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HomeMy WebLinkAbout7A2 - LELS Police OfficersSTAFF AGENDA REPORT AGENDA #: PREPARED BY: SUBJECT: DATE: 7A-2 ~ FRANK BOYLES, CITY MANAGER"~,- \ ~// CONSIDER APPROVAL OF LABO.~," AGREEMENT REPRESENTING POLICE OFFIC~ FEBRUARY 6, 1995 FOR LELS BACKGROUND: DISCUSSION: After numerous negotiation sessions last year it became apparent to both parties that it would not be possible to reach agreement on certain issues. The issues of particular concern to both parties were: Pay for performance/longevity, caps on city health and dental contributions and wages. Under state law police officers may not strike. In lieu of strike they may request binding arbitration. Accordingly, arbitration was requested and a hearing was held in November, 1994. In December the arbitrator rendered his decision. Unfortunately, the decision contained an important mathematical error with respect to wages and had to be referred back to the arbitrator for clarification. On Tuesday, January 31 we received a copy of the arbitrator's clarification to the award and I am therefore placing this item on the February 6 agenda in order that it can be addressed expeditiously. Initially fourteen issues were referred to the arbitrator. Prior to the arbitration, the parties resolved four issues including: 1. Duration - agreed to a 1994/1995 contract. . Life Insurance Maximum Benefit - agreed to a $40,000 benefit to be paid from city contributions previously made toward the discontinued short term disability. 3. Dental Insurance Benefits - The benefit will be unchanged for the 1994/1995 contract. 4. Retroactivity - The wages and benefits for the contract will be retroactive to January 1, 1994. The arbitrator considered ten issues which are outlined in his award (attached) dated December 13, 1994. Shown below for Council information is a summary of the arbitrator's final award including his January 27, 1995 revision to wages: 1. 1994 Wages - Increased by 2.84% from $3305 per month for a 36 month employee to $3399 per month. 16200 Eagle Creek Ave., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTUNITY EMPLOYER ISSUES: ALTERNATIVES: 2. 1995 Wages - Increase by 3.0% for a 36 month employee from $3399 to $3501 per month. 3. 1994 Health Insurance - City pays 100% of the cost. 4. 1995 Health Insurance Contribution - City contribution capped at $380 effective January 1, 1995. o Long Term Disability Insurance - Add an employer contribution of up to $25 per month to be applied to a long term disability policy or to the health insurance contribution if an LTD policy is not available. 6. 1994 Dental Insurance Contribution - City pays 100% of the cost of the insurance. 7. 1995 Dental Insurance Contribution - City contribution capped at $40.00 per month. 8. Skill/Physical Fitness Pay Option - not implemented. 9. Longevity - To remain as set forth in the 1993 contract. 10. Interest On Retroactive Wages - None. Arbitration is always a risk for both parties since the matter is placed in a third party's hands. The city did make progress with respect to capping its contributions for both health and dental insurance. This is particularly important since our contributions ranked among the highest in the metropolitan area, and given the volatile nature of insurance premiums. With respect to Pay for Performance/Longevity, the arbitrator did not elect to adopt our proposal to delete longevity for new police officers only and offer those individuals a revised Pay for Performance system. The arbitrator relied primarily on external comparisons between police departments rather than internal city comparisons. With respect to wages, the arbitrator sought to retain the existing relationship between the pay for Prior Lake police officers and the cities in the group 5 and 6 DCA Stanton Survey. These are cities that are approximately the same size as Prior Lake from a population perspective. The arbitration award is binding on both parties. Therefore, there is no action the council can take but to authorize implementation of the award. The State now requires that the attached Uniform Settlement Form be completed for each contract settlement. Based upon the methodology used in this report the cost of the 1994 agreement is 7.25%, the cost in 1995 is 3.69% The alternatives are to: . Approve the