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In the Matter of an Interest Arbitration Between INTERNATIONAL ASSOCIATION OF
This is an arbitration in accordance with ORS 243, between the International Association of Firefighters, Local 2091 ("IAFF") and the Winston-Dillard Fire District ("District"). The parties presented their Last Best Offer Packages ("LBOP") to each other, in accordance with ORS 243.746. I held a hearing on November 15, 2004, in Roseburg, OR. Both parties were present at the hearing and represented by counsel. Each had a full opportunity to examine and cross-examine witnesses, and present relevant evidence. There was no stenographic record. At the close of the hearing the parties asked to file post-hearing briefs by December 30, 2004. Because of an apparent mail failure, I did not receive the District's brief until January 13, 2005.
Last Best Offer Packages
The parties agreed to all aspects of a new collective bargaining agreement to run from July 1, 2004 to June 30, 2007, except for the specific changes contained in each of their LBOPs. I describe the LBOPs below; the full language of the proposals is in Appendix A, which is attached to this Opinion and Order.
1. Health Insurance. IAFF proposes the District continue to pay 90% of the premiums for medical, vision, and dental insurance, regardless of whether the employee, employee and spouse, or employee and family are covered. It sets forth the specific medical plan (Pacific Source Preferred 200+15), dental plan (Pacific Source Incentive $1500), and vision plan (Pacific Source $10 Co-pay). The LBOP also creates an Insurance Committee made up of 2 persons appointed by the District and two appointed by IAFF. This committee reviews the existing plans,
examines potential cost savings through Plan manipulation, and recommends new carriers or Plans. If the committee cannot reach consensus, it recommends actions to the Boards of IAFF and the District. If the Boards do not agree, IAFF can require the matter be settled by interest arbitration.
2. Haz-Mat Members Life and Disability. The District will provide $100,000 life and disability insurance to every hazardous materials certified technician.
3. Paid Time Off. Add 3.5 days pay at regular rate in lieu of holiday time off; begin PTO accrual at hire, instead of after 1 year; additional accrual after 15 years; allow probationary employees to use vacation after six months of employment.
4. Salary. Increase all classifications and steps by 2.5% on July 1, 2004, January 1 and July 1, 2005, January 1 and July 1, 2006, and January 1, 2007.
1. Health Insurance. Continue to contribute 90% of premiums to Lifewise Option III PPO, including vision. Reimburse employees through an HRA for increased deductible over Lifewise Traditional Option II plan, and for $5 of co-pay per covered medical expense. Continue to pay 90% of the premium for current dental. Effective August 1, 2005, continue 90% payment of premiums for plan providing substantially similar medical and dental benefits. Continue to reimburse for deductible in excess of Lifewise Traditional Option II plan.
2. Salary. Increase by 2.2% July 1, 2004; increase by CPI-W, All Cities annual increase on July 1, 2005, and July 1, 2006.
Interest and Welfare of the Public
The District asserts its LBOP promotes the interest and welfare of the public because it best promotes the sustainability and stability of the fire service within the District. It makes three arguments to support this assertion. First, it argues the financial conditions that affected the State and its political subdivisions when State of Oregon v. Oregon State Police Officers' Assoc., IA-15-03 (Brand, 2004) was issued still prevail, so that taking the less expensive LBOP is in the interest and welfare of the public. Second, the District argues it has incurred budget shortfalls in the last two years, requiring it to leave two bargaining unit positions unfilled. Third, it argues the budget shortfalls have required it to borrow money to fund operations while awaiting taxes. IAFF asserts there is no patent illegality, or other overriding defect in either of the LBOPs. Consequently, the arbitrator must consider the secondary criteria.
The District's arguments are essentially that it has an inability to meet the financial costs of the LBOP proposed by IAFF, within its other priorities.(1) Unlike the circumstances in Oregon State Police, the District made no overwhelming showing of failed attempts to raise revenue and drastic cuts to control costs. Nor is the District a complex entity that has cut costs by imposing wage constraints on thousands of other employees, all of whom were treated similarly. While the
District may have strong arguments about its financial inability, they do not amount to a prima facie showing it is in the interest and welfare of the public to accept the District's LBOP.
