BILL ANALYSIS Ó
SB 548
Page A
Date of Hearing: July 8, 2015
ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
Roger Hernández, Chair
SB
548 (De León) - As Amended June 1, 2015
SENATE VOTE: 25-12
SUBJECT: Child care: family child care providers: bargaining
representative.
SUMMARY: Authorizes family child care providers to form, join
and participate in "provider organizations" for purposes of
negotiating with state agencies on specified matters, among
other provisions. Specifically, this bill:
1)Defines "family child care provider" as a child care provider
that participates in a state-funded child care program and is
either of the following:
a) A family day care home provider who is licensed.
b) An individual who meets both of the following:
i) Provides child care in his or her own home or in the
home of the child receiving care.
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ii) Is exempt from licensing requirements.
2)Gives family child care providers the right to form, join, and
participate in provider organizations of their own choosing
for the purpose of being represented.
3)Extends the state action antitrust exemption to the activities
of the family child care providers and their representatives.
This bill also states, however, that the status of family
child care providers as independent business owners does not
change, nor does this bill classify family child care
providers as public employees.
4)Creates a right for family child care providers to form
provider organizations. Child care providers would retain the
right to join or not join such an organization.
5)Requires that, within ten days of receipt of a request from a
provider organization, the State Department of Social Services
(DSS) must make available to that provider organization
information regarding licensed family child care providers,
including each provider's contact information.
6)Requires that, within 30 days of receipt of a request from a
provider organization, the California Department of Education
(CDE), with the assistance of the relevant organization, must
collect information regarding family child care providers,
including each provider's contact information. The provider
organization must bear the reasonable costs of collecting the
information.
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7)Requires that, upon written request of a family child care
provider, the CDE and the DSS must remove the family child
care provider's home address and telephone number from the
above-described lists.
8)Provides that a unit of provider organizations may choose to
designate the provider organization that shall be the
exclusive representative for negotiations with the state. In
order for a unit of provider organizations to be considered
appropriate, the unit must be statewide and include all family
child care providers.
9)Provides that the Public Employment Relations Board (PERB)
must conduct an election to certify the provider organization
as the exclusive bargaining representative. PERB is also
required to receive and act upon challenges, petitions for
unit certification, and other representation issues. A
provider organization petitioning for an election to be
certified is required to include in its petition proof of a 30
percent showing of interest designating the provider
organization to act as the exclusive representative. The
provider organization must pay the reasonable costs of
verifying this showing of interest.
10) Empowers PERB to contract with a neutral third party
to conduct all necessary elections and other representation
requests.
11) Provides that there shall be no more than one
bargaining unit at any time. A certified provider
organization may file a request with the PERB for an election
to add providers to an existing unit.
12) Provides that the child care organization would
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represent all child care providers in negotiations with the
Governor and state agencies on issues that fall within the
child care provider organization's scope of representation.
13) Provide that issues within the scope of
representation include:
a) The administration of laws and regulations governing
licensing for providers.
b) Joint labor-management committees.
c) Contract grievance arbitration.
d) Expanded access to professional development and training
opportunities for providers.
e) Benefits for providers.
f) Payment procedures for child care subsidy programs.
g) Reimbursement rates for providers participating in a
child care subsidy program including, but not limited to,
rate add-ons for providers who complete extra training.
h) Expanded access to and funding for food and nutrition
programs.
i) The deduction of membership dues and fair share fees.
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j) Expanded access to state-funded child care program to
families in need of subsidies.
aa) Any changes to current practice other than those
listed in above that would improve recruitment and
retention of child care providers, quality of child care
programs, additional education of qualified child care
providers, and the promotion the health and safety of
providers and the children in their care.
14) Requires that the Governor, through the Department
of Personnel Administration, in consultation with the
Superintendent of Public Instruction (SPI), other state
agencies that administer state-funded child care programs, and
their contractors, must meet and confer in good faith
regarding all matters within the scope of representation with
representatives of a certified provider organization.
15) Provides that if an agreement is reached between the
Governor, through the Department of Personnel Administration,
and the certified provider organization, they jointly shall
prepare a written memorandum of understanding.
16) Provides the child care provider organization with
the right to enter an agreement with the state for the
deduction of membership dues and fair share fees from child
care subsidy payments made to providers.