attached labor agreement which incorporates the arbitration award of December 13, 1994 as modified by the arbitrator's letter of January 27, 1995, and authorize the Mayor and City Manager to execute the Agreement. RECOMMENDATION: ACTION REQUIRED: . Defer approval for a future date if Councilmembers have additional questions. Alternative #1. Motion and second to: . Adopt the arbitrator's award as modified by his January 27, 1995 letter. . Authorize the Mayor and City Manager to execute a labor agreement for 1994 and 1995 with Law Enforcement Labor Services, Inc. representing police officers and detectives. A copy of the unsigned contract will be provided to the council on Friday together with the update memorandum. I hope to have copies of the signed agreement at the Council meeting on Monday night. FB7A2.WRT DEC-!9-!95~ R~T:~!K, ~OSZmK. ET ~L. P.A_! IN THE MATTER OF ARBITRATION between City of Prior Lake, Minnesota -and- Law Enforcement Labor Services ))))))))))))) ;) ))))))))))))))));))) APPEARANCES __ INTEREST ARBITRATION BMS Case No. 94-PN-1849 December' 13, 1994 For Cit~ of Prior Lake Peter Bergstrom, Minneapolis, Bonnie Carlson, Attorney, Ratwik, Roszak, Minnesota Assistant City Manager _Fo~ La__~w Enforcement Labor Services _ Roland Miles, Business Representative Tom Erickson, Steward Dennis Leff, Police Officer Fred Bock, Police Officer Bergstrom & Maloney, JURISDICTION OF ARBITRATOR The Law Enforcement Labor Services (hereinafter referred to as the "Union") is the certified bargaining representative for all employees of the Prior Lake Police Department employed by the City of Prior Lake (hereinafter referred as the "City" or "Employer") for more than 14 hours per week, and more than 100 work days per year, excluding the Chief of Police, supervisory and confidential employees. The Parties have been signatories to several collective bargaining agreements dating back to a~ least January 1, 1984. Prior to that time, the Police Department employees were DEC-19-199~ 16:!6 PRO~ RAT~IK, ROSZ~K. ET ~L. TO organized and duly represented by Minnesota Teamsters Local No. 320. The Parties have been unable to reach a negotiated settlement of the 1994 and 1995 contract. The Parties negotiated and mediated their disputes but did not find common ground for settlement. The issues remaining at impasse are subject to conventional interest arbitration under the provisions of the Minnesota Public Employment Labor Relations Act, Section 179, as amended. A hearing in the matter convened on November 17, 1994, at 10:00 a.m. at the Prior Lake City Hall, Prior Lake, Minnesota. The Parties were afforded full opportunity to present evidence and arguments in support of their respective positions. The Parties waived the £iling of post hearing briefs, after which the ~ecord was considered closed on November 17, 1994. BACKGROUND The Minnesota Bureau of Mediation Services ("BMS") certified fourteen issues to impasse on June 28, 1994. The Commissioner, Peter E. Obermeyer, stated in his June 28, 1994 letter to Union Business Representative Roland Miles and City Attorney Peter D. Bergstrom that "[e]ach party shall submit their final positions on these items to the Bureau not later than July 13, 1994." The Union complied with that directive by submitting their final positions on June 30, 1994. The City did not comply with Mr. Obermeyer's directive, even after the Union attempted on DEC-!9-!99~ ~P,:~, ~RO~ R~TW!K. ROSZ~K. E~ ~L. TO ~?~5 P.05 several occasions to obtain the City's final position beyond June 30, 1994. It was not until the arbitration hearing that the Union first learned of the City's final positions on the issues certified at impasse. As a result, the Union claims that the Arbitrator should rule that all of the City's final positions offered at the hearing are inualid, illegal and unlawful. The Arbitrator does not have the authority to rule on the Union's contention since it deals with an interpretation of the Minnesota statutes. Such interpretation of statutory matters are within the jurisdiction of the courts and the Arbitrator. The Parties, however, agreed that the Arbitrator should rule on the unresolved impasse items certified by BMS, pending possible appeal by the Union. Prior to the start of the arbitration, the Parties [esolved four of the issues, namely duration (issue 