Ability to Pay
To examine the District's ability to pay, one must begin with an accurate cost analysis of each of the LBOPs. The District argues IAFF has seriously understated the costs of its wage proposal. The District is correct. IAFF has calculated its wage proposal as if a 2.5% increase every six months amounts to an uncompounded 3.75% increase each year. Except for the first year, it is not a 3.75% increase in either cash flow terms, or total new money. Beginning in the second year the District must pay the full 5% increase from the first year, plus two 2.5% increases compounded on the full 5% increase and then on a 7.5% increase. The last 2.5% increase is fully paid the first year after the contract ends. The IAFF proposal amounts to a 16% wage increase, costing approximately $274,583 in new money (compared to current wages and wage driven costs) over the term of the contract. (See, Ex E-22) In the year after the contract ends, absent an increase in wages that year, the IAFF 16% increase will cost the District approximately $124,000 more in wages and wage driven costs than the current wage levels.(2) The District's cost calculations for both LBOPs assume it fills the firefighter position it left vacant this year. (Ex. E-22, FN 1)
IAFF argues that the District proposal is almost as costly as its own, based on an assumption of a 3.7% annual cost of living increases in the second and third years of the contract. That assumption is not warranted. In the last 120 months the CPI has risen by 3.7 or more in only five months. There has been no annual increase as high as 3.7% in any of the last ten years. Similarly, the District's assumption of 2.2% CPI increases for the second and third years seems unwarranted. The average CPI increases over the past ten years are a bit under
3.0%. Using that 3% figure for the second and third years yields an approximate $122,000 in new money.(3) That leaves the IAFF wage proposal costing approximately $153,000 more than the District proposal, without considering the effect of the IAFF proposal on wages the year after the contract ends or other costs of its LBOP.
Both proposals for health insurance represent a savings over prior costs. IAFF asserts the first year savings should be calculated for the entire year because it proposed a cheaper plan that could have saved money for the entire year but the District rejected it. The District counts savings only from the approximate date of this Award forward, since those are the only savings that can actually be realized.(4) The District position makes more sense, since it deals in actual rather than theoretical savings. The District projects its health care costs (assuming a 20% annual increase in cost of insurance and employees paying the deductible in years 2 and 3) at about $76, 000 for the term of the contract. (Ex. E-21) It projects the cost for the IAFF proposal, assuming 20% increases, at a net of $64,632 over the life of the contract.
At the hearing, the District conceded the total cost estimate of its proposal should be adjusted to $187,341. With an adjustment for a 3.0% CPI increase in years 2 and 3, a more accurate estimate would be that the District's proposal would cost approximately $191,00 in new money over the term of the contract.
The IAFF LBOP contains further costs that are not adequately represented in IAFF's cost comparisons. I have set out the District's estimates of the new costs over three years for the following:
1. Life Insurance -- $1800.
2. Liability for PTO carryover Year 2 -- $30,137.
3. Liability for PTO carryover Year 3-- $31,400.
4. Additional PTO for 15+ years --$4,745.
The figures for PTO carryover liability are based on the assumption that all PTO will be carried over to the following year, and paid at the higher wage rates of the following year. The District provided no adequate basis for that assumption. It is likely that there would be a cost to allowing PTO carry over, since the inability to carry over PTO means employees use it each year, rather than lose it. If firefighters did not want to carry over their PTO, they would not have requested
the new provision. But the District calculation severely overstates the likely cost. If 25% of the PTO were carried over each year, the total cost for years 2 and 3 would be approximately $15,384. That is a more realistic estimate than 100%. Using that adjustment, the total three year cost of the IAFF proposal is $361,144.00, without accounting for the cost of the final IAFF 2.5% raise in the following year, when it must be fully funded.
The District argues an inability to pay the increases IAFF requests, while IAFF insists the District has the ability to pay. In part, the difference is based on how the parties look at District finances. IAFF looks at the annual ending fund balance and sees a large pot of money that carries over from year to year and is available for wage increases. IAFF notes that the ending fund balance has varied from 38% to 40% to 34% of General Fund revenue from 2001 to 2003. The
District notes the ending fund balance was reduced to $394,820 on June 30, 2004, down from $515,275 on June 30, 2002. The ending fund balance is used to pay for operations from the end of the fiscal year until the District receives its annual tax revenues beginning in November. The alternative to an ending fund balance sufficient to cover these costs are tax or revenue anticipation notes, which are short term loans that pay for operations until the District receives its tax money and pays them back. The District notes that because of 3 years of 6% wage increases the fund balance has declined so that it was obliged to borrow $50,000 to cover operating expenses in October 2004. (E-10)
The size of the ending fund balance is, of course, dependent on the District's revenue, as well as its expenditures. While the District budgets a 1% increase in Total Taxable Assessed Value (Ex. E-7, p.4), according to its auditor, most municipalities budget a 3% increase. (Ex. E-9, p.1) In the 2004-2005 budget year, the TAV used to compute the tax rate increased substantially. (Ex. E-9, p. 7) According to the auditor, an assumed 3% increase for the 2005-2006 budget year would produce an additional $43,647. (Ex. E-9, p. 1) The parties provided no projected TAV and revenue figures for the final year of the proposed contract. In its brief, the District estimates $131,000 (3 years at $43,647) in new revenues over the life of the contract. The only available projections for increases in the Ambulance fund revenues come from Chief McGinnis, who estimates them at $6,126 in 2005-2006 and $6485 in 2006-2007. (Ex. E-10, p. 6) As the Chief notes, since the Ambulance fund is an enterprise fund, entirely dependent on collected fees for service, the increases are somewhat speculative.
