HomeMy WebLinkAboutResolution - 2021-27 - Authorize Entry into Labor contract with Law Enforcement Labor Services, Inc. - 04/06/2021CITY OF EDEN PRAIRIE
HENNEPIN COUNTY, MINNESOTA
RESOLUTION NO. 2021-27
A RESOLUTION APPROVING AND IMPLEMENTING THE 2021-2022 LABOR
AGREEMENT BETWEEN THE CITY OF EDEN PRAIRIE AND LAW
ENFORCEMENT LABOR SERVICES, INC. (LOCAL #430)
WHEREAS, the current Labor Agreement between the City and Law Enforcement Labor
Services Inc. (Local #430) ("LELS") governing police patrol officers expired on December 31,
2020;and
WHEREAS, the City and LELS participated in contract negotiations on a new Labor
Agreement governing the period from January 1, 2021 through December 31, 2022 and reached a
tentative agreement in March 2021 which is attached hereto as Exhibit A; and
WHEREAS, the tentative agreement is subject to the approval of and implementation by
the City Council in accordance with Minn. Stat. § 179A.20, subd. 5.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Eden
Prairie, Minnesota that: (i) the 2021-2022 Labor Agreement between the City of Eden Prairie and
Law Enforcement Labor Services Inc. (Local #430) attached as Exhibit A is hereby approved and
may be executed by the Mayor and City Manager; and (ii) City staff are hereby authorized to
implement the agreement.
ADOPTED by the Eden Prairie City Council this 6th day of April, 2021.
Ronald A. Case, Mayor
ATTEST:
EXHIBIT A
2021-2022 Labor Agreement between
City of Eden Prairie and
Law Enforcement Labor Services, Inc. (Local #430)
2021-2022
LABOR AGREEMENT
BETWEEN
THE CITY OF EDEN PRAIRIE
AND
LAW ENFORCEMENT LABOR SERVICES, INC.
{LOCAL #430)
Effective January 1, 2021 through December 31, 2022
INDEX
ARTICLE I. PURPOSE OF AGREEMENT ................................................................. 1
ARTICLE II. RECOGNITION ................................................................................... 1
ARTICLE Ill. UNION SECURITY .............................................................................. 1
ARTICLE IV. EMPLOYER
SECURITY ........................................................................ 2
ARTICLE V. EMPLOYER AUTHORITY ..................................................................... 2
ARTICLE VI. EMPLOYEE RIGHTS-GRIEVANCE PROCEDURE .................................... 3
ARTICLE VII. DEFINITIONS ................................................................................... 5
ARTICLE VIII. SAVINGS CLAUSE ........................................................................... 6
ARTICLE IX. WORK SCHEDULES .......................................................................... 6
ARTICLE X. OVERTIME PAY ................................................................................. 6
ARTICLE XI. CALL BACK AND COURT PAY ............................................................. 7
ARTICLE XII. DISCIPLINE ..................................................................................... 7
ARTICLE XIII. SENIORITY ..................................................................................... 8
ARTICLE XIV. PROBATIONARY PERIODS ............................................................... 8
ARTICLE XV. SAFETY .......................................................................................... 8
ARTICLE XVI. INSURANCE .................................................................................... 9
ARTICLE XVII. UNIFORMS .................................................................................... 9
ARTICLE XVIII. INJURY ON DUTY .......................................................................... 9
ARTICLE XIX. ANNUAL PAID LEAVE AND HOLIDAYS ............................................... 9
ARTICLE XX. WAIVER ........................................................................................ 10
ARTICLE XXI. DURATION .................................................................................... 10
APPENDIX A. WAGES ......................................................................................... 11
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ARTICLE I. PURPOSE OF AGREEMENT
This AGREEMENT is entered into between the City of Eden Prairie hereinafter called the
EMPLOYER, and Law Enforcement Labor Services, Inc., hereinafter called the UNION.
The intent and purpose of this AGREEMENT is to:
1.1 Establish certain hours, wages and other conditions of employment;
1.2 Establish procedures forthe resolution of disputes concerning this
AGREEMENT'S interpretation and/or application;
1.3 Specify the full and complete understanding of the parties; and
1.4 Place in written form the parties' agreement upon terms and conditions of employment
for the duration of this AGREEMENT. The EMPLOYER and the UNION, through this
AGREEMENT, continue their dedication to the highest quality of public service. Both
parties recognize this AGREEMENT as a pledge of this dedication.