1), life insurance- maximum benefit (issue 7), dental insurance - benefit (issue 8) and ~etroactivity (issue 13). AS to duration, the Parties agreed to the Union's final position for a two year agreement from January 1, 1994, to December 31, 1995. With regard to life insurance-maximum benefit, the Union agreed to the City's final offer to increase the Employer paid life insurance benefit to $40,000, contingent upon the elimination of the current short term disability program. There is no issue regarding any Union proposed change in the current dental insurance benefit. The Parties have agreed that the current dental insurance benefit shall remain unchanged for the 1994-95 contract. Finally, the Parties agreed that the Employer shall pay all back pay retroactive to January 1, 1994. Any change in benefits or benefit levels awarded by the Arbitrator shall be commended as soon as possible after receipt of his decision or that date shall be determined by the Arbitrator. As a result of the Parties resolving four of the items certified at impasse by BMS, there are only ten issues left for decision by the Arbitrator. The ten remaining issues at impasse are as follows: 2. Wages - 1994 3. Wages - 1995, if applicable 4. Health Insurance - 1994, Employer Contribution 5. Health Insurance- 1995, Employer Contribution, If Appl icabl e 6. LTD Insurance 9. Dental Insurance - 1994, Employer Contribution 10. Dental Insurance- 1995, Employer Contribution, If Applicable 11. Skill/Physical Fitness Pay Option 12. Longevity 14. Earned Interest on Retroactive Wages POSITION OF THE PARTIES The Union proposes to increase the 1993 wage rates by 4%, e~fective January 1, 1994, and increase the 1994 wage rates by 4%, effective January 1, 1995. The City proposes for 1994 to increase the 1993 wage rates by 1%, plus step increases under ~he contract, as applicable. The City's final offer for 1995 is no wage increase, ~ut s~ep increases, as applicable. · DEC-!9-!99~ 1~:17 ~RO~ R~TI~[K, ROSZ~K, ET ~L. TO ~2~5 P.OS The City proposes that the Employer's contribution toward employee and dependent health insurance be capped at $380 per month, effective October l, 1994. The Union proposes to maintain the current contract language in Article XXII, Sections 22.1 and 22.2, wherein the Employer shall pay 100% of the premium for employee and dependent health insurance. The Union proposes that the Employer shall provide and pay for a Long Term Disability (LTD) insurance policy that shall pay benefits at least 60% of salary after a 90 calendar day waiting period per injury and pay benefits until the age of 65 years as long the injured is unable to perform the substantial and material duties of his/her regular occupation. The City opposes the inclusion of this new fringe benefit. The City proposes that the Employer's contribution to employee and dependent dental insurance be capped at $40 per month, effective October 1, 19~4. The Union proposes to maintain the current contract language in Article XXII, Section 22.3, wherein the Employer shall pay 100% of the pcemium for employee and dependent dental insurance. The Union proposes that employees be allowed the option of maintaining current longevity payment or an alternative pay program that recognizes an officer's worth based on wellness, education, physical fitness and community service in lieu of longevity. The City opposes the alternative pay program. The City proposes that longevity be eliminated for new employees hired after January 1, 1994. The Union seeks to DE,3-19.-!99~-~-,:- _,_,~':, FRAm RAT~.~[K_ · RA~Z4K. __ , PT_ ~._ TF~_ 4~n, ~2~5 P. AP,__ maintain the current longevity pay plan which appeared in Article )IIX of the contract as follows: Effective 1-1-84 Three percent (3%) after four (4) years of service Five percent (5%) after eight (8) years of service Seven percent (7%) after twelve (12) years of service Nine percent (9%) after sixteen (16) years of service The Union proposes that the Employer shall pay interest at the legal rate for all retroactive pay. The City opposes an interest payment. AWARDS The 1994 wage rates for Top Patrol shall be increased to $3399 (3.18%), effective January 1, 1994. The 1995 wage rates for Top Patrol shall be increased to $3485 (2.53%), effective January 1, 1995. The Employer's contribution toward employee and dependent health insurance shall be capped at $380 per month, effective January 1, 1995. The Employer's contribution to employee and dependent dental insurance shall be capped at $40 per month, effective January 1, 1995. The Employer shall provide and pay for a Long Te~m DisaBility (LTD) insurance policy, effective as soon as the Employer can find an insurance carrier and the Parties agree upon LTD benefits. The City's payment toward LTD insurance shall not exceed $25 per month, effective January 1, 1995. If a LTD plan is not available DEC-19-199~ I~,:~A PRO~ R~T~IK. ROSZAK, ET AL. TO ~'?