17) Prohibits the child care provider organization from
directing or calling a strike. The bill would also allow for
disputes to be submitted to the California State Mediation and
Conciliation Service for mediation.
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18) Requires, if a family child care provider
organization is certified, the state and the certified
provider organization to establish a training partnership
consisting of a Joint Partnership on Child Care Training,
Education, and Quality Improvement. The membership of the
Joint Partnership is to include representatives of the
certified provider organization and designees of the Governor.
19) Requires the partnership to make recommendations
regarding, and oversee, the expenditures. Authorizes the
partnership to consult with other early education and care
advocates, the SPI or designees, representatives of community
colleges, higher education institutions, resource and referral
networks, unions that operate training programs,
apprenticeship programs, and early education and care
employers. Requires the certified provider organization to
carry out the recommendations of the partnership.
20) Requires the partnership to meet to identify gaps in
the training available to family child care providers and
barriers that prevent family child care providers from gaining
greater skills and accessing postsecondary education, and
issue recommendations on an annual basis to improve the
quality of care offered by licensed and license-exempt family
child care providers.
21) Requires the partnership to play a coordinating role
in ensuring that the training offered to providers:
a) Meets the State's needs for the child care workforce.
b) Satisfies the health, safety and educational standards
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prescribed by the State.
c) Aligns with the State's quality rating systems.
d) Identifies and works to eliminate barriers to providers
accessing training.
22) Authorizes the partnership's recommendations to
include, but not be limited to:
a) Ways to access federal and private funding for training
to expand capacity to existing State training resources,
such as general education classes and English language
learner classes.
b) Ways to expand and improve provider training and skills
on subjects including but not limited to child literacy,
children with special needs, and children's social and
emotional development.
c) Ways to support providers who seek to obtain training or
higher education credentials in child development or a
related field.
d) Ways to work with existing training providers and
educational institutions, including but not limited to
resource and referral networks, community colleges, and
apprenticeship programs.
e) Ways to make training and education, which may include
unit-bearing courses and training, available to child care
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workers and other workers employed by child care centers
and schools.
23) States it is the intent of the Legislature to
allocate $1 million in the 2015 Budget to carry out the
initial recommendations of the partnership, and that in
subsequent years, the recommendations of the partnership be
funded by contributions agreed to for that purpose in the
memorandum of understanding between the provider organization
and the Governor.
24) Requires the Governor or designee to conduct a study
of best practices for engaging families in their children's
early care and education in family child care settings, and of
federal and other funding that could support parental
engagement efforts without reducing the availability and
affordability of child care.
25) Requires the Governor or designee to report to the
Legislature and Department of Finance, by January 1, 2017,
with the findings and a proposed framework of priorities in
which to invest.
26) Requires the Governor or designee, in conducting the
study, to consult with stakeholders, including the DSS, First
5 California, and organizations that represent parents with
young children, particularly lower income and non-English
speaking families, to consider how best to engage and support
those families in a culturally competent manner.
27) States it is the intent of the Legislature to create
an unspecified number of additional slots in alternative
payment programs for children living in extreme poverty,
defined as 50% of the federal poverty level, if funding is
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allocated in the Budget.
EXISTING LAW:
1 Authorizes the Superintendent of Public Instruction to develop
standards for quality child care programs and to enter into
contracts with child care centers and family child care homes
for the provision of child care and development services.
Family child care is provided by someone who resides in the
home where care is provided.
2) Establishes a reimbursement system for subsidized child care
in which:
a) Parents can choose a licensed center or family child
care home, and the state reimburses the provider the same
rate that the provider charges a family who is not
subsidized, up to a ceiling established by the state.
b) Parents can choose a provider who is not required to be
licensed (usually a relative, neighbor or friend), and the
state reimburses that provider a rate set within each
county based on the mean cost of licensed care in the
county.
c) Parents can enroll their children in a center or network
of family child care homes that has a direct contract with
the State Department of Education. Child care in these
programs is reimbursed at a daily rate established in the
contract. For most contractors, the daily rate is the
Standard Reimbursement Rate, set in statute and adjusted by
the Legislature to reflect changes in the cost of living.
d) The daily rate for direct contractors is adjusted by a
statutory formula for infants, school-aged children,
children with disabilities, children at-risk of abuse or
neglect, children who have limited English proficiency and
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children who spend less than six hours per day in care or
more than eight-and-one-half hours per day in care.
