HomeMy WebLinkAbout3A Public CommentConsolidated Agenda Correspondence
Received prior to 03/11/2021 at 2:30 p.m.
Batch Four
3
John Paul Maier
Subject: RE: *NEW SUBMISSION* Submit Public Comment to the City of Palm Springs
From: City of Palm Springs <palmspringsca@enotify.visioninternet.com>
Sent: Thursday, March 11, 20212:39 PM
To: City Clerk <CityClerk@palmspringsca.gov>; Anthony Mejia <Anthony.Mejia@palmspringsca.gov>
Subject: *NEW SUBMISSION* Submit Public Comment to the City of Palm Springs
Full Name/Nombre
Troy Morgan
City of Residence/Ciudad de residencia
Hemet
Phone (optional) /Telefono (opcional)
9516639097
Email (optional/opcional)
tmorgan1987@gmail.com
Your Comments/Sus comentarios
This has to do with the $4 an hour hero Pay. I am your Palm Springs Stater Brothers meat manager. All I can say is I appreciate it but
we don't need it The only mandate I need the city council upon springs to is to give out tickets for people that wear no mask inside a
store protect us $4 an hour increase in wages means less hours for everybody to go around people get transferred out of your Palm
Springs Stater Brothers other businesses in the community will shut down they can't afford $4 1 urge the city council to reconsider
and vote no on hero Pay $4 thank you Troy Morgan meat manager Stater Brothers markets Palm Springs
Thank you,
City of Palm Springs
This is an automated message generated by the Vision Content Management System'"". Please do not reply directly to this email.
,i k 1
0 J
MORRISON I FOERSTER
February 24, 2021
Via Email
The Honorable Christy Holstege
Office of the Mayor and City Council
3200 East Tahquitz Canyon Way
Palm Springs, California 92262
425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
TELEPHONE: 415.268.7000
FACSIMILE: 415.268.7522
WWW.MOFO.COM
MORRISON h FCIERSTER LLP
BEIJING, BERLIN, BOSTON, BRUSSELS,
DENVER, HDNG BONG, LONDON,
LOS ANGELES, NEW YGRK, PALCI ALTO,
SIN DIEGG, SIN PRANCISC.G, SHANGHAI,
S INGAPDRE, TOKYO, WASHINGTON, D.C.
Writer's Direct Contact
+1 (415) 268.6358
WTarantino@mofo.com
Re: Premium Pay for Grocery and Retail Pharmacy Workers Ordinance
Dear Council Members:
We write on behalf of our client, the California Grocers Association (the "CGA"), regarding
the proposed Premium Pay for Grocery and Retail Pharmacy Workers Ordinance (the
"Ordinance") that singles out a specific group of grocery stores (i.e., those companies with
300+ employees nationally and more than 15 employees per grocery store in the City of
Palm Springs) and requires them to implement mandatory pay increases. The City Council's
rushed consideration of this Ordinance would, if passed, lead to the enactment of an
unlawful, interest -group driven ordinance that ignores large groups of essential retail
workers. It will compel employers to spend less on worker and public health protections in
order to avoid losses that could lead to closures. In addition, the Ordinance, in its proposed
form, interferes with the collective -bargaining process protected by the National Labor
Relations Act (the "NLRA"), and unduly targets certain grocers in violation of their
constitutional equal protection rights. We respectfully request that the City Council reject
the Ordinance as these defects are incurable.
The Ordinance fails to address any issue affecting frontline workers' health and safety.
The purported purpose of the Ordinance is to "protect and promote the public health, safety,
and welfare" during the Covid-19 pandemic. (§ 5.87.005.) The Ordinance is devoid of any
requirements related to the health and safety of frontline workers or the general public and
instead imposes costly burdens on certain grocers by requiring them to provide an additional
Four Dollars ($4.00) per hour wage bonus ("Premium Pay"). (§ 5.87.050.) A wage increase
does not play any role in mitigating the risks of exposure to COVID-19, nor is there any
suggestion that there is any risk of interruption to the food supply absent an increase in
wages. If anything, the Ordinance could increase those risks, as it may divert funds that
otherwise would have been available for grocers to continue their investments in public
health measures recognized to be effective: enhancing sanitation and cleaning protocols,
r
sf-4435640 1;+L L.
MORRISON I FOERSTER
Hon. Christy Holstege
February 24, 2021
Page Two
limiting store capacity, expanding online orders and curbside pickup service, and increasing
spacing and social distancing requirements.