~5 P.~9 or if the Parties cannot agree upon the benefits, employees are entitled to use up to $25 per month, effective January 1, 1995, to offset the difference Detween the cost of the employee and dependent health and/or dental insurance premium and the capped amoun ts. Employees are not entitled to an alternative pay program that recognizes an officer's worth based on wellness, education, physical fitness and community service in lieu of longevitY. The longevity pay plan which currently appears in the contract shall remain unchanged. Employees are not entitled to receive the legal rate of interest for all retroactive pay. RAT I ONALE The role of an interest a[biurator is to predict what the parties would have agreed to had negotiations been continued to finality. In any interest arbitration dispute there are generally three factors that should be considered. The first is the financial ability of the employer to fund the economic proposals made by the bargaining unit. members. If there is adequate funds available, the case then generally falls on internal and/or external comparability. Finally, pas~ bargaining history of the parties is a valid consideration. The City is in healthy financial condition when one considers total tax capacity, per capita tax capacity, Homestead & DEC-!9-!99~ 16:19 PRO~ RATIO!K, ROSZAK. ET ~L. TO ~9~5 P.08 Agricultural Credit Aid (HACA), Local Government Aid (LGA), budgeted to actual expenditures, unreserved, undesignated general fund balances, property taxes and property taxes levied. In light of this evidence, the City never raised an inability to pay argument, but only that the Arbitrator should use financial constraint when making his awards in light of the two other factors (comparability and past bargaining history). The Arbitrator adhered to this principle in rendering his decision. The Employer believes that wages, hours and othe~ terms and conditions of employment for City employees must be determined by an examination of its unique facts and circumstances. While the wage and benefit rates in a neighboring or distant community may be of interest, the City contends that the determining factors must be those generated within the City. The Union, on the other hand, contends that the Arbitrator should concentrate more on the external market, i.e. comparing the salaries and fringe benefits paid to patrol office~s in Prior Lake to those in othe~ surrounding cities contained within Stanton Group Five and Stanton Group Six. The City is located on the southern edge of the Twin City metropolitan area, with a population of 11,876 and is one of the smallest cities in the Stanton Group Six survey grouping. The City borders the City of Savage on the north and the City of Shakopee on the northwest. Both of these cities are on the developing southern and western edges of the metropolitan area; each borders Prior Lake; and each represents circumstances, DEC-19-!99~ 16:!9 PROM RATt~!K, ROSZ~K. ET ~L. TO 449424~ P.~9 including population, location and scope of development, similar to those found in Prior Lake. In the 1993 Stanton survey, Prior Lake was in Group ~ive - Suburbs over 10,000. Stanton Group Six contained cities under 10,000 people. In 1994, Stan=on changed its groupings to include Group 5 - Suburbs over 25,000; Group Six - Suburbs under 25,000 and over 10,000; and Group Seven - Suburbs under 10,000. Prior Lake now falls under Group Six. Past bargaining history shows that the Parties have negotiated using the cities contained within former Stanton Group Pive, which is now combined into Groups Five and Six, for comparison purposes. There is no evidence that the Parties narrowed their scope of comparison to only Savage and Shakopee in the past or agreed to only