ARTICLE II. RECOGNITION
2.1 The EMPLOYER recognizes the UNION as the exclusive representative for all
EMPLOYEES in the job classifications listed below who are public EMPLOYEES
within the meaning of Minn. Stat. §179A.03, Subdivision 14, excluding supervisory,
confidential and all other EMPLOYEES:
All licensed essential employees of the Eden Prairie Police Department who are
public employees within the meaning of Minn. Stat. 179A.03, subd. 14, excluding
supervisory and confidential employees.
ARTICLE Ill. UNION SECURITY
In recognition of the Union as the exclusive representative the EMPLOYER shall:
3.1 The UNION will obtain written authorization from the EMPLOYEE for the
deduction from wages of union dues established by the UNION. The UNION will
forward the written authorization from EMPLOYEE to EMPLOYER.
3.2 The EMPLOYER will deduct the amount authorized by the EMPLOYEE and
remit the amount to the appropriate designated officer for the UNION commencing
no later than the first pay period of the next month with proper employee
authorization.
3.3 When an EMPLOYEE is in non-pay status for the entire pay period in which a
deduction would be taken, no withholding will be made to convert that pay period
from future earnings. In the case of an EMPLOYEE who is in non-pay status during
only part of the pay period in which a deduction would be taken, and the wages are
not sufficient to cover the full withholding, no deductions shall be made.
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3.4 The UNION may designate certain EMPLOYEES from the bargaining unit to act as
stewards and shall inform the EMPLOYER in writing of such choice.
3.5 The UNION agrees to indemnify and hold the EMPLOYER harmless against any and
all claims, suits, orders, or judgments brought or issued against the City as a result of
any action taken or not taken by the City under the provisions of this Article.
3.6 The EMPLOYER will provide reasonable space on one EMPLOYEE bulletin board
for union postings. Union stewards will be responsible for maintaining the
designated space. All postings will comply with City policies, including the policy on
political neutrality. Postings shall first be approved by the Police Chief.
ARTICLE IV. EMPLOYER SECURITY
4.1 The UNION agrees that during the life of this AGREEMENT it, nor any of the
EMPLOYEES covered by this Agreement, will not cause, encourage, participate in
or support any strike, slow down, other interruption of or interference with the
normal functions of the EMPLOYER.
ARTICLE V. EMPLOYER AUTHORITY
5.1. The UNION recognizes the right and authority of the EMPLOYER to operate and
manage its affairs in all respects in accordance with its management rights, existing
and future laws and regulations of the appropriate authorities. The rights or authority
which the EMPLOYER has not officially abridged, delegated or modified by this
Agreement are retained by the EMPLOYER.
5.2 The EMPLOYER retains the full and unrestricted right to operate and manage all
manpower, facilities, and equipment; to establish functions and programs; to set and
amend budgets; to determine the utilization of technology; to establish and modify the
organizational structure; to select, direct and determine the number of personnel; to
establish work schedules; and to perform any inherent managerial function not
specifically limited by this AGREEMENT.
5.3. The EMPLOYER'S failure to exercise any right, prerogative, or function hereby reserved
to it, or the EMPLOYER'S exercise of any such right, prerogative, or function in a
particular way, shall not be considered a waiver of the EMPLOYER'S right to exercise
such right, prerogative, or function or preclude it from exercising the same in some other
way not in conflict with the express provisions of this Agreement.
5.4 The parties recognize that all EMPLOYEES covered by this Agreement shall perform the
services and duties prescribed by the EMPLOYER and shall be governed by EMPLOYER
rules, policies, regulations, directives and orders, provided that such rules, regulations and
orders are not inconsistent with the provisions of this Agreement or state or federal laws. The
EMPLOYER will provide EMPLOYEES with notice of any proposed change in any policy
applicable to the bargaining unit members.
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ARTICLE VI.EMPLOYEE RIGHTS-GRIEVANCE PROCEQURE
6.1 DEFINITION OF A GRIEVANCE
A grievance is defined as a dispute or disagreement as to the interpretation or
application of the specific terms and conditions of this AGREEMENT.
