed by food and general retail establishments
should be afforded some predictability and dignity in how
they are scheduled to work.
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Brief Background on "Unstable and Unpredictable" Work Schedules
A recent report<1> by the Center for Law and Social Policy and
others states that unpredictable and unstable work scheduled
leave many low-wage workers in a constant state of economic
instability and personal turmoil. Unfortunately, for a growing
number of employers, these scheduling practices are becoming
business as usual.
The report describes the extent and scope of the problem as
follows:
"With the rise of what is sometimes called "just-in-time
scheduling," managers are expected to carefully control the
relationship between consumer demand and expenditures on
wages. If customer traffic or sales seem to be lagging on a
given day, the expectation is that immediate changes to
workers' hours should ensue. Just-in-time scheduling practices
are part of larger trends in business practices - trends that
--------------------------
<1> "Tackling Unstable and Unpredictable Work Schedules," Center
for Law and Social Policy, Retail Action Project, and Women
Employed (2014).
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are increasingly accepted as the norm in hourly-wage, service
sector industries. These practices disproportionately affect
low-income workers, who are already vulnerable financially.
Just-in-time scheduling contributes to workers' income
instability, making it difficult to make ends meet; it may
threaten their eligibility for government income supports; and
because workers may not always be scheduled for enough hours
to qualify, it may limit their eligibility to claim
firm-provided benefits like health insurance and sick days. In
their rush to cut costs, many corporations are adopting
business practices that seriously compromise workers'
well-being.
While workers feel pressure on their pocketbooks and strain on
their home lives, front-line managers are being pressured too.
In the retail industry, managers are often evaluated on
whether they meet targets for payroll as a percentage of
sales. With minimal control over sales, managers move quickly
to decrease staffing levels when sales go down. In a study of
low-level, non-production jobs at major US corporations in the
retail, transportation, hospitality, and financial services
industries, researchers found that managers at all firms
experienced pressure and responded by "scheduling to demand."
Across industries, employers have adopted labor strategies
that "shift risk from the corporation onto workers, bringing
with it instability in hours and income." For example, one
study found that restaurant workers could be scheduled with a
start time but no end time. Workers were instead scheduled as
"12 BD." This means that a worker would arrive at work at noon
and then leave when "business declined" or BD. That could be
anytime and at the discretion of the management.
Employers now also have technological tools to help manipulate
workers' schedules in response to changes in demand. Recent
news reports indicate an increasingly widespread use of
software created by such companies as Kronos Inc. and Dayforce
to "optimize schedules" by breaking them down into small
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increments of time and by tracking factors such as sales and
(as in the case of Jamba Juice) weather patterns. In other
words, the software creates schedules that cut costs, but are
highly unpredictable for workers."
The same report describes the impact of scheduling changes on
workers as follows:
"While paying bills and taking care of family members are high
on the list of challenges that workers in lower-wage jobs
experience when they are subject to erratic scheduling
practices, the harm they face does not stop there. Workers
experience adverse health effects, have difficulty finding and
keeping childcare arrangements, face transportation obstacles,
have trouble going back to school to advance their education,
and experience considerable overall stress and strain on
family life. Since their schedules fluctuate so much, they
can't predict the size of their paychecks. Communities suffer,
too, when workers can't afford to buy groceries or other goods
from neighborhood businesses. Even the employers that adopt
volatile scheduling practices that contribute to these
problems may face negative repercussions, as they cope with
the significant expenses associated with high rates of
turnover and low morale. Moreover, consumers are increasingly
wary of spending their money at businesses that treat their
workers poorly. The ripple effects of unstable and
unpredictable scheduling are felt in the lives of individuals,
in communities, and throughout the economy?
?Such scheduling practices are more than simply inconveniences
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for workers. They have serious effects on individuals and
families, are linked to adverse business consequences, and
result in broad economic costs. Unpredictable and unstable
work schedules may contribute to work-family challenges and
employee stress, as well as marital strife and poor school
performance among these workers' children. Workers with little
control over their schedules and hours struggle to arrange
childcare and transportation and may have difficulty
scheduling doctor's appointments for themselves and their
families, contributing to weaker health outcomes.
Because they are unable to count on a set number of hours per
week, many workers simply cannot make ends meet. For these
workers, despite having jobs that should ostensibly enable
them to pay the bills, public assistance often becomes
necessary."