these cities during current negotiations. For these reasons, Prior Lake should be compared to those cities now contained in Stanton Group Five and Group Six (old Group Five cities). The trend has been since 1991 that Prior Lake has been slightly above the average for Top Patrol monthly salaries compared to the comparison cities. In 1993, the last year of expired contract, the City was $11 per month above the average. The Arbitrator's award of $3399 (3.i8%) for 1994 and $3485. (2.53%) for 1995 maintains the bargaining history established by the Parties. The award for both years is $11 above the average of those comparable cities with settled contracts for 1994 and 1995. DEC-!9-!99~ 16:~ FRO~ RATWiK. ROSZAK, ET ~L. TO ~9~5 P.!O The Local Government Pay Equity Act (LGP£A) requires the City to establish equitable compensation relationships between its female dominated, male dominated and balanced classes of employees or suffer a 5% reduction in local ~overnment aid. Minn. Stat. Section 471.9981 (1992). An arbitrator must consider the City's comparable worth plan when settling an interest arbitration dispute. Minn. Stat. Section 471.992, subd. 2 (1992). The unit involved in this case is defined by the LGPEA as being composed of male-dominated classifications. The underpayment ratio is the most important number in the statistical analysis under LGP£A. TO pass the ssatis[ical analysis test, the underpayment ratio must be 80% or greater. Another important consideration is the T-Test and Degrees of Freedom. These numbers are used only for jurisdictions with an underpayment ratio below 80%, at least six male classes and at least one class with a salary range. If an underpayment ratio is 80% or more, these numbers are not used nor are they used for jurisdiction in the alternative analysis. The Salary Range Test and the Exceptional Service Pay Test are valid considerations for comptiamce. These numbers must be either 0% or 80% or more to pass these tests. Under all of the above tests, the City remains in compliance under the salary awards rendered by the Arbitrator. In fact, even if the Arbitrator would have awarded that which was sought by the Union, which is greater than awarded by the Arbitrator, the City would have remained in compliance. 10 DEC-19-199~ 16:20 PRO~ RAT~d!K~ ROSZAK, ET ~L. TO ~9~d5 P.!i In that the City is in compliance with LGPEA, external comparability is more important than internal comparability. Moreover, there is no evidence that the City has maintained any consistent historical internal settlements among its employee groups. The other units within the City (administration, AFSCME, management and Teamsters) have negotiated or received increases in the 1.25% to 7.5% range for 1994 and only AFSCME has settled for 1995 (2.42% increase). In addition to wages, these settlements include cost of living adjustments, longevity, education incentive pay and performance increases. The maintenance of the current wage schedule (without the Arbitrator's salary award) provides the unit with more than a 14% increase in total package costs for 1994, which is about twice as much as the next highest unit (administration - 7.50%). The greater increases (including cos~ of living adjustments, longevity, education incentive pay or performance increases) enjoyed by this unit for many years were a product of negotiations between the Parties and were never used against the unit when establishing a wage settlement with comparable cities that in recent years have been above the average. Wa~es, like longevity, have been compared externally rather than internally by the Parties. Arbitrators, in general, adhere to this philosophy. The current longevity p=ogram, which was negotiated by the Parties many years ago, applies to all employees and is far more consistent with that provided for in comparable cities than the 11 DEC-19-!99~ !6:21 PRO~ R~T~!K, ROSZAK. ET AL. City's proposal to eliminate the current longevity program for those employees hired after January 1, 1994. Although there are some cities in which new employees must choose between a longevity ~rogram or a pay for performance program, the City nas ~esisted in this arbitration the option of an employee choosing between a performance program or maintaining the current longevity plan. As such, there are no convincing reasons