FISCAL EFFECT: According to the Senate Appropriations
Committee, this bill would impose major costs to the state
attributed to various state agencies being involved in the
collective bargaining process, potential increases in provider
wages and benefits derived from negotiations, potential
additional child care slots, the establishment of a training
partnership committee, the intent to provide $1 million to
implement initial committee recommendations, and a best
practices study for parent engagement.
COMMENTS: This bill proposes to enact the Raising Child Care
Quality and Accessibility Act. The bill states that it is
intended:
"to promote quality, access, and stability in the child care
system by increasing the number of child care slots available
to California's neediest children; by authorizing an
appropriate unit of family child care providers to choose a
provider organization to act as their exclusive representative
for purposes of the meet and confer process set forth in this
article and the administration and enforcement of any
resulting memorandum of understanding; by establishing a
training partnership between the state and that exclusive
representative; and by conducting a study of best practices
for parent engagement in home-based early care and education.
It is also the purpose of this article to promote full
communication between family child care providers and the
state by permitting a provider organization certified as the
representative of family child care providers to meet and
confer with the state regarding the state's child care
system."
Brief Background on Child Care in California
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The state's subsidized child care system serves around 360,000
subsidized children. Care is provided to children in families
currently or previously receiving CalWORKs, as well as to other
working families subject to available resources. The state
spends a total of approximately $2.2 billion on child care,
which is made up of a mix of state funds and federal funds from
the Temporary Assistance for Needy Families (TANF) and the Child
Care and Development block grants. An estimated 300,000
eligible children are unserved because of a shortage of
resources.
The state's child care system has a dual purpose: caring for
children while their parents work, and enhancing their
developmental potential as they prepare for and attend school.
Two state departments administer child care programs: the
Department of Education (responsible for more than 2/3 of the
funds) and the Department of Social Services (responsible for
administering the first stage of child care for CalWORKs
recipients).
Families are eligible for subsidized care when their incomes are
lower than 70% of the State Median Income (SMI). Above 50% of
SMI, a graduated schedule of family fees applies, up to 8% of
gross income.
Slightly less than half of the total cost of subsidized child
care is spent for current or former recipients of CalWORKs.
Delivery of care for this population is provided through a
3-stage process. In Stage 1, CalWORKs applicants and recipients
are provided care early in their welfare-to-work activities
before their care situation becomes stabilized. In Stage 2,
current and former recipients are guaranteed care while they
continue to participate and for two years after they leave aid.
Stage 3 has been provided since CalWORKs began, covering
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families after Stage 2 until they no longer need care or exceed
the general subsidized care income eligibility limits.
Child care to low-income families, whether in CalWORKs or not,
is provided by a variety of entities: child care centers, which
contract directly with the Department of Education (SDE) and
must meet established educational and health and safety
standards enforced by SDE; licensed family day care, which must
meet health and safety standards enforced by the Department of
Social Services; specialized care such as migrant care; and
informal license-exempt care provided by relatives or for a
single child or children from a single family. Alternative
payment programs administer voucher payments, and resource and
referral agencies provide education, training and support and
help families find appropriate care.
Providers are exempt from the licensing requirement if they
provide care for the children of only one family in addition to
his or her own children, or if they participate in a cooperative
arrangement with other parents when no payment is involved and
specified conditions are met. SDE estimates that there are
approximately 48,000 license-exempt child care providers in the
state (although this number may have decreased with recent
budget cuts).
A recent study<1> by the U.C. Berkeley Labor Center found that
early care and education (ECE) is an important industry in
California, serving more than 850,000 California children and
their families and bringing in gross receipts of at least $5.6
billion annually. The study reported that the industry not only
---------------------------
<1>
MacGilvray, Jennifer and Laurel Lucia. "Economic Impacts in
Early Care and Education in California." U.C. Berkeley Center
for Labor Research and Education (August 2011).
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benefits the children who receive care, but also strengthens the
California economy as a whole by promoting and facilitating
parents' ability to participate in the paid workforce, something
that is especially important during this time in which
California is struggling with high unemployment and a weak
economic recovery. In particular, the study noted that analyses
of the costs and benefits of ECE have found impressive returns
on investments to the public, ranging from $2.69 to $7.16 per
dollar invested.