The Ordinance also inexplicably chooses winners and losers among frontline workers in
mandating Premium Pay. The Ordinance defines "grocery store" as a "store that devotes
seventy percent (70%) or more of its business to retailing a general range of food products,
which may be fresh or packaged, or a store that has at least fifteen thousand square feet
(15,00 so of floor space dedicated to retailing a general range of food products." (§
5.87.020.) Other retail and health care workers are ignored, despite the fact that those same
workers have been reporting to work since March. The Ordinance grants Premium Pay for
select, employees while ignoring frontline employees of other generic retailers and other
frontline workers in Palm Springs that face identical, if not greater, risks.
The Ordinance is unlawful By mandating Premium Pay, the Ordinance would improperly
insert the City of Palm Springs into the middle of the collective bargaining process protected
by the National Labor Relations Act. The Ordinance suggests that the certain grocery
workers require this "relief' on an emergency basis, as "establishing an immediate
requirement... protects public health, supports stable incomes, and promoted job retention."
("City Attorney Summary"). Palm Springs employers and workers in many industries have
been faced with these issues since March 2020. Grocers have continued to operate,
providing food and household items to protect public health and safety. In light of the
widespread decrease in economic activity, there is also no reason to believe that grocery
workers are at any particular risk of leaving their jobs, but even if there were such a risk,
grocers would have every incentive to increase the workers' compensation or otherwise
bargain with them to improve retention. The Ordinance would interfere with this process
that Congress intended to be left to be controlled by the free -play of economic forces.
Machinists v. Wisconsin Employment Relations Comm'n, 427 U.S. 132 (1976). Such
ordinances have been found to be preempted by the NLRA.
For example, in Chamber of Commerce of U.S. v. Bragdon, the Ninth Circuit Court of
Appeals held as preempted an ordinance mandating employers to pay a predetermined wage
scale to employees on certain private industrial construction projects. 64 F.3d 497 (9th Cir.
1995). The ordinance's purported goals included "promot[ing] safety and higher quality of
construction in large industrial projects" and "maintain[ing] and improv[ing] the standard of
living of construction workers, and thereby improv[ing] the economy as a whole." Id. at
503. The Ninth Circuit recognized that this ordinance "differ[ed] from the [a locality's]
usual exercise of police power, which normally seeks to assure that a minimum wage is paid
to all employees within the county to avoid unduly imposing on public services such as
welfare or health services." Id. at 503. Instead, the ordinance was an "economic weapon"
meant to influence the terms of the employers' and their workers' contract. Id. at 501-04.
The Ninth Circuit explained that the ordinance would "redirect efforts of employees not to
sf-4435640
MORRISON I FOERSTER
Hon. Christy Holstege
February 24, 2021
Page Three
bargain with employers, but instead, to seek to set specialized minimum wage and benefit
packages with political bodies," thereby substituting a "free -play of economic forces that was
intended by the NLRA" with a "free -play of political forces." Id. at 504.
The same is true of this Ordinance. While the City has the power to enact ordinances to
further the health and safety of its citizens, it is prohibited from interfering directly in
employers' and their employees' bargaining process by arbitrarily forcing certain grocers to
provide Premium Pay that is both unrelated to minimum labor standards, or the health and
safety of the workers and the general public.
The Ordinance also violates the U.S. Constitution and California Constitution's Equal
Protection Clauses (the "Equal Protection Clauses"). The Equal Protection Clauses provide
for "equal protections of the laws." U.S. Const. amend. XIV, § 1; Cal. Const. art I, § 7(a).
This guarantee is "essentially a direction that all persons similarly situated should be treated
alike" and "secure[s] every person within the State's jurisdiction against intentional and
arbitrary discrimination, whether occasioned by express terms of a statute or by its improper
execution through duly constituted agents." City of Cleburne v. Cleburne Living Center, 473
U.S. 432, 439 (1985); Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000). No law
may draw classifications that do not "rationally further a legitimate state interest."
Nordlinger v. Hahn, 505 U.S. 1, 10 (1992). By requiring that any classification "bear a
rational relationship to an independent and legitimate legislative end, [courts] ensure that
classifications are not drawn for the purpose of disadvantaging the group burdened by law."
Romer v. Evans, 517 U.S. 620, 633 (1996).
As discussed above, the Ordinance here unfairly targets traditional grocery companies and
arbitrarily subjects certain 300-employee grocers to the Premium Pay mandate while sparing
other generic retailers who also employ frontline workers. See Fowler Packing Co., Inc. v.