The District looks at its finance on a cash flow basis, seeking to balance revenues and expenditures. It notes that its expenditures have exceeded revenues in each of the past two years, causing it to spend down its ending fund balance. As a result of the 6% annual raises, the percentage of revenues expended on personal services has increased from 77% in 2001-2002 to 84% in 2003-2004 in the General Fund and from 70% to 87% in the Ambulance Fund. During the last two years the District has further compensated for revenue shortfalls by reducing its contributions to Capital Project Funds for equipment replacement by $147,000. (Ex. E-7, p.7) It has taken on an annual debt burden of $61,000 for the new fire station. (Ex. E-9, p. 2) Even if the District were to increase its transfers to Capital Project Funds to their previous rate, the additional debt would reduce the funds available for replacing equipment to $21,420 per year. According to the auditor, that would affect future purchases of equipment. (Ex. E-9, p. 2) In short, in the District's view, the new funds that would be required to pay the IAFF's LBOP would leave it inadequate money for Materials and Services, Capital Outlay, and Transfers Out, as well as reduce the ending balance further.
To assess the District's reasonable financial ability to meet the costs of the contract in light of its other priorities, one must compare the total increased costs (new money) over three years with the total reasonably projected increased revenues (new money) over those same three years. Using the auditor's 3% estimate, the total projected new money is approximately $261,882 over the current base revenues. The total estimated three year cost of the IAFF proposal is $361,144 over the current base personnel costs. Thus, the increased cost to pay for the IAFF LBOP proposal would exceed reasonably projected revenue increases for the same period.(5) There would be no money to increase the previously reduced budgets for Materials and Services, Capital Outlay, and Transfers Out. Nor would the ending fund balance increase, so the District would not have to continue to borrow to meet expenses.
It is, of course, possible the District will increase revenues more than 3% a year during the contract term. Over the past five years the increases in TAV have averaged 4.4%. (Ex. E-9, p. 7) If that were to occur over the next three years, that would amount to somewhat more than $384,093 in new money. (1%=$14,549 currently (Ex. E-9, p. 1) Adding in Ambulance Fund revenue increases, that would amount to $404,093. Less the cost of the IAFF LBOP, that would leave $43, 000 to cover the shortfall in Materials and Services, Capital Outlay, and Transfers Out, or less than $15,000 per year. That is only enough make up the budgeted reduction in the 2004-2005 Fire Engine Replacement Fund. Other cost increases (even those due solely to inflation) would have to be funded by further reducing the ending fund balance, without a reasonable prospect of its being restored. The cost of the IAFF LBOP is simply not sustainable over the term of the contract, even with a revenue estimate that exceeds what the auditor deems prudent. It assigns almost every dollar of new revenue to personnel costs, leaving ongoing costs of increases in Material and Services, as well as proper funding of replacement funds, to come out of the ending balance. Thus, on the criterion of ability to pay, the facts argue overwhelmingly in favor of the District LBOP.
Ability to Attract and Retain Qualified Personnel
The District data show a total of four separations in the past four years, with two occurring in 2004. One was a retirement, one a move to a supervisorial job with a city, one to a hospital job, and one to a fire department to which the employee had previously applied. The IAFF data show the same three firefighters who changed jobs in the last four years, and another name, without a year of separation. IAFF concedes there is no paucity of applicants for firefighters jobs. On this evidence, it cannot be said the District has a problem recruiting or retaining qualified personnel. This factor favors the District LBOP.