Antitrust Issues and the "State Action" Doctrine
This bill seeks to allow family child care providers to engage
in specified collective activity under the "state action
doctrine" to federal and state antitrust laws. Therefore, as a
preliminary matter it is necessary to discuss some general
principals of antitrust law and the state action doctrine:
Antitrust Issues Under Federal Law
The primary purpose of federal and state statutory antitrust law
is to prevent businesses from creating unjust monopolies or
competing unfairly in the marketplace.
However, at common law throughout the nineteenth century, most
courts regarded labor unions as unlawful conspiracies in
restraint of trade, punishable civilly or criminally. In 1890,
Congress passed the Sherman Anti-Trust Act, the basic federal
antitrust statute, which declared illegal "every contract,
combination?or conspiracy in restraint of trade." In the years
following passage of the Sherman Act, the courts proceeded to
hold unions liable for antitrust violations in more instances
than businesses, which were the primary objects of concern under
the Act.
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Application of the federal antitrust laws to organized labor
culminated in the Supreme Court decision in Loewe v. Lawlor
(1908) 208 U.S. 274, the famous "Danbury Hatters" case, in which
the Court upheld the applicability of the Sherman Act to unions
and union activities.
Resentment generated by the "Danbury Hatters" case placed
substantial pressure on Congress for a labor exemption to the
Sherman Act, and in 1914 the Clayton Act was passed. The labor
exemption was further articulated with the passage of the
Norris-LaGuardia Act in 1932. Both of these provisions declare
that labor unions are not combinations or conspiracies in
restraint of trade, and specifically exempt certain union
activities such as secondary picketing and group boycotts from
the application of federal antitrust laws.
Antitrust Issues Under State Law
California's general antitrust law, known as the Cartwright Act,
generally prohibits combinations of two or more persons'
capital, skill, or acts to restrict trade or commerce, reduce
the production of merchandise, increase the price of a
commodity, prevent competition, or control or fix at a standard
or figure any commodity. (California Business and Professions
Code Section 16600, et seq.)
Like its federal counterpart, the Cartwright Act contains a
labor exemption. This exemption is found in Business and
Professions Code Section 16703, which provides: "Within the
meaning of this chapter, labor, whether skilled or unskilled, is
not a commodity." Like its federal Clayton Act counterpart,
Section 16703 was intended to insulate from antitrust liability
concerted activities by workers seeking to improve their working
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terms and conditions.
Interplay Between Federal and State Regulation: The "State
Action" Doctrine
The "state action" doctrine recognizes that the federal
government did not intend to supersede the authority of the
states through antitrust regulation. This doctrine was first
articulated by the Supreme Court in 1943 in the case of Parker
v. Brown, 317 U.S. 341, in which the Court declared that the
Sherman Act was not intended to apply to the activities of the
States. Under this doctrine, a state acting within its own
domain may structure its economic market as it sees fit. The
state may allow completely unfettered competition, or substitute
a competitive market structure with regulation.
The state action doctrine provides that a private party is
immune from federal antitrust law if it can show that the state
has displaced competition via regulation. As articulated in
Parker v. Brown, a two-part test is utilized to show requisite
state action. First, the conduct is exempt if it is undertaken
pursuant to a "clearly articulated" state law that displaces
competition with a regulatory scheme. Second, the conduct is
exempt if it is "actively supervised" by the state. This latter
requirement is generally seen as ensuring that the private
parties are acting to fulfill the state's objectives, rather
than for purely self-motivated purposes.
Similar Efforts in Other States
Establishing collective bargaining rights for the child care
workforce is not entirely without precedent. Nationally, a
small percentage of child care centers and Head Start programs
have been unionized for decades. What is relatively new is the
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effort to begin organizing home-based child care providers.
A recent report by the National Women's Law Center<2> discussed
recent developments in other states to authorize home-based
child care providers to join unions and negotiate with the state
for better compensation and working conditions. The report
noted that home-based child care providers are not in a
traditional employer- employee relationship that permits them to
unionize. Most are independent contractors and need special
legal authority to organize into unions that can bargain with
the state over rates, benefits, and similar matters.
According to the report, 14 states have authorized child care
providers to organize and negotiate with the state. These
states include Illinois, Washington, Oregon, Iowa, New Jersey,
Michigan, Wisconsin, New York, Pennsylvania, Kansas, Maryland,
Ohio, Maine and New Mexico.