Lanier, 844 F.3d 809, 815 (9th Cir. 2016) ("[L]egislatures may not draw lines for the
purpose of arbitrarily excluding individuals," even to "protect" those favored groups'
"expectations."); Hays v. Wood, 25 Cal. 3d 772, 786-87 (1979) ("[N]othing opens the door to
arbitrary action so effectively as to allow [state] officials to pick and choose only a few to
whom they will apply legislation and thus to escape the political retribution that might be
visited upon them if larger numbers were affected."). Moreover, absent from the Ordinance
is any requirement that would actually address its stated purpose of promoting the public's
health and safety. Put simply, there is a disconnect between the Ordinance's reach and its
stated purpose, making it unlawful and violating the equal protection rights of CGA's
members.
CGA disagrees with the Council's characterization of the Ordinance as an "urgency
ordinance." There is nothing in the Ordinance that is required for immediate preservation of
the public peace, health and safety. (§ 5.87.005.) Even if an urgency ordinance passes, there
is no requirement that an urgency ordinance become effective immediately on passage. As
sf-4435640
MORRISON I FOERSTER
Hon. Christy Holstege
February 24, 2021
Page Four
this Council has done many times before, an urgency ordinance can become effective at a set
date in the future.
Finally, in light of emerging vaccination programs for essential workers, stores' increasing
ability to protect patrons and workers from infection using distancing, curbside pickup, and
other measures, we strongly encourage the City to set an alternate deadline for expiration of
hazard pay ordinance (i.e., 90 days) so that it can be revisited by the Council in light of the
rapidly changing pandemic conditions.
For all of the reasons discussed above, we respectfully request that the City Council reject
the Ordinance.
Sincerely,
IA
William F. Tarantino
cc: Honorable Members of the Palm Springs City Council
Grace Elena Garner
Dennis Woods
Geoff Kors
Lisa Middleton
sf-4435640
John Paul Maier
Subject: RE: Hero Pay
From: Jim Kling & Dave Fletcher <def.ilk@gmail.com>
Sent: Thursday, March 11, 2021 11:23 AM
To: Anthony Mejia <Anthony.Meiia@palmspringsca.gov>
Subject: Hero Pay
I have concerns about ordering supermarkets and others to increase employee pay. I feel the idea is miss guided and
not in the best interest of the city. Please reconsider not to approve this ordnance.
Jim Kling
$ 4i,a rA NO. � �
March 11, 2021
The Honorable Christy Holstege
Mayor, City of Palm Springs
3200 Tahquitz Canyon Way
Palm Springs, CA 92262
RE: Grocery Worker Pay
Dear Mayor Holstege,
On behalf of Palm Springs grocers, I write to ask the Council to not move forward with the proposed grocery worker
premium pay ordinance given the numerous negative consequences to grocery workers, neighborhoods and the grocery
industry. Based on the consequences experienced in other jurisdictions with similar ordinances, we must oppose the
ordinance for both policy and legal reasons.
We agree that grocery workers serve a vital and essential role during the pandemic. They have worked tirelessly to keep
stores open for consumers, allowing our communities to have uninterrupted access to food and medications. To protect
our employees, grocery stores were among the first to implement numerous safety protocols, including providing PPE and
masks, performing wellness checks, enhancing sanitation and cleaning, limiting store capacity, and instituting social
distance requirements, among other actions.
On top of increased safety measures, grocery employees have also received unprecedented amounts of supplemental
paid leave to care for themselves and their families in addition to already existing leave benefits. Grocers have also
provided employees additional pay and benefits throughout the pandemic in various forms, including hourly and bonus
pay, along with significant discounts and complimentary groceries. All of these safety efforts and additional benefits
clearly demonstrate grocers' dedication and appreciation for their employees. Most importantly the industry has been
fierce advocates for grocery workers to be prioritized for vaccinations. This is evident now that your county is now
considering grocery workers a priority and they are currently receiving the vaccine.
Unfortunately, the Grocery Worker Premium Pay ordinance would mandate grocery stores provide additional pay beyond
what is economically feasible, which would severely impact store viability and result in increased prices for groceries,
limited operating hours, reduced hours for workers, fewer workers per store, and most concerning, possible store
closures. These negative impacts from the ordinance would be felt most acutely by independent grocers, ethnic format
stores, and stores serving low-income neighborhoods. The Cities of Los Angeles, Long Beach and Seattle, who have passed
a similar ordinance, have already suffered the permanent loss of several full -service grocery stores as direct result.
We request the City of Palm Springs perform an economic impact report to understand the true impacts of this policy. If
you choose not to understand specific impacts for Palm Springs, then we refer you to the economic impact report from
the City of Los Angeles Legislative Analyst Office. This report makes it clear that the impact of this policy will severely
impact workers, consumers, and grocery stores.
