Calculating paid sick leave pay for commissioned and exempt employees
STATE OF CALIFORNIA
DEPARTMENT OF JNDIIBTRlAL RELATIONS
DIVISION OF LABOR STANDARDS ENFORCEMENT
1515 Clay Street, Suite 801
Onkhu1d, C~lifornht !)11612
(510) 622-3246
(510) 622"3258 fax
SUSAN A, DOV!
Staff Attorney
October 11, 2016
Lawrence S. Branton
Seltzer Caplan McMahon Vitek
750 B Street, Suite 2100
San Diego, CA 92101
Dear MT. Branton:
Re: Healthy Workplace Healthy Fan1ilies Act of2014 - Calculating Payment of Paid
Sick Leave· Exempt Non-Exempt Employees, Employees Paid by Commission
Your letter dated December 16, 2015, seeks clarification regarding which method of calculation
for paid sick leave (PSL) as required by Labor Code section 246(k)(l); (2) & (3) should be t\sed
for employees paid by commissions· and employees exempt from the payment of overtime. You
ask whether an exempt employee who is paid almost entirely by commissions has to be paid a
separate amol\11t of PSL or whether amounts that an employee regularly receives in commissions
which happen to be paid on a sick day would suffice. 1 Secondly, you ask for clarification
regarding how to calculate PSL for an exempt employee who also receives an annual bonus at the
end of each year.
Labor Code section 246(k) allows, as discussed below, an employer to pay PSL to an employee
who is not exempt from overtime under the prnfessional, administrative or executive exemption in
one of two ways. The employer may calculate the regular rate of pay for the workweek in which
the paid sick leave was taken (under (k)(l )) or the employer may calculate the total non-overtime
earnings for the prior 90 days divided by the total hours for the prior 90 days (under (k)(2)) A
non-exempt employee is paid based upon their total compensation which includes all forms of
compensation (hourly, commissions, piece rate, incentive/performance bonuses).2
Answering your first question, computing the amount of PSL due to an employee who is paid
almost entirely by commissions may be calculated by either method available under Labor Code
1
The Labor Commissioner addressed a similar question in an Opinion Letter dated May 14, 1987. ln the May 14,
1987 Opinion Letter, the Labor Commissioner stated that previously earned commissions paid while an employee was
off work on unpaid leave did not constitute vacation· pay. Rather, the lettei· reasoned that the compensation was earned
while working. It was simply paid while the employee was off on an unpaid leave.
2
For non -exempt employees paid by salary, the salary constitutes non-overtime pay. In calculating the regular rate
under (k)(l), the salary is divided by non-ovet"time hours. When calculating total non-overtime earnings for the
previous 90 days, the salary is divided by total non-overtime hours. Although the statute states that non-ovet"time pay
should be divided by total hours under (k)(2) - that provi'sion is only applicable when payment is made by
commission, piece rate or bonus which require that total hot1rs be used to calculate the regular rate of pay for the prior
90 days.
Letter to Mr. Branton
October 11, 2016
Page2
section 246(k)(l) or (2). Labor Code section 246(k)(3) would not apply to an employee paid
almost entirely by commissions because that employee is not as we understand your letter, earning
a salary of at least two times the minimum wage in addition to commissions.
At the outset it is important to understand that generally an employee paid almost entirely by
commissions is only exempt from overtime if one's earnings exceed one and one-halftimes the
minimum wage and more than one half of al! compensation represents commissions for each pay
period pursuant to Labor Code Section 515(b) and Section 3(D) of the Indus.trial Welfare
Commission Orders, or if the employee qualifies as an outside sales person under Labor Code
Section 1171 (and Section 1 (C) of the Industrial Welfare Commission Orders. Under both
instances, employees are commonly understood to be "exempt" from different aspects of minimum
labor standards (overtime or minimum standards imder the !WC Orders, respectively). These two
exemptions are independent exemptions which apply separately from paid sick leave requirements
including the calculation for payment for sick leave taken by employees who receive commissions.
In Labor Code section 246(k), the reference to "exempt" and "nonexempt" employee for purposes
of selecting the appropriate calculation under Labor Code section 246(k) refers to an employee
who satisfies both the salary and duties tests in Labor Code section 515(a), and not to the outside
sales exemption pursuant to Labor Code 1171 and Section l(C) of the !WC Orders, nor to the
overtime exemption for commissioned salespersons pursuant to Section 3(D) of the Wage Orders
as authorized under Labor Code section 51 S(b).