to change f~om the current longevity pay plan, which provides this benefit to all employees who are now in the employ of the City or will be in the future. Employee groups within the City have enjoyed for many years the benefit of fully paid employee and dependent health and dental insurance. The City pays mo[e for these insurances than the vast majority of the comparable cities. The cos~ of these benefits have risen so steeply in the past several years that the City has negotiated a cap of $380 per month for medical and a $40 per month cap for dental insurance with the AF$CME unit for 1994 and 1995. The City has also adopted the same caps for its non-union employees. All other City employees have had these caps since October 1, 1994. The $40 dental cap currently covers the entire cost of this insurance. If employees elect to participate in family coverage under Group Health (cheapest monthly plan), their current co- payment will only be $5.58 per month. If they elect to participate in one of the other three health plans, their co- payment per month will be greater, up to $59.54 per month (Blue Plus) . 12 DEC-19-199~ 16:2! FROm RAT;~[K, ROSZAK. ET aL. TO ~2~5 P. IJ Although bargaining history is important, so too is the l~hilosophy held by many arbitrators that fringe benefits should be standardized among employees within the employ of the public employer. The Arbitrator is also uery mindful that this unit has enjoyed fully paid health and dental for many years by virtue of negotiating these benefits into the contract. The City s=ated that if these insurance benefits could be capped there could be the possibility to venture into other fringe benefits. One of these benefits proposed by the Union was LTD insurance. Although LTD insurance is not common among other City employees, it is common among other comparable cities that employ police officers. In that the Parties were at a stalemate over these issues, the Arbitrator has awarded an equitable quid pro quo by grantin9 the City's request to cap both health and dental insurance, in exchanqe for a new LTD insurance benefit, with a maximum contribution by the City of $25 per month. The Arbitrator has essentially awarded that which most likely would have evolved in contract negotiations through tradeoffs in the absence of arbitration. The Arbitrator has provided some protection to the employees if LTD insurance is not available from the Employer selected insurance carrier or if the Parties cannot negotiate the benefits o4 the LTD plan. In that regard, if a LTD plan is not available or if the Parties cannot agree upon the benefits, employees are entitled to use up to $25 per month, effective January 1, 1995, to offset the difference between the cost of the employee and 13 DEC-19-199~ 16:22 PRO~ R~T:~!K. ROSZ~K. ET dependent health and/or dental insurance premium and the capped amounts. The Union stated that a LTD plan such as the one in the City of Lakeville would be acceptable and the cost of that plan is approximately $23 to $25 per month. The Parties created a task force for the purposes of studying, reviewing and recommendin9 an alternative pay program to the existing longevity plan. In other words, the employee would have the option to receive longevity or be paid compensation under the skill/physical fitness pay plan. The task force was successful in drafting a skill/physical fitness pay but the City has not yet implemented the plan because it is too expensive. The City would be willing to implement the plan if the Union would agree to the elimination of longevity, which the Union ~efuses to do. The Arbitrator denies the inclusion of the skill/physical fitness pay option in lieu of longevity as an alternative pay program because the City never agreed to it. It must be remembered '~ ' -~,at zn the Letter of Understanding dated April 1, 1992, both the Union and the City agreed to make an independent decision on whether or not to participate in the optional pay plan developed by the task force. The City has chosen not to participate and the Arbitrator cannot compel enforcement. This issue is better left to the Parties for future resolution. The Arbitrator, afte: review of all the evidence relating to the issue of whether the City should pay interest at the legal rate for all retroactive pay, must deny the Union's demand. There 14 · DEC-19-i99~ 16:22 PROM R~TI~IK. ROSZ~K. ET ~L. is no evidence that the City or its attorney intentionally delayed the .scheduli, ng of the arbitration hearing to the detriment of the Union. The l~rocess of negotiations, mediation and finally interest arbitration ali contributed to the delays in this case, but such delays were not excessive under the circumstances. Both Parties are to be complimented on their professional conduct at the hearing and the comprehensi-4eness of their written and oral presentations. ~r Dated December 13, 1994, at Maple Grove, Minnesota. 