Overall Compensation
The District lists all of the elements of firefighters total compensation. Although it argues for PTO carry over and increasing paid time off for long term employees, IAFF demonstrates only that Winston-Dillard firefighters have somewhat less paid time off accrual than its comparison group of entities. Because of the inclusion of certain outliers and the use of averages, as discussed below, IAFF does not make a convincing case for its increase based on the comparison of overall compensation. Thus, this factor favors the District LBOP.
Comparison with Communities of the Same or Nearest Population Range
The parties disagree strenuously about the proper jurisdictions with which to compare District firefighters. The District is rural and chooses geographically proximate communities with similar populations. It uses the same comparators (although it deals differently with the two that have ceased to exist independently) the arbitrator used in the last interest arbitration.(6) IAFF ignores geographic proximity and looks at population as the sole criterion. This results in several anomalies in the comparators, such as Wilsonville (served by Tualatin Valley Fire & Rescue) with an $89 million 2004-2005 budget, and Troutdale (served by the city of Gresham) with a $12 million 2004-2005 budget. These are both far larger departments than Winston-Dillard, capable of having more kinds of specialized pay and incentives. They also are likely to have a higher tax base because they are suburbs rather than rural areas. It is problematic to compare them with a rural district that has a budget of $2.5 million.
IAFF argues, however, that post-SB 750 the only permissible statutory consideration is population, not location, or how fire services are provided. It supports this argument with quotes from cases and by dismissing the 1995 interest between the parties that considered the location of entities of similar population. IAFF asserts that the previous arbitration cannot be considered because it is pre-SB 750. The latter explanation ignores footnote 1 in that decision, which says: "The parties agreed that this arbitration would be governed by ORS 243.650-782,as amended by SB 750 and corresponding amendments to the Administrative rules of the Oregon ERB."
The other cases IAFF cites generally look at either the simple question of whether a district can be compared with a city, or what role population plays. Arbitrator Lankford noted:
The City also objects to the Union's inclusion of fire protection district salaries in its list of proposed comparables. Once again, however, it is not clear that the statutory language leaves room for such a distinction. The statutory language-"'comparable' is limited to communities of the same or nearest population range within Oregon"-could mean (1) that no community shall be considered comparable if it is not of the same or nearest population range or (2) that nothing except being within the same or nearest population range shall be considered in determining comparability. Arbitrators appear to have agreed on at least the first of these possible senses of the term, but there is no apparent agreement on the second (i.e. that similarity of size, and nothing else, is to be the desideratum). (http://www.erb.state.or.us/awards/ia0799.htm)
The other cases IAFF cites simply do not stand for the proposition "population, not geography is sole determinant for comparable communities." This paraphrase of Arbitrator Levak in Tigard Police Officers Assn. does not adequately summarize his statement: "it is clear from the very change made by the legislature that it intended a switch from the labor market standard to a population standard. Only jurisdictions within a labor market that are in the same or nearest population range can be given consideration under the statute." For a jurisdiction to be "within a labor market," it must be within a defined geographic area. Put another way, for jobs that require physical presence (such as firefighting), once the distance between two locations exceeds a commuting distance, they tend to be different labor markets. Given this equivocal statement by Arbitrator Levak, it cannot be said that he decided population is the sole determinant of comparability.
The District's comparables are consistent with the statutory requirement and more persuasively "comparable" jurisdictions. Suburban entities with nearly the same population as rural entities are not necessarily comparable to the rural entities. They are likely to have higher tax bases because property values tend to be higher in suburbs of cities like Portland than in rural areas.(7) To the extent they are served by larger departments, those departments may exist in a labor market that pays generally higher wages. The departments themselves may have economies of scale and resources not available to a rural department. Thus, while the statute requires arbitrators to choose comparable jurisdictions only from entities with "the same or nearest population range within Oregon," it does not require the inquiry into comparability to end with population. There is an anomaly in the District comparisons, as well. There is no explanation of why the District PERS contribution rate (exclusive of pick up) is so much higher than almost all the comparable jurisdictions. There is no evidence that employees have a better retirement benefit than employees in the comparable jurisdictions. If they have the same benefit, then the "indirect monetary benefit"to the District employees is the same as the benefit enjoyed by the comparable employees. There is no statutory basis for comparing the cost. The employer pick up of the employee 6% contribution is, of course, a valid monetary benefit to compare with other jurisdictions. The District does not make that comparison, but combines all retirement costs. Thus, the District comparisons that include its cost of retirement do not fairly represent the employees' indirect monetary benefits. While the comparisons are favorable to the District, they are not consistent with the statute.