To the extent there is ambiguity regarding the meaning of"exempt" in the calculation for paid sick
leave in Labor Code section 246(k), intent can be ascertained from the statute's context and
legislative intent. The language of Section 246 evidences an intent that the distinctions for how to
compute PSL is based on whether an employee is exempt (paid a minimum salary for all hours
worked and meets the duties test) as a professional, executive, or administrative employee and
therefore meets the requirements of Labor Code section 51 S(a). 3 ·
When the Healthy Workplaces, Healthy Families Act of2014 was amended by Assembly Bill 304
in 2015, the Legislature created fiexibili ty by allowing employers to calculate a non-exempt
employee's pay either by looldng back 90 days and dividing total wages paid, excluding overtime
pay, by total hours in the full pay periods in the prior 90 days of employment, or by using the
regular rate of pay in the pay period in which the leave was tal<en. An analysis by the Senate
Committee on Labor and Industrial Relations at the time AB 304 was being considered indicates
that the language in Labor Code 246(k)(3) was meant to apply to an employee exempt as
"administrative, executive, or professional". (See Senate Committee on Labor and Industrial
Relations, Analysis, Hearing date July 8, 2015.)
Also, the same Legislative Committee Analysis described above also stated a concern regarding
commissioned sales persons. The committee analysis stated that paid sick leave could be paid
based 011 either the regular rate of pay in the pay period the paid sick leave is taken or the average
pay fo1· the prior 90 days for commissioned sales persons which is consistent with the view that the
options provided in (k)(l) and (k)(2) would apply to a commissioned salesperson. This allows
3
The fact that an employee receives at least the minimum salary amount under Labat· Code section 515(a) is not itself
sufficient to qualify as an exempt employee because the duties test must also be met for an employee to be exempt for
purposes of ovettime and, as discussed In this letter, for calculation of PSL as well.
Letter to Mr. Branton
October 11, 2016
Page 3
employers to choose either method of calculating payment that would compensate the employee
for the sick day but not lead to an inflated !'ate for the leave if, in fact, a payment was just received
fot commissions. The Analysis is attached here for your review.
Based on the above, in the first scenario yot1 describe, employees who are paid by commissions
must be paid accotding to Labor Code sections 246(k))(l) or(2).
Secondly, you ask how an employee who is exempt and is entitled to a non- discretionary bonus is
required to be paid for a sick clay. Normally, an exempt employee would be entitled to continue to
receive his or her full pay without deduction for a sick day of less than 8 hours but the clay or
partial clay of sick leave may be deducted from earned or fronted leave balances. (See discussion
regarding application of leave for exempt employees in DLSE Opinion Letter 2009.11.23, pp. 4- 7).
If the employee is exempt under the administrative, executive or professional exemption and no
leave time is provided for any other purpose, then normally the salary would continue without
deduction for a sick day with the time applied against leave balances and tracked in accordance
with Labor Code section 246(h). The non-discretionary bonus would not figure into the salary of
an employee exempt under Labor Code section 515(a) because such bonuses are only figured into
the pay of a non-exempt employee in order to determine the regular rate of pay for overtime and to
figure the paid sick leave rate under Labor Code section 246(k)(l)-(2). Here, an employee who is
exempt tmder the administrative, executive or professional exemption and uses a full sick day
would be paid for an amount of pay which equals his or her regular salary for the sick day because
the leave would be computed based on the regular salary, pursuant to Labor Code section
246(k)(3). For a full-time employee, the annual salary would be divided by 52 weeks and then by 5
days to determine the daily wage that would have to be paid for a sick day.
This opinion is based exclusively on the facts and circumstances described in your request and is
given based upon your representations, express or implied, that you have provided a foll and fair
description of all facts and circumstances that would be pertinent ta out consideration of the
questions presented. The existence of any other factual or historical background not contained in
your letter might require a conclusion different from the one expressed herein. You have
represented that this opinion is not sought by a pari-y to pending private litigation concerning the
issues addressed herein. You have also represented that this opinion is not sought in connection
with an investigation or litigation between a client or firm and the Division of Labor Standards
Enforcement.
Thank you for your inquiry.
Sincerely,
.jJ,t...., q (!2 ,
Susan A. Devi
Attorney for the Labor Commissioner
SENATE COMMITTEE ON LABOR AN:O INDUSTRIAL RELATIONS
Senato·r·To1iy Me,l1()ozn, Cllair ·
2015 "2016 Regular
. .