The legal authority needed for child care providers to unionize
and negotiate with the state generally has been derived from an
executive order from the governor, state legislation, or both.
The executive order or legislation granting legal authority
generally defines the bargaining unit (which type of providers
may be organized and how they are grouped together for
representation and bargaining); specifies the process for
electing a representative, if not covered by existing state law;
identifies the issues the union may bargain over; and defines
the strength of the bargaining mandate and the enforceability of
any negotiated agreement. Agreements often create institutional
arrangements to ensure that providers have some voice in policy
and regulatory changes that affect their interests.
---------------------------
<2> Blank, Helen, Nancy Duff Campbell and Joan Entmacher.
"Getting Organized: Unionizing Home-Based Child Care Providers
(2010 Update)." National Women's Law Center (June 2010).
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OTHER KEY PROVISIONS OF THE BILL
In addition to the provisions discussed above related to
provider organizations and collective bargaining, this bill also
contains provisions related to training, best practices, and
additional child care slots.
Joint Partnership on Child Care Training, Education and Quality
Improvement
According to the author, existing training opportunities are
limited and unavailable or inaccessible to early education and
care providers in many areas of the state.
Therefore, this bill requires a certified child care provider
organization and the state to establish a training partnership
consisting of a Joint Partnership on Child Care Training,
Education, and Quality Improvement. The membership of the Joint
Partnership is to include representatives of the certified
provider organization and designees of the Governor. Among
other things, the bill requires the partnership to meet to
identify gaps in the training available to family child care
providers and barriers that prevent family child care providers
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from gaining greater skills and accessing postsecondary
education, and issue recommendations on an annual basis to
improve the quality of care offered by licensed and
license-exempt family child care providers.
Best Practices for Parent Engagement
This bill requires the Governor or designee to conduct a study
of best practices for engaging families in their children's
early care and education in family child care settings, and of
federal and other funding that could support parental engagement
efforts without reducing the availability and affordability of
child care. The bill requires the Governor or designee to
report to the Legislature and Department of Finance, by January
1, 2017, with the findings and a proposed framework of
priorities in which to invest. In addition, the bill requires
the Governor or designee, in conducting the study, to consult
with stakeholders, including the DSS, First 5 California, and
organizations that represent parents with young children,
particularly lower income and non-English speaking families, to
consider how best to engage and support those families in a
culturally competent manner.
According to the sponsors, parent engagement is a crucial part
of children's success in early care, in school and later in
life. Family child care providers' role in the state's child
care program gives them unique insight into how quality, access,
and stability could be improved for children and families. Many
parents choose home-based providers due to shared values,
language, and cultural background, close personal relationships,
and provider flexibility with erratic work schedules. Under
this bill, the state will sponsor a study of best practices for
culturally competent parent engagement in home-based early care
and education to determine how to most effectively ensure that
parents are involved with their children's development and are
better able to provide learning and other developmental
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opportunities for their children at home.
Additional Child Care Slots
This bill states legislative intent to create an unspecified
number of additional slots in alternative payment programs for
children living in extreme poverty, defined as 50% of the
federal poverty level, if funding is allocated in the budget.
The recently-enacted budget contained a substantial increase in
funding and slots for child care. As described by the
Legislative Analyst Office (LAO):
"[T]he budget funds almost 23,000 (7 percent) more preschool
and child care slots in 2015-16 compared to 2014-15. This
includes about 17,400 (9 percent) additional slots in
non-CalWORKs programs and 5,600 (4 percent) additional slots
in the CalWORKs programs. Of the increase in slots for
non-CalWORKs programs, about 7,500 are full-day preschool
slots and 2,900 are part-day preschool slots. (These reflect
annualized slots, as the budget funds additional slots for the
full- and part-day programs starting at different times.) The
budget also funds 6,800 additional Alternative Payment Program
slots. For the CalWORKs programs, the 4 percent increase in
caseload primarily is due to more families projected to
participate in welfare-to-work activities and, as a result,
use Stage 1 child care.
In light of this budget action, the author has agreed to
eliminate this language from the bill in the Assembly
Appropriations Committee.