The District's comparisons, without the cost of retirement, show the ten year firefighter at a significant compensation disadvantage. Without EMT-I the ten year firefighters is 11% below comparables. With EMT-I they are 6.5% below, and with Paramedic 4.9% below.(8) The ten year Engineer and Captain are quite close to their comparable categories. The firefighter rank is the most populous one in the bargaining unit, but there is no evidence about which of the unit members are ten year firefighters without EMT-I or Paramedic certificates. By straight longevity, only 5 firefighters will have ten years of service during this contract period. (Ex. E-28) Of these, it is likely that some have the training that gives them higher pay. The evidence shows only that a minority of the unit suffers a significant total compensation disadvantage. Nevertheless, this criterion argues for the IAFF LBOP.
The evidence shows firefighters have had cumulative increases over the past ten years that exceed the CPI increase. It is only in the last contract, however, that the increases significantly exceeded CPI for multiple years. Firefighters in the District have not lost buying power to inflation over the last ten years. Thus, this criterion argues for the District LBOP.
While more of the criteria argue for the District LBOP, the criteria are not of equal weight. The two most significant criteria - ability to pay and comparability - are in conflict with one another. Certain firefighters are compensated significantly below firefighters in comparable jurisdictions. They need significant raises to become competitive. That is not true for the other ranks. At the same time, the IAFF's LBOP is not within the District's reasonable ability to pay. It uses more than the reasonably projected revenue increases over the next three years. Even if the District has the average actual increase it has had over the last 5 years, the Union's LBOP will cause the District to continue to outspend its income, continue to under fund its replacement funds, and continue to reduce its ending fund balance. While the Union's LBOP is justified in so far as the ten year firefighter rank's current compensation is below comparables, it is beyond the
District's reasonable financial ability to pay. Consequently, I award the District's LBOP.
San Francisco, CA February 7, 2005
Norman Brand
For the International Association of Firefighters, Local 2091
Michael L. Tedesco, Esq.
For the Winston-Dillard Fire District
Bullard Smith Jernstedt Wilson
By Adam S. Collier, Esq.

Appendix A
Section 19.1 Insurance Contribution
This article in its entirety is to ensure equal Health Care Benefits (HCB's) for District personnel. HCB's shall be paid by the District at 90% for Single, Married and Family personnel. The premiums shall include medical, vision, and dental insurance.
Section 19.2 Insurance Committee
The Union and District will develop an Insurance Committee. Should the current insurance become unavailable, a committee of 2 persons appointed by management and 2 persons appointed by the Union will meet at the request of either party to review existing plans. It is the charge of this committee to look at cost savings through plan manipulation and/or investigation of different insurance carriers. The committee will strive to maintain a plan that is substantially equal in the insurance benefits to the current benefits. If the committee can not reach a consensus, then a report or recommendation summarizing the positions of the committee members shall be given to the IAFF 2091 Executive Board and the Fire District Board of Directors to bargain the impact.
If one or both the Board of Directors or the Union rejects the recommendation of the committee, or they can not reach agreement to change the insurance plan or carrier, the parties will immediately commence bargaining. The first order of business in bargaining will be to select an arbitrator and set a date for interest arbitration in the event the parties are unable to reach agreement at the bargaining table. The Union may request in writing a list of seven (7) Oregon arbitrators from the Employment Relations Board.
The selection shall be made within ten (10) days after the list of names has been received. From the list, one arbitrator shall be selected in the following manner:
The District's and the Union's representative shall flip a coin to determine who strikes out the first name. After the first name is stricken, each side shall strike in turn until only one (1) name remains. The remaining name shall be the selected arbitrator. The District and the Union shall pay the arbitrator's fees and expenses incurred equally (50% / 50%).
Section 19.3 Insurance Benefits Defined.
Medical Plan:
Name: Pacific Source Preferred 200+25
Benefits: Lifetime Maximum: $2,000,000.00
Annual Out of Pocket Max: $2,000
Co-Pay: $15
Rx Plan: Three Tier at $15, $30, and $35
Refer to plan booklet for full benefit explanation
Dental Plan
Name: Pacific Source Incentive $1500
Refer to plan booklet for full benefit explanation.
Vision Plan
Name: Pacific Source $20 co pay
Refer to plan booklet for full benefit explanation.
Section 19.4 Haz-Mat Members Life and Disability Insurance.
The District shall provide $100,000 life and disability insurance on every Hazardous Materials certified technician.