Bfll No: AB 304 J:le:arlng Date: July 8, 2015
Author: Gonzalez
Version: Ju11e: 22, 2015 ·
Urgency: Yes Fls·cal; Yes
Consultant:- . Alma Perez-Schwab
Subject1 Slok leave: accrual and limitations.
KEY ISSUE
Should !he Legislature amend the pa,Jd sick leave Jaw enacted last yciw, which 1-equlres
employers to provide spe(J.ified employees w!J:h up fo three days per year of leave, in 01-der to I
address some stakeholder oonoems and ensure proper l111ple:111e:ntation?
.'
ANALYSIS
. .!Jnder the e,xisting Hea!J:hy Workplaces, 1-foa.lthy ·Families Aot of 2014, startlng on July I, Q;OJS,
an employee who works 111 Calilbl't1ia fol' 30 or more days within a year from the commencement
of employment is entitled to Jm/d sick days at the rntc of not less tJian one hour p~r every 30
hours wm•ked.
I
Among other things, the Act (Labor Gode §24$-249):
1, Authoriz.es the use ofaocrued paid sick days hegkining on the 90th day ofen,ployment.
2. .Allows employers to limit ·the \1se of piild sick days to 24 hours or three days per year. .
3. Upon the Ol'al Ol' wdtten request of an employee, requires ro1 employer to. peovide paid
sick days (bl': .
a. Di~gnosis, .care, or treatment of nu exlstihg heakb condition of, or preventive oal'e
for, !be employee or the employee's family member (defined as a oh/Id, parent,
spowe, registered domest/o partner, grandparent, gi•andohlld and s//1/ing). .
b. For specified purposes, as de.:!lned, :fb1· an employee who is !l vlctbn of domestic
vloleoC<l, sexual assault, 01· stalldtt!?,
4. Prohibits an employer from denying an employee the dght to qse aoc!'ued sick days,
· disoha.rge, threaten to dischai•ge, de1110te, .suspand, 01· in auy 111!11111(01' dlscrlmb1ate against
an employee for using aom·ued sick days, attempting t.o exerc!.!Je the l'ight to uge !lCOt'Lied
sick days, filing a complaint with the depal'lment ol' alleging a viol11tlon of this artlole,
coope1·atlng fn an l1ivestigatlon 01· pl'Oseou(:lon of an alleged violation of this at'tiole; · or
opposing !lny policy 01· practice or act that is pt·ohibit<:ld by this article.
piis Bill wo,1ld make a number of changes to the· Healthy Workplaces, Healthy Famllles Act
<:lnacted hist year. Speclfically, this bill:
I) Provides that the definition of"employee" does not i11olt1de speclfied retired annuitants.
A13 304 (Gon7J1lez) Page2of6
2) Specitles that an "employee In tho construction industry" means an employee pe1fo1•ming
work - deleting the 1·oi!lrertoe to "orurlte work" in the 01W1'llnt provt~ions ofthe IEJaw,
3) Specifies that the law applies to at1 employee Who works In Calilbrnia ''for the same
employer" for 30 or more days wltl1ln a year.
a
4) Provides that an ernployet• may use difl'eront accrual mo'thod, other than providln:g one
hour per every 30 hout·$ woi•ked, provided that the aool'lml ls on 11- regulat· basis so that an
etbployee has no less than 24hours ofaocl'lll;ld sick leave 01· paid time off by 1he 120th
calendar day of employment or each calendar year, 01· In. each l2-moli1h period. ·
5) Provides th11t 1111 employe1· may s11tlsfy the accrual requirements of this section by
provkl ing not less than 24 hours 'Ol' three days of paid sick leave that Is available to the
· employee to use by the.completion of his or l1e1· 120th calendar day of e111ployment,
6) Amend,i the law to specify that an employer ls not required to provide additional paid
sick days tf !he employe1• has a pukl leave pqlicy or paid time off policy, the e111pjoye1•
111llkes available ·(beginning July I, 2015) an am:ount of leave that may be used fur 1lie
. same p,11·poses and under thi:, same conditions, and tlie policy satisfies one ofthe
followh1g optkl'(1$:
. a) Satisfies the acc!'Ul,l, carry over, 1md use requirements of the law,
b) Provkfod paid sick le11-ve or pa:ld time o:lf to a class of employees before Ja11uary 1,
2015, pursuant to n siok leave policy that used an accrual method. dilTorent than
providing one hotll' por every 30 hours worked, provided that thi;, 11oc1·ual is on a
regular basis so that m1 etnployeo, includ It.lg an employee hired into 1hat class after
,Tanuat'y l , 20 '15, has 110 Je;ss than 0110 day or eight hours of accrued leave within tht'ee