ARGUMENTS IN SUPPORT
This bill is co-sponsored by the United Food and Commercial
Workers Western States Council and the Western Center on Law and
Poverty. They make the following arguments, among others, in
support of this bill:
"Status Quo Scheduling Allows Employers to Exploit Worker's
Unpaid Time - More than half of food and general retail store
employees nationally receive their work schedules one week or
less in advance. According to a recent survey of employees at
large retail and grocery stores, only 40% of those surveyed
have consistent minimum hours per week and the vast majority
of employees find out from a supervisor if they are needed for
the on-call shift a mere two hours before the shift starts.
Spending unpaid time in limbo, pending a call from her
employer, low-wage workers are less able to spend their unpaid
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time freely and undermined if they wish to use the time at a
second or third job or advancing their future job
opportunities through vocational training or post-secondary
education.
Fair Scheduling Helps Parents be Accountable to Children and
Family Obligations Unpredictable scheduling practices and
last-minute work schedule changes cause workers who are
already struggling with low wages to live in a constant state
of insecurity about when they will work or how much they will
be paid on any given day. The instability of day-by-day
scheduling not only makes it difficult for employees to plan
their finances, it also makes it difficult to secure and
maintain child care and contributes to parental stress, family
instability, and has been documented as resulting in poor
school performance among these workers' children?
Fair Scheduling Helps Workers Keep Child Care Placements &
Their Children Get AheadAccording to a report by Child Care
Aware America, the average cost of full-time childcare ranges
from $4,000 to $1600 annually per child. The National Women's
Law Center (NWLC) says that there is only one child care slot
for every child who needs on. If an hourly wage earner is
fortunate enough to secure a placement at a child care
provider, last minute changes in work schedules can put that
placement at risk?
Fair Scheduling Supports Work and Earnings - During recent
legislative debates, opponents to legislation that would raise
the wage claimed that increasing the wage by a dollar
increment would not change the life conditions of workers who
lived below the poverty line and that the debate over the wage
increase was misplaced. Instead, they argued, that we should
focus on how to help workers advance to better jobs. Without
fair scheduling, low-income workers are stuck with their
current job and wage. They are less able to pursue vocational
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or post-secondary education or to pursue opportunities to earn
more money through self-employment or a second job. Instead,
erratic and unpredictable schedules contribute to wage
instability, which leads workers
While some in the business community may argue that this
policy change is an overreach, researchers have documented the
business case for schedule fairness policies. In fact, several
large retail and food employers have voluntarily begun moving
to a 2-week fair scheduling policy. However, employees should
not have to depend on the voluntary decisions of their
employer(s) in order to be afforded the very necessary right
of having advance notification of their schedule and
compensation for last minute changes. If this policy change
is possible, and recent announcements prove that it is, then
it should be required so that workers can depend on a
job-market that empowers them to manage their family and
community obligations and to pay their bills.
Fair Scheduling Protects Women and Minorities from Disparate
Treatment - Women and workers of color are more likely to be
low-wage hourly workers and they are more likely to be
impacted by scheduling abuses. Research shows that Black and
Latino workers work more shift-work and also experience more
cancelled and shortened shifts than their white counterparts.
These policies contribute to the fact that black men with full
time jobs are paid just 76.3 cents for every dollar their
white counterparts receive; for black women, the figure is
84.6 cents for every dollar a white woman is paid. Lack of
ability to plan ahead also prevents full time work,
contributing to the doubling of women workers who are employed
part-time though desiring full-time work since the recession."
With respect to the portion of the bill dealing with public
assistance, the Western Center on Law and Poverty argues that
fair scheduling can protect workers when they are forced to
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apply for public assistance. When workers income falls short,
or when they fall out of the job market due to inability to find
childcare or transportation to comply with on-call work demands,
they are often forced to seek food or basic needs assistance
through California's safety-net programs. In fact, according to
the Center on Budget and Policy Priorities, 40 percent of
California's food stamp recipients live in working families.
Ironically, these workers face additional barriers of finding
time to apply and certify their eligibility for the federal food
benefits they are entitled to as low-income Americans because of
their inability to schedule unpaid time off to attend to the
paperwork and requisite interviews. In fact, California, with
more poor workers eligible for food stamps than any other state,
also ranks the lowest in the percent of eligible poor workers
receiving these federally funded benefits.
ARGUMENTS IN OPPOSITION
A coalition of employers, including the California Chamber of
Commerce and the California Retailers Association, opposes this
measure and argues that it represents a one-size fits all
mandate on only California retailers, will significantly
increase such employers cost of doing business, and will limit
their opportunity to provide flexibility to employees as well as
offer additional hours of work, as doing so will expose the
employer to litigation and statutory penalties.