6.2 UNION REPRESENTATIVES
The EMPLOYER will recognize representatives designated by the UNION as the
grievance representatives of the bargaining unit having the duties and
responsibilities established by this Article. The UNION shall notify the EMPLOYER
in writing of the names of such UNION REPRESENTATIVES and of their
successors when so designated.
6.3 PROCESSING OF A GRIEVANCE
It is recognized and accepted by the UNION and the EMPLOYER that the processing
of grievances as hereinafter provided is limited by the job duties and responsibilities of
the EMPLOYEES and shall therefore be accomplished during normal working hours
only when consistent with such EMPLOYEE duties and responsibilities. The
aggrieved EMPLOYEE andthe UNION REPRESENTATIVE shall be allowed a
reasonable amount of time without loss in pay when a grievance is investigated and
presented to the EMPLOYER during normal working hours provided the EMPLOYEE
and the UNION REPRESENTATIVE have notified and received the approval of the
designated supervisor who has determined that such absence is reasonable and
would not be detrimental to the work programs of the EMPLOYER. The designated
supervisor will be notified when the steward or grievant EMPLOYEE(S) returns to the
workstation and resumes duties.
6.4 PROCEDURE
Grievances, as defined by Section 6.1, shall be resolved in conformance with the
following procedure:
Step 1. An EMPLOYEE claiming a violation concerning the interpretation or
application of this AGREEMENT shall, within fourteen (14) calendar days after such
alleged violation has occurred, present such grievance in writing to the
EMPLOYEE'S Sergeant. The Sergeant will discuss and will respond in writing to such
Step 1 grievance within fourteen (14) calendar days after receipt. A grievance not
resolved in Step 1 and appealed to Step 2 shall set forth the nature of the
grievance, the facts on which it is based, the provision or provisions of the
AGREEMENT allegedly violated, and the remedy requested and shall be appealed
to Step 2 within ten (10) calendar days after the Sergeant's final answer in Step 1.
Any grievance not appealed in writing to Step 2 by the UNION within ten (10)
calendar days shall be considered waived.
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Step 5.
Step 2. If appealed, the written grievance shall be presented by the UNION and
discussed with the Division Lieutenant. The Division Lieutenant shall give the
UNION the EMPLOYER'S Step 2 answer in writing within ten (10) calendar days
after receipt of such Step 2 grievance. A grievance not resolved in Step 2 may be
appealed to Step 3 within ten (10) calendar days following the Division Lieutenant's
final Step 2 answer. Any grievance not appealed in writing to Step 3 by the UNION
within ten (10) calendar days shall be considered waived.
Step 3. If appealed, the written grievance shall be presented by the UNION and
discussed with the Police Chief. The Police Chief shall give the UNION the
EMPLOYER'S answer in writing within ten (10) calendar days after receipt of such
Step 3 grievance. A grievance not resolved in Step 3 may be appealed to Step 4
within ten (10) calendar days following the Police Chief's final answer in Step 3. Any
grievance not appealed in writing to Step 4 by the UNION within ten (10) calendar
days shall be considered waived.
Step 4. A grievance unresolved in Step 3 and appealed in Step 4 may by mutual
agreement by the EMPLOYER and UNION be submitted to mediation through the
Minnesota Bureau of Mediation Services. Agreement to submit the grievance to
mediation must be made within ten (10) calendar days of the Step 3 response. If the
parties do not agree to submit the grievance to mediation within such 10-day period, the UNION
may appeal the grievance to Step 5 within five (S) calendar days of the date the parties could not
reach agreement. If the parties agree to submit the grievance to mediation and the grievance is not
resolved by mediation, the UNION may appeal the grievance to Step 5 within ten (10) calendar days
of the date that mediation ended. Any grievance not appealed in writing to Step 5 as provided by
this paragraph shall be considered waived.
A grievance unresolved in Step 4 and appealed to Step 5 shall be submitted to arbitration subject to the provisions of
the Public Employment Labor Relations Act and MN Statutes Section 626.892.
6.5 ARBITRATOR'S AUTHORITY
A. The arbitrator shall have no right to amend, modify, nullify, ignore, add to, or
subtract from the terms and conditions of this AGREEMENT. The arbitrator
shall consider and decide only the specific issue(s) submitted in writing by
the EMPLOYER and the UNION and shall have no authority to make a
decision on any other issue(s) not so submitted.