Section 1: Employees assigned to work 40 hours per week will receive 8 hours time off plus the following Holidays off: New Years Day, Veterans Day, Memorial Day, Thanksgiving Day,
July 4th, Christmas Day, Labor Day
In the event a 40 hour employee is required to work a listed holiday, they will be paid at 1.5 times their regular rate of pay.
Section 2: 56 hour personnel will receive 3.5 days pay at regular rate of pay in lieu of holiday time off. The amount paid will be issued in November.
Section 3: PTO Accrual:
Employees will receive time off at the following rates:
56 Hour Personnel: Shifts 40 Hour
0-4 years 168 hours 7 88 hours
5-9 years 240 hours 10 128 hours
10-14 years 312 hours 13 168 hours
15+ years 360 hours 15 208 hours
Section 4: Utilization:
Carry over should not exceed 120 hours. The one year entitlement of time off for each employee will be issued July 1st each year. Probationary employees may use vacation after six months of employment.
Section 5: Retirement Carry Over:
Employees giving written notice of their intent to retire at least 30 months prior to their separation date may accumulate up to 600 hours of pto in recognition of the possibility that retirement benefits may not be paid for 60 to 90 days post separation from the district.
The District shall pay the wages set forth in the classifications of Firefighter, Engineer, and Captain. Salary increases for this contract shall be for all classifications and all steps shall increase by 2.5% in July 1, 2004 and each six months thereafter though [sic] January 1, 2007. (Six increments at six month intervals of 2.5%.)
The District agrees to contribute 90% of the premium amount to Lifewise Option III PPO medical insurance ($500 individual, $1,500 family deductible) including the vision insurance. The District shall, upon receiving documentation satisfactory to the program administrator, reimburse eligible employees pursuant to a health reimbursement arrangement (HRA) for medical costs the employee or covered family members incur that are not payable by the Lifewise Option III PPO medical insurance solely because of that program's deductible and that exceed the deductible amounts of the Lifewise Traditional Option II plan ($200 individual, $500 family) for the deductible year for the level of coverage the employee has pursuant to the Lifewise Option III PPO medical insurance. The District shall also reimburse eligible employees pursuant to the HRA $5 for each co-pay charge the employee incurs in connection with a covered medical expense. In addition, the District shall contribute 90% of the premium amount to the current dental insurance plan (Blue Cross Blue Shield of Oregon, Benefits: $1000 per year, $25 deductible).
Effective August 1, 2005, the District shall continue to contribute 90% of the premium amount to a medical and dental insurance plan that provides substantially similar benefits to the parties' previous medical and dental insurance plan. To the extent that the deductible amounts of the medical insurance plan exceed the deductible amounts of the Lifewise Traditional Option II plan for the deductible year, the District shall, upon receiving documentation satisfactory to the program administrator, reimburse eligible employees pursuant to the HRA for medical costs the employee or covered family members incur that are not payable by the medical insurance solely because of that program's deductible for the level of coverage the employee has pursuant to the medical insurance plan.
Effective July 1, 2004, increase wages of all classifications by 2.2%.
Effective July 1, 2005, increase wages of all classifications by the amount of the increase in the CPI-W, All Cities Index (annual increase).
Effective July 1, 2006, increase wages of all classifications by the amount of the increase in the CPI-W, All Cities Index (annual increase).

1. In making its argument the District asserts it needs to hire enough firefighters, so that it can have 5 per shift. With any fewer, it is sometimes obliged to run engines with three firefighters because of vacation, illness, and other normal time off. This, it notes, is not in conformance with state and national fire protection standards.
2. Current cost of $ 775,081.00 X 115.97% = $898,861-$775,081=$ 123,780.44 The number is a rough approximation because it does not separately calculate wages and wage driven costs, but takes the initial cost and multiplies it by the compounded raise.
3. The calculation is based on the current cost of payroll (with roll-ups) of $775,081 shown on the corrected Union page 49. Since it uses gross figures it is an approximation, rather than an exact calculation.
4. The District understates the savings because it includes reimbursement of non-bargaining unit employees when netting out the cost savings. (Ex. E-21)
5. Adding $20,000 for increases in the Ambulance Fund revenues does not affect the overall comparison.
6. It adds two more jurisdictions that are rural and similar in population.
7. IAFF argues that this is really an ability to pay criterion. It may well be correct. Nevertheless, large differences in TAV argue against considering two entities comparable when comparing wages and benefits, because one does not have the revenue to pay the wages and benefits enjoyed by the other.
8. All are calculated after the District's 2.2% proposed increase.