ARUMENTS IN SUPPORT
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According to the author, "The current subsidized child care
system encompasses more than 120 different agencies contracting
with the state as middlemen, who in turn administer access to
the system for subsidized families and reimburse providers who
care for children whose families receive subsidies. Low income
children have uneven access to quality child care. Given low
reimbursement rates and a fragmented system, there is also
extremely high turnover among providers. One of the primary
work-related costs that providers struggle to afford is higher
education and training to increase their knowledge of child
development and stay current on the latest theory and practice
of early education and care."
The sponsors state that our current system of child care is
fragmented, standards vary greatly, and it is plagued by high
turnover among providers, as approximately 40% of providers are
leaving the profession each year. In addition, the sponsors
note that income inequality is at the forefront of the nation
and our state. They state that, according to data from the U.S.
Census Bureau, 47% of California's poor children live in
single-mother families and that the majority of California's
single-mother households earned less than 200% of the poverty
threshold. Noting these two factors, the sponsors argue that
California must implement policies that support families in
achieving economic stability and ensure they can access a
stable, affordable, quality child care system so that they can
find work and stay employed. The sponsors believe that this
bill will help achieve this by creating more child care slots
and allowing childcare providers to organize, creating a more
stable workforce and allowing family child care providers to
join together on matters that affect their profession.
ARGUMENTS IN OPPOSITION
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The National Right to Work Committee opposes this bill, arguing
that it would force childcare providers to join a union,
depriving childcare providers of the right to negotiate
workplace conditions for themselves. The National Right to Work
Committee argues that allowing childcare workers to organize
will increase state costs and hurt taxpayers, childcare
providers, and the State of California.
PRIOR AND RELATED LEGISLATION
AB 641 (Rendon) of 2013, among other things, authorized family
child care providers to form, join, participate in, and to seek
the certification of, a provider organization to act as their
exclusive representative on matters related to child care
subsidy programs. AB 641 was held on the Senate Floor.
This bill is similar, but not identical to AB 2573 (Furutani) of
2012. AB 2573 was referred to, but never heard, in the Assembly
Committee on Labor and Employment.
This bill is also similar to AB 101 (John A. Pérez) of 2011. AB
101 was vetoed by Governor Brown, who stated the following in
his veto message:
"Maintaining the quality and affordability of childcare is
a very important goal. So too is making sure that working
conditions are decent and fair for those who take care of
our children. Balancing these objectives, however, as this
bill attempts to do, is not easy or free from dispute.
Today California, like the nation itself, is facing huge
budget challenges. Given that reality, I am reluctant to
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embark on a program of this magnitude and potential cost."
This bill is also similar, but not identical to SB 867 (Cedillo)
of 2008. SB 867 was vetoed by Governor Schwarzenegger, who, in
his veto message stated, "Given California's significant budget
challenge, I cannot consider bills that would add significant
fiscal pressures to the state's structural budget deficit."
Other similar prior legislation includes AB 1164 (De León) of
2007 (which was vetoed by Governor Schwarzenegger), SB 697
(Kuehl) of 2006 (which was vetoed by Governor Schwarzenegger),
SB 1600 (Kuehl) of 2006 (which was held under submission by the
Senate Committee on Appropriations), and SB 1897 (Burton) of
2004 (which was vetoed by Governor Schwarzenegger).
REGISTERED SUPPORT / OPPOSITION:
Support
9to5-CA Chapter
American Association of University Women
American Federation of State, County and Municipal Employees
(co-sponsor)
BANANAS
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Berkeley City Council
Black Women for Wellness
California Alliance for Retired Americans
California Labor Federation, AFL-CIO
California National Organization for Women
California Women Lawyers
Child Care Law Center
Children Now
Children's Defense Fund - CA
Community Coalition
Community Education Partnerships
Congressman Ted Lieu
Consumer Attorneys of California
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Councilmember Magdalena Carrasco, City of San Jose
Courage Campaign, CA
Educators Excellence
Equal Rights Advocates
InnerCity Struggle
Monterey County Board of Supervisors
National Council of Jewish Women California
Numerous Individuals
Our Family Coalition
Parent Institute for Quality Education
Service Employees International Union - CA (sponsor)
Special Needs Network
St. Paul Lutheran Church
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UAW Local 2865
UAW Local 5810
UDW/AFSCME Local 3930
Western Center on Law & Poverty
Western Regional Advocacy Project
Young Invincibles
Opposition
National Right to Work
Analysis Prepared by:Ben Ebbink / L. & E. / (916)
319-2091
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