B. The arbitrator shall be without power to make a decision contrary to, or
inconsistent with, or modifying or varying in any way the application of laws,
rules, or regulations having the force and effect of law. The arbitrator's
decision shall be submitted in writing within thirty (30) days following the close
of the hearing or the submission of briefs by the parties, whichever be later,
unless the parties agree to an extension. The decision shall be binding on
both the EMPLOYER and the UNION and shall be based solely on the
arbitrator's interpretation or application of the express terms of this
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AGREEMENT and to the facts of the grievance presented.
C. The fees and expenses for the arbitrator's services and proceedings shall be
borne equally by the EMPLOYER and the UNION provided that each party
shall be responsible for compensating its own representatives and witnesses.
If either party desires a verbatim record of the proceedings, it may cause such
a record to be made, providing it pays for the record. If both parties desire a
verbatim record of the proceedings the cost shall be shared equally.
6.6 WAIVER
If a grievance is not presented within the time limits set forth above, it shall be
considered "waived". If a grievance is not appealed to the next step within the
specified time limit or any agreed extension thereof, it shall be considered settled on
the basis of the EMPLOYER'S last answer. If the EMPLOYER does not answer a
grievance or an appeal thereof within the specified time limits, the UNION may elect
to treat the grievance as denied at that step and immediately appeal the grievance to
the next step. The time limit in each step may be extended by mutual agreement of
the EMPLOYER and the UNION. The UNION may not skip any step without the written
consent of the EMPLOYER.
6. 7 CHOICE OF REMEPY
If the grievance is not submitted to or not resolved by mediation in Step 4, and if the grievance
involves the suspension, demotion, or discharge of an EMPLOYEE who has completed
the required probationary period, the grievance may be appealed either to Step 5 of
ARTICLE VI or a procedure such as: Civil Service, Veteran's Preference, or Fair
Employment. If appealed to any procedure other than Step 5 of ARTICLE VI the
grievance is not subject to the arbitration procedure as provided in Step 5 of ARTICLE
VI. The aggrieved EMPLOYEE shall indicate in writing which procedure is to be
utilized -Step 5 of ARTICLE VI or another appeal procedure -and shall sign a
statement to the effect that the choice of any other hearing precludes the aggrieved
EMPLOYEE from making a subsequent appeal through Step 5 of ARTICLE VI.
ARTICLE VII. QEFINITIONS
7.1 UNION: Law Enforcement Labor Services, Inc.
7.2 EMPLOYER: The City of Eden Prairie.
7.3 UNION MEMBER: A member of Law Enforcement Labor Services, Inc.
7.4 EMPLOYEE: A member of the exclusively recognized bargaining unit.
7.5 BASEPAY RATE: The EMPLOYEE'S hourly pay rate exclusive of longevity or
any other special allowance.
7.6 OVERTIME: Work performed at the express authorization of the EMPLOYER in
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excess of a regularly scheduled shift.
7.7 CALL BACK: Return of an EMPLOYEE to a specified work site to perform assigned
duties at the express authorization of the EMPLOYER at a time other than an
assigned shift. An extension of or early report to an assigned shift is not a call back.
ARTICLE VIII. SAVINGS CLAUSE
8.1 This AGREEMENT is subject to the laws of the United States, the State of
Minnesota, and the City of Eden Prairie. In the event any provision of this
AGREEMENT shall be held to be contrary to law by a court of competent jurisdiction
from whose final judgment or decree no appeal has been taken within the time
provided, such provision shall be voided. All other provisions of this AGREEMENT
shall continue in full force and effect. The voided provision may be renegotiated at
the request of either party.
ARTICLE IX. WORK SCHEQULES
9.1 The sole authority in work schedules, hours of employment, and changes thereto is
the EMPLOYER.
9.2 Nothing contained in this or any other Article shall be interpreted to be a
guarantee of a minimum or maximum of hours the EMPLOYER may assign
EMPLOYEES.
ARTICLE X. OVERTIME PAY
Hours worked in excess of an EMPLOYEE'S regular scheduled shift shall be
paid at the overtime rate of one and one-half (1.5) the EMPLOYEE'S regular
rate of pay. Compensatory time shall not accumulate beyond 120 hours,
which equates to 80 hours of overtime (80 hours x 1.5 = 120 Comp Hours). A
limit of 120 hours of Compensatory time may be used to replace scheduled
hours per year. Employees may begin earning compensatory time starting
with the first payroll of the calendar year through the last full pay period in
November. All remaining Compensatory time shall be cashed out after the
last full pay period in November each year.