In its own words the Los Angeles City Legislative Analyst clearly states that grocery "companies would be required to take
action to reduce costs or increase revenue as the labor increase will eliminate all current profit margin." The report
recognizes that "affected companies could raise prices to counteract the additional wage cost." This type of ordinance
would put "more pressure on struggling stores (especially independent grocers) which could lead to store closures" and
that "the closure of stores could lead to an increase in 'food deserts' that lack access to fresh groceries." These are all
scenarios we know everyone in the city wants to avoid, especially during a pandemic. This is why we are asking the
Council to not move forward with this policy and, instead, focus on making sure all grocery workers are provided the
vaccine.
CALIFORNIA GROCERS ASSOCIATION 1 1005 12th Street, Suite 200, Sacrame4rto, CA 95814
P: (916) 448-3545 1 F: (916) 448-2793 1 www.cagrocers.com
March 11, 2021
PAGE 2
Specific to ordinance language, there are numerous policy and legal issues which unnecessarily single out the grocery
industry and create significant burdens. The ordinance fails to recognize the current efforts grocers are making to support
their employees and requires grocers add significant costs on to existing employee benefit programs.
Furthermore, passing this ordinance improperly inserts the city into employee -employer contractual relationships. The
ordinance also ignores other essential workers, including city employees, that have similar interaction with the public.
Taken in whole, this ordinance is clearly intended to impact only specific stores within a single industry and fails to
recognize the contributions of all essential workers. Based on language specifics, this ordinance misses a genuine effort to
promote the health, safety and welfare of the public.
Emergency passage of the ordinance also ignores any reasonable effort for compliance by impacted stores, as several
grocery stores will be operating at the time of passage. By implementing the ordinance immediately there is literally no
time to communicate to employees, post notices, adjust payroll processes, and other necessary steps as required by
California law. Coupled with the varied enforcement mechanisms and significant remedies outlined, the passage of this
ordinance would put stores into immediate jeopardy. This scenario is yet another negative consequence resulting from
the lack of outreach to grocers and the grocery industry to understand real world impacts.
Grocery workers have demonstrated exemplary effort to keep grocery stores open for Palm Springs. This why the grocery
industry has provided significant safety measures and historic levels of benefits that include additional pay and bonuses. It
is also why vaccinating grocery workers has been our first priority. Unfortunately, this ordinance is a significant overreach
of policy and jurisdictional control. This will result in negative consequences for workers and consumers that will only be
compounded by the pandemic.
We respectfully implore the Council to not move forward with the grocery worker pay ordinance at this time. We
encourage you to recognize and understand the impacts of this ordinance on workers and the community by accepting
our invitation to work cooperatively with Palm Springs grocers. If Council must bring the ordinance forward for a vote at
this time we ask you to oppose its passage. CGA is submitting additional information from our legal counsel for your
consideration.
Thank you for your consideration and we look forward to being able to combat the pandemic in partnership with the City
of Palm Springs.
Sincerely, *__� Z
Timothy amen
California Grocers As i on
CC: Members, Palm Springs City Council
City Clerk, City of Palm Springs
CALIFORNIA GROCERS ASSOCIATION 1 1005 12th Street, Suite 200, Sacramento, CA 95814
P: (916) 448-3545 1 F: (916) 448-2793 1 www.cagrocers.com
John Paul Maier
Subject: RE: Hero pay
-----Original Message -----
From: Maripet Galang <maripetgalang@yahoo.com>
Sent: Thursday, March 11, 2021 12:47 PM
To: City Clerk <CityClerk@palmspringsca.gov>
Subject: Hero pay
I have been an employee of Ralphs for the past 15 years and since the pandemic started we have been working and even
got sick for 2 months. I think we deserve to get the hero pay due to the fact that our company is getting greedy all they
want is SALES and not worry about their employees. OUR EMPLOYER OWES THAT TO US!I! We have been working so
hard and even work late nights and WE DESERVE TO GET OUR HERO PAY!!!
Sent from my iPhone
John Paul Maier
Subject: RE: Discussion of Establishing "Hero Pay" Ordinance for Front -Line Grocery Employees
From: Mark Ostoich<Mark.Ostoich@greshamsavage.com>
Sent: Thursday, March 11, 2021 12:44 PM
To: City Clerk <CityClerk@palmspringsca.gov>
Cc: David Ready <David. Ready@ pal mspringsca.gov>; 'Jeff. Ballinger@ bbklaw.com' <Jeff.Ballinger@bbklaw.com>; Mark
Ostoich<Mark.Ostoich@greshamsavase.com>
Subject: Discussion of Establishing "Hero Pay" Ordinance for Front -Line Grocery Employees
4
Please enter this letter in the record of the administrative proceedings for Agenda Item 3.A at the City
Council meeting tonight. Please also distribute copies of the letter to the City Attorney, the City
Manager and each member of the City Council.