Opponents argue that this bill creates significant layering of
penalties against employers for schedule changes. They state
that although the bill provides limited exceptions to the
application of these penalties for schedule changes, such as
when operations cannot begin due to an Act of God or utilities
are not working, the scope of when the penalties will apply is
significant. They contend that employers are already faced with
significant penalties, mandated additional compensation, and
higher minimum wage rates. This bill would layer more penalties
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on an employer who is already compensating the employee for
schedule changes, as well as hours worked. Financially
punishing an employer for responding to last minute business
demands or, worse, for offering an employee more hours of work
is unfair and penalizes the employer just as much as employees.
Opponents also argue that this bill creates ambiguity regarding
"required" versus "voluntary" employee schedule changes. As
they state:
"[This bill] states that an employer shall pay an employee
penalties for unscheduled changes the employer "requires" an
employee to work. The term "requires" is ambiguous as to
whether it includes only those schedule changes that (1) the
employer actually mandates the employee to work or suffer
adverse employment action; or (2) a schedule change that the
employer offers the employee, and the employee individually
feels pressured or compelled to work and therefore consents.
For example, if an employer suggests it really needs
additional help to cover a shift at a restaurant as a large of
customers has just arrived and is the employee available to
come in, is that enough to satisfy the "required" element of
[this bill]?
Ambiguity regarding similar terminology such as "provides" has
created more than a decade of significant litigation for
California only employers regarding the triggering of
additional compensation for employees with regard to meal
periods and is therefore an important distinction. See
Brinker Restaurant Corporation v. Superior Court, 53 Cal.4th
1004 1039 (2012) (defining "provide" to mean a reasonable
opportunity for an employee to take a 30-minute uninterrupted
meal period that is not discouraged or impeded by the
employer)."
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On a related point, they argue that this bill discourages
employers from offering additional work to part-time employees:
"Under [this bill], if additional hours of work become
available after an employer has issued the schedule, and the
employer offers that additional work to a part-time employee,
[this bill] penalizes the employer. Specifically, if the
employee feels "required" to work the previously "unscheduled"
offer of work, the employer would be forced to pay the
employee not only compensation for hours worked, but also an
additional four hours of compensation at the employee's
"regular hourly rate." Such a penalty discourages employers
from offering additional hours of work to part-time employees,
thereby ultimately harming employees who are working
part-time."
Opponents also object to provisions of the bill that they
contend creates a new, protected classification of employees.
Under this bill, an employer would be prohibited from
discriminating against or discharging any employee who falls
within one of three protected categories. Combined with the
new, unlimited leave referenced above, this precludes an
employer from taking any conservative action against an employee
who regularly misses work on a daily, weekly or monthly basis to
attend an appointment, for threat of discrimination or
retaliation litigation. In addition, they argue that there is
no evidence of systematic employment discrimination against
employees on this basis that would justify a new, protected
classification in California law. As such, this protected
classification will simply lead to an increase in litigation as
it provides a new basis upon which to sue an employer who takes
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an adverse employment action for a legitimate reason against an
employee who falls within one of these protected categories.
They also argue that this bill subjects employers to multiple
threats of extensive litigation:
"In addition to litigation under PAGA, Labor Code Section
2699, an employee could also threaten an unfair competition
claim under Business and Professions Code Section 17200, as
well as a common law wrongful termination claim. Increasing
the cost of doing business on all employers who engage in
retail activity with the "additional pay" mandate, as well as
subjecting them to multiple threats of litigation, is
detrimental to the economy and the ability for businesses to
thrive in this state.
Notably, [this bill] references the various levels of
penalties for schedule changes as "compensation," even though
it is not compensating an employee for actual hours worked.
This choice of term is not inconsequential, as it potentially
triggers a three year statute of limitation to bring a civil
action as opposed to a one-year statute of limitation for the
penalty imposed. See Murphy v. Kenneth Cole Productions,
Inc., 40 Cal.4th 1094 (2007) (holding premium pay for missed
meal period is subject to three year statute of limitations
versus one-year statute of limitations for penalties)."
Finally, opponents argue that the San Francisco ordinance has
not even gone into effect yet to determine the consequences of
this policy. They state that in December 2014, the San
Francisco Board of Supervisors passed the "Retail Workers Bill
of Rights" that included a "fair scheduling" mandate, similar to
that proposed in this bill. Mayor Ed Lee did not sign this
ordinance, which will not go into effect until July 3, 2015.
They state that San Francisco has yet to see the consequences
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either intended or unintended from the impact of its local
ordinance mandating penalties for schedule changes. Given this,
they argue that it is premature to impose this broad and
punitive measure on all "food and general retail establishments"
in California, especially those areas with high unemployment
rates.