15 ARBITRATOR 7919 ORCt4ID LANE NOR'I'll '. MAPLI'~ GR(~/E, MINNESOTA 35311 -- PHONE & FAX: (012) 494.-3260 January 27, 1995 Mr. Roland Miles Business Representative Law Enforcement Labor Services, Inc. 2051 KilleDrew Drive, Suite 403 Bloomington, Minnesota 55425-1867 Mr. Peter Be~gstrom Attorney " Ratwik, Roszak, Bergstrom & Maloney 300 Peavey Building 730 Second Avenue South Minneapolis, Minnesota 55402 Re: Interest Arbitration between City of Prior Lake -and- LELS BMS Case No. 94-PN-1549 Representat ives: By letter dated December 23, 1994, Mr. M~].es submitted a request for clarification of my award in the above-captioned matte~ dated December 13, 1994. As indicated by Mr. Miles, copies of this lette~ were $~bl~itted to Mr. Be~gstrom, and Union Stewards Chris Olson and Tom Erickson. The clarification requcs~ is made pursuant to M.$. 572.16 and M.S. 572.20, Subd. 1, clause 1. The City did not respond to Mr. Miles' request for clarification. S.S. 572.20, Subd. 1, clause 1 states: There was an evident miscalculation of figures or an evident mistake in the description of any person, thing, or property referred in the award; On page 6 of my award, the following is stated: The 1994 wage rates for Top Patrol shall be increased to $3,399 (3.18%), effective January 1, 1994. The ].995 wage '~a~eS for Top Pat£ol shall be ~ncreased to $Z,485 (2.53%), effective January 1, 1995. Messrs. Miles and Bergstrom January 27, 199 5 Page 2 The intent of the arbitrator's award was to maintain the City of Prior Lake at $11 per month above the average and as close to the 5.8% two-year settlement rate (1994 and 1995) for Stanton Group V and VI cities. For 1994, the dollar figure awarded of $3,399 is correct but the percentage contains an error. The stated, percentage of 3.18% was incorrectly calculated. The 3.18% was based on the average of the Stanton ~rou~ v and.VI cities for 19.93 of $3,294 and then compared to the award of $3,399. This was an error on the arbitrator's partr since the percentage increase should have been calculated by taking the difference between the 1994 and 1993 wages rates of the City. When this calculation is completed ($3,399 - 3,305 = $94 divided by $3,305), it results in a 2.84% increase and not a 3.18% for 1994. The percentage error in 1994 is compounded for 1995. Kather than having a percentage increase of 3.18% (1994) and 2.53% (1995) for a two-year total of 5.71%, the error in 1994 reduced the two-year total to 5.37% ('2.84% - 1994 and 2.53% - 1995). The percentage settlement rate for the comparable cities is 2.8% (1994) and 3.0% (1995) for a total of 5.8% for both years. As noted previously, it was not the intent of the arbitrator to award less than the percentage or dollar average of the comparable cities but to keep the City at slightly above the average. The difficulty, of course, is one does not know what the average of the comparable cities will be for 1995 at this time, since less than one-half of the cities are not settled for that year. One method to rectify this error would be to wait until all of the comparable cities settle for 1995 and then give the Top Patrol an amount which is $11 above that average. A better method would be to give them a 3.0% increase for 1995, which is the current settlement rate. A 3.0% increase for 1995, coupled with a corrected 2.84% for 1994, yields a two- year total of 5.84%, which is slightly above the average of 5.80% of the comparable cities. This corrected award should place the City about $11 above the average, which complies with the intent of the arbitrator's award. Thus: the corrected award is to ~.rant To? Patrol a wa~e increase of 2.84% for 1994 and a 3.0% for 1995. I am sorry for making this error. Sincerely, Ric~rd John Miller