Thank you, Mark Ostoich
Mark Ostoich
Principal Shareholder
Gresham Savage Nolan & Tilden, PC
550 East Hospitality Lane, Suite 300
San Bernardino, CA 92408-4205
Office: (909) 890-4499 Ext. 1704
Fax: (909) 890-9690
www.GreshamSavage.com
mark.ostoichCabgreshamsavage.com
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MARKS A. OSTOICH (909) 890-4499
P.O. Box 12118
San Bernardino, CA 92423-2118
March 11, 2021
VIA E-MAIL — citvclerkCa Dalmsnrinvsca.¢ov
Mayor and Members of the City Council
c/o City Clerk
City of Palm Springs
3200 East Tahquitz Canyon Way
Palm Springs, California 92262
Re: Discussion of Establishing "Hero Pay" Ordinance for Front -Line Grocery Employees
Honorable Mayor and Members of the City Council:
Thank you for the opportunity to again address you regarding this important matter. Please consider
this letter as a supplement to my February 25, 2021 letter to you.
At this time, the proposed Ordinance is directed toward retail grocery stores. However, your Staff
Report mentions the need for further discussion of other categories of workers that should be
considered, including restaurant workers. I am opposed to the adoption of any ordinance that purports
to govern pay to restaurant workers.
In any event, I want to again urge you to refrain from adopting the proposed Ordinance until you
comply with the California Environmental Quality Act. In that regard, Section 4 of the proposed
Ordinance states that, "The City Council determines that the adoption of this Urgency Ordinance is
exempt from environmental review under the California Environmental Quality Act ("CEQA')
pursuant to the following provisions of the CEQA Guidelines, 14 California Code of Regulations,
Chapter 3: this Urgency Ordinance is exempt under CEQA Guidelines Section 15378(b)(5) in that it
is not a "project" under CEQA, and will not result in direct or indirect physical changes in the
environment."
Recently, Kroger Co. announced the closure of two Long Beach grocery stores in response to
adoption of the Hero Pay Ordinance by the City of Long Beach, as well as three Los Angeles grocery
stores in response to adoption of the Hero pay Ordinance by the County of Los Angeles and the City
of Los Angeles. The latter closures were reported yesterday in the Business section of the Los
Angeles Times.
Your Staff Report acknowledges on page 5 that, on February 1, 2021, the Los Angeles Times reported
that Kroger Co. would close two stores in Long Beach in response to the City's adoption of a "Hero
Pay Ordinance".
002D-M-4038647.1
MARK A. OSTOICH
Mayor and Members of the City Council
City of Palm Springs
March 11, 2021
Page 2
Your acknowledgment of the Long Beach closures, along with the above -referenced Los Angeles
Times article regarding the Los Angeles closures, create a fair argument that retail grocery stores will
close in response to adoption of the proposed Hero Pay Ordinance and as a result, buildings will be
shuttered and physical deterioration and blighting will occur.
In addition, when store closures occur, traffic patterns will change as shoppers drive to stores that
remain open, including stores in other jurisdictions, creating additional traffic impacts that do not now
exist. In view of the foregoing, the proposed Hero Pay Ordinance is a "project" under CEQA. You
cannot ignore this and act to adopt the proposed Ordinance without first studying the impacts that the
project will have on the environment.
I am requesting that the City Clerk place this letter in the Administrative Record of these proceedings.
Very truly yours,
Mark A. Ostoich
MAO/pmj
cc: David H. Ready, City Manager (via e-mail - David.Ready@palmspringsca.gov)
Jeffrey S. Ballinger, City Attorney (via e-mail - Jeff.Ballinger@bbklaw.com)
00204M-4038(A7.1
Consolidated Agenda Correspondence
Received prior to 03/11/2021 at 10:00 a.m.
Batch Three
John Paul Maier
Subject: RE: Hero Pay - No
From: jasperlp3@aol.com <jasperip3@aol.com>
Sent: Thursday, March 11, 2021 8:00 AM
To: City Clerk <CityClerk@palmspringsca.gov>
Subject: Hero Pay - No
E
I am requesting that the City Council vote No to Hero Pay for grocery store employees today. Although these workers are
hard working and very deserving, this measure singles out a specific occupation when there are many many other front
line workers in other industries who are also very deserving. In addition it is very likely that prices at our local stores will
rise effecting members of all economic groups, many who are struggling as it is without jobs at all. Please vote No.
John Ryan
2701 Mesquite H42
Palm Springs, CA 92264
562-228-3448