COMMITTEE STAFF COMMENT
In addition to the arguments mentioned above, opponents contend
that, despite the exceptions contained in the bill, employers
will still be subject to liability under the Labor Code Private
Attorney General Act (PAGA) for any change in employee
schedules. They argue that this bill states that an employer
"shall" provide no less than two weeks' notice of an employee's
schedule. Failure to provide two weeks' notice, no matter the
reason, will independently create a PAGA violation and subject
the employer to a representative action. Specifically, even
though this bill would not assess penalties for an employer who
has to cover a shift at the last minute because another employee
calls in sick or works overtime, it is still a change in an
employee's schedule with less than two weeks' notice and
therefore a Labor Code violation subject to PAGA penalties. The
threat of PAGA litigation will eliminate an employer's ability
to provide any flexibility to their employees and will subject
the employer to penalties for accommodating requested time off,
sick leave, vacation, trading of employee shifts, etc.
In response to this concern, the author has agreed to amend
proposed Labor Code Section 518(h) to read as follows:
(h) The requirements in subdivision (c) and (f) shall not
apply, and an employer shall not be deemed to have violated
subdivision (b), under any of the following circumstances:
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REGISTERED SUPPORT / OPPOSITION:
Support
9to5 National Association of Working Women, CA
American Association of University Women
American Federation of State, County and Municipal Employees
Better Opportunity Bill
California Alliance for Retired Americans
California Black Health Network
California Employment Lawyers Association
California Labor Federation, AFL-CIO
California Nurses Association
California Partnership
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California Professional Firefighters
California School Employees Association
California Teachers Association
Center for Law and Social Policy
Child Care Law Center
Coalition of California Welfare Rights Organizations
Community Food and Justice Coalition
Consumer Attorneys of California
Courage Campaign
Equal Rights Advocates
Hunger Action Los Angeles
National Association of Social Workers, CA Chapter
National Council of Jewish Women
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Office & Professional Employees International Union, Loca 29
Professional Association for Childhood Education
River City Food Bank
Sacramento Hunger Coalition
San Francisco Living Wage Coalition
SEIU California
St. Anthony's Foundation
Supervisor John Leopold, County of Santa Cruz
UFCW Western States Council (sponsor)
Western Center on Law and Poverty (sponsor)
Western Regional Advocacy Project
Opposition
Agricultural Council of California
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Alhambra Chamber of Commerce
AutoNation
Brawley Chamber of Commerce
Building Owners and Managers Association California
California Association of Bed and Breakfast Inns
California Association of Nurseries & Garden Centers
California Attractions and Parks Association
California Bankers Association
California Business Properties Association
California Chamber of Commerce
California Employment Law Council
California Grocers Association
California Hotel and Lodging Association
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California League of Food Processors
California Manufacturers and Technology Association
California Mortgage Bankers Association
California New Car Dealers Association
California Restaurant Association
California Retailers Association
California Travel Association
Camarillo Chamber of Commerce
Cerritos Regional Chamber of Commerce
Civil Justice Association of California
El Centro Chamber of Commerce and Visitors Bureau
Fairfield-Suisun City Chamber of Commerce
Fullerton Chamber of Commerce
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Gateway Chambers Alliance
Goleta Valley Chamber of Commerce
Greater Fresno Area Chamber of Commerce
International Council of Shopping Centers
International Franchise Association
Irvine Chamber of Commerce
Lodi Chamber of Commerce
Monterey Peninsula Chamber of Commerce
NAIOP - Commercial Real Estate Development Association
National Association of Theatre Owners of California/Nevada
National Federation of Independent Business
North Lake Tahoe Chamber of Commerce
Orange County Business Council
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Oxnard Chamber of Commerce
Palm Desert Area Chamber of Commerce
Rancho Cordova Chamber of Commerce
Redondo Beach Chamber of Commerce and Visitors Bureau
Retail Industry Leaders Association
Ripon Chamber of Commerce
San Francisco Chamber of Commerce
San Gabriel Valley Legislative Coalition of Chambers
Santa Clara Chamber of Commerce & Convention-Visitors Bureau
Santa Maria Valley Chamber of Commerce Visitor and Convention
Bureau
Simi Valley Chamber of Commerce
South Bay Association of Chamber of Commerce
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Southwest California Legislative Council
Southwest California Legislative Council
TechAmerica
The Chamber of the Santa Barbara Region
Torrance Area Chamber of Commerce
Wine Institute
Analysis Prepared by:Ben Ebbink / L. & E. / (916) 319-2091