10.2 Overtime will be distributed as equally as practicable.
10.3 For the purpose of computing overtime compensation, overtime hours worked
shall not be pyramided, compounded, or paid twice for the same hours worked.
ARTICLE XI. CALL BACK AND COURT PAY
11.1 An EMPLOYEE called back, as defined in Section 7.7, will be compensated for a
minimum of two (2) hours' pay at one and one-half (1 X) times the
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EMPLOYEE'S base pay rate.
11.2 An EMPLOYEE required to be on call for court on a scheduled day off shall
receive three (3) hours of straight time pay. These hours cannot be
converted to Compensatory Time.
11.3 An EMPLOYEE required to appear in court on a scheduled day off shall
receive a minimum of three (3) hours of overtime pay.
11.4 An EMPLOYEE is eligible for either pay defined in 11.2 or pay defined in
11.3 once per day and is not eligible for both in the same day.
11.5 If an EMPLOYEE is required to appear in court but that appearance requirement is canceled after 12
p.m. the day prior, the employee may submit for three hours of straight time pay. To be eligible for this
pay, the employee must call the attorney's office by 12 p.m. the business day prior to determine if their
appearance is required.
ARTICLE XII. DISCIPLINE
12.1 The EMPLOYER will discipline EMPLOYEES only for just cause. Discipline does not have
to be progressive. Discipline will be in one of the following forms:
Verbal Warning;
Written Warning;
Final Warning;
Suspension; or
Discharge
All other employer actions will not be considered discipline.
12.2 EMPLOYEES will receive a copy of such discipline and/or notice.
12.3 An EMPLOYEE(s) will not be required to participate in an investigatory interview
by the EMPLOYER where the information gained from the interview could lead to
the discipline of the EMPLOYEE(s) unless the EMPLOYEE(s) upon his/her request
is given the opportunity to have union representation present at the interview to act
as a witness for the EMPLOYEE(s).
12.4 Grievances relating to discipline shall be initiated by the UNION at Step 3 of the
grievance article.
ARTICLE XIII. SENIORITY
13.1 Seniority shall be defined as the length of continuous service in the job classification
covered by ARTICLE II -RECOGNITION. EMPLOYEES who are promoted from a
job classification covered by this AGREEMENT and return to a job classification
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covered by this AGREEMENT shall have their seniority calculated on their length of
service under this AGREEMENT for the purposes of promotion, transfer and lay off
and total length of service with the EMPLOYER for other benefits under this
AGREEMENT.
13.2 Seniority will be the determining criterion for layoffs.
13.3 Seniority will be the determining criterion for recall. Recall rights under this
provision will continue for twenty-four (24) months after layoff. Recalled
EMPLOYEES shall have ten (10) working days after notification of recall by
registered mail at the EMPLOYEE'S last known address to report to work or forfeit
all recall rights.
13.4 Senior employees shall have preference when selecting shifts.
ARTICLE XIV. PROBATIONARY PERIODS
14.1 All newly hired or rehired EMPLOYEES shall serve a probationary period of twelve
(12) consecutive months of active work.
14.2 At any time during the probationary period a newly hired or rehired employee may
be terminated at the sole discretion of the EMPLOYER without such discharge
being a violation of this Agreement and such termination is not a proper subject
for Article VI (Grievance Procedure).
ARTICLE XV. SAFETY
15.1 The EMPLOYER and the UNION agree to jointly promote safe and healthful working
conditions, to cooperate in safety matters and to encourage EMPLOYEES to work in a
safe manner.
15.2 Representatives of the bargaining unit may be selected to serve on the City
Safety Committee based on management approval.
ARTICLE XVI. INSURANCE
16.1 All eligible full time EMPLOYEES may participate in the EMPLOYER'S insurance program.
An eligible employee is defined as an individual who would be covered under the medical
insurance coverage provisions of both the City's personnel policies and insurance plan
documents between the City and insurer. For the term of this agreement, the EMPLOYER
will contribute toward the premium for medical, life, and Long-Term Disability insurance on
the same basis and subject to the same conditions and restrictions as the basic program
for nonunion EMPLOYEES as it may be amended from time to time.
ARTICLE XVII. UNIFORMS
JO
17.1 EMPLOYEES shall receive a uniform allowance of $1,000 per year.
EMPLOYEES shall have the option of receiving all cash, half cash/half kept
on account, or all on account. Newly hired EMPLOYEES are issued uniforms
and begin utilizing the uniform allowance the next calendar year after hire
date. EMPLOYEES who begin after July 1 receive $500 the next calendar
year.
ARTICLE XVIII. INJURY ON DUTY
18.1 The EMPLOYER, through its Worker's Compensation insurance plan, will provide
Worker's Compensation benefits as allowed by law to all EMPLOYEES. In addition,
the EMPLOYER will provide for a period of up to ninety (90) days, the difference
between the EMPLOYEE'S normal gross wages and the worker's compensation
benefit. The first three (3) days of absence to be deducted from the EMPLOYEE'S
PTO leave.
ARTICLE XIX. ANNUAL PAIP LEAVE ANP HOLIPAYS
19.1 Employees will participate in the City's leave policies on the same basis as the general
non-union employee group.
19.2. Patrol Officers do not observe City holiday schedule. Instead, 80 hours of holiday
time is reflected in the reduced scheduled hours. Patrol Officers assigned to work on
the following City observed holidays will be compensated at time and a half for no
more than one shift per holiday (these hours may not be converted to Compensatory
time): Martin Luther King Day, President's Day, Memorial Day, Labor Day, Veteran's
Day, and New Year's Eve (actual day). Patrol Officers who work on New Year's Day,
July 4, Thanksgiving, Christmas Eve, or Christmas earn double time for no more than
one shift per holiday. Patrol Officers with this schedule receive 8 hours of Floating
Holiday time annually. Floating Holiday time must be taken at minimum 8 hour
increments and will be forfeited after the last full pay period in November each year.
Holiday time is not eligible to be converted to Compensatory time.
19.3 All other bargaining unit employees follow the City holiday schedule as defined by the
personnel policies as they may be amended from time to time.
ARTICLE XX, WAIVER
20.1 Any and all prior agreements, resolutions, practices, policies, rules and
regulations regarding terms and conditions of employment, to the extent
inconsistent with the provisions of this AGREEMENT, are hereby superseded.
20.2 The parties mutually acknowledge that during the negotiations which resulted in this
AGREEMENT, each had the unlimited right and opportunity to make demands and
proposals with respect to any terms or conditions of employment not removed by
law from bargaining. All agreements and understandings arrived at by the parties
are set forth in writing in this AGREEMENT for the stipulated duration of this
AGREEMENT. The EMPLOYER and the UNION each voluntarily and unqualifiedly
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waives the right to meet and negotiate regarding any and all terms and conditions
of employment referred to or covered in this AGREEMENT, even though such terms
or conditions may not have been within the knowledge or contemplation of either or
both parties at the time this contract was negotiated or executed.
ARTICLE XXL DURATION
Upon its approval and implementation by the City Council of the City of Eden Prairie, this AGREEMENT and all
appendices shall be effective as of January 1, 2021 and shall remain in full force and effect until December 31,
2022.
FOR THE CITY OF EDEN PRAIRIE:
Ron Case, Mayor
Rick Getschow, City Manager
Alecia Rose, Administrative Services
and Human Resources Director
APPENDIX A
FOR LAW ENFORCEMENT LABOR
SERVICES, INC.:
Adam Burnside, Business Agent
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WAGE SCHEDULE
2021 (3%) 2022 (3%)
STEP
1 $31.71 $32.66
2 $38.05 $39.19
3 $41.29 $42.53
4 $44.74 $46.08
5 $48.48 $49.93
Step Increase: Advancement of steps will be granted based on a minimum of 12 months served
at each step, in addition to positive performance evaluation.
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FTO and Instructor Pay: Due to the impact on professional development and growth of our
organization, EMPLOYEES working as FTO, or on an Instructor Day (I Day) for a full shift, shall
receive one (1) additional hour of pay per shift at straight time for an 8.75-hour shift.
If Field Training duties are performed for a 12-hour shift, EMPLOYEES shall receive one and a
half (1.5) hours of pay at straight time.
On-Call Pay: Detectives assigned to the on-call rotation receive 21 hours per week (3 hours per
day) at straight time when on call.
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