months, and the employee w11s e.liglblo to earn at least three days or 24 hou1·s within
nine months. lf an employer madlf:fos the itocrual method used in the policy it had In
placo prior to .TanU1\l'y l, 2015, the employer shnll comply wilh any accrual method
set fol'th in existing law or provide the 'full timount of leave at the beg:ltming of the
year, This bill shiill not pTohibit the employe1· :Ii-om lncreaslng the aool'lta! amount 01·
rate,
c) Pl'Ovldi:,s that specified sick leave 01· arunial leave benefits pl'Ovided to specified state
employees 01• officers by statute or the provlsions of a rnernorandmn of understanding
mll'et the requirements ·of the pald ~fuk day's mw. ·
7) P1·ovides that an eiI1ploye1· is not required to reinstate accrued paid time off to a rehil'ed
employee that was paid out at the time oftermination, resignation, or separation of
employnwnt,
. 8) Provides that if an employer provide~ unlimited paid sick leav'6 m·unlimited paid thne
. off, the employe1• tr!Ely satisfy a specified written notice reqtiirement of existing Jaw by
indicating on the notice or the employee's itemiwd wago statement that suoh leave ls
"unlimited,"
AB 304 (Gonzalez) !'age 3 of6
9) Delays application of provisions related to the Inclusion of the amount of paid sick leave
· available on itetniz:ed wage statements or separate writings until J11mmry 21, 2016, for
employers in the broadcasting i:\nd ·motion .Plcttu·e indt,~tl'ies.
10) Provides that an employel: shall calculate paid slck lenve using any of the following
. calculatlo ns:
a) Paid sick time Jbr nonex:el11pt employees shall 'be calci:ilafod h1 tile satne inanner as
the regular rate of pay for the wodcwcek In which the employee uses paid sick time,
whethel' 01• not the employee actually works overthne it\ that workweel~.
b) Pald sick time ful' noneireinpt employees slmll be calculated by dlvid Ing the
employee's total wages, not h10!ud ing overtime premium pay, by the employeo's total
hmit·s worked in the full pay periods of the prior 90 days of employhient..
c) Piiid sick time for exempt employees shall be calc11lated in the same manner as tlm
employer calculates wages fut· nther furms of paid !eave thne.
11) Provides that an etnp !oye1· is not obligated to inquil'e lnto or l'ecord 1l1e purpose :lbt• which
an· employee uses paid leaw or paid titm ofl:
12) Provides that the ptovisions of this bill ai·e severable, a~ specified.
13) Contains an ut'genoy clause.
I
COMMENTS
-
Neecl for this bill?
AB 1522 (Gomalez), Chapter 317, Statutes of2014, 1;1na.ctod the Healtl1 Workplaces, Heal!hy
Families Act of 2014 to provide paid sick days to spec!!led Callfomia employees eflectlve
July 1, 2015. AB 1522 W!\8 landmark !eglslatlon that exte11ded the dght to paid sick days to
an· estimated 6.5 million Califurnla workem. H,:rweve1·, the pnssit.ge of such a sweepiog
workplaoe benefit has spurred a robust publiu disc1tsslon reg,ircllng the implementation of the
law. As such, the author wishes to olllll'ify a bandftd ofU1e law's requirement'l in order to ease
Implementation of Cal!furnla's new pald sick leave lt1w.This bill would amend tl1e Aot in order to _provide clarifioatlon regarding which wot·kers ai-e
cove1-ed, how the paid time off is accrned, and prowctions for employers that all'eady JYrovlde
paid sick leave. Previous versions of the 'bill wern opposed by vario~s employer
organlzatrons, .howiwm·, the nuthm and stakeholdern were able to 1-eaoh agreement on the
language before us which has addressed most. of the employer concerns, In a letter dated
June 19, 2015, the Ct1lin:ll'nia Cb11mber of Commerce tmd a coalition of employer
Ol'ganlzations removed. tlieir opposition to tlm bill, -
Sumrnai·~ ofoha11ges to the I-ki9.lthv Workplaces, Healthy Fmnilies Aot of2014;
Below ls a summary of the changes to the paid sick law that ru-e proposed with this blli:
AB 304 (Gonmloz) Page 4 of6
Co11form.s to State Law Governing Ca/PERS Retired A11nultmits: Under the' Government
Code, Ca!PERS retired annukMts are not allowed to 1·eceive any form of comJ)eusatlon h1
additlon to thek pay as it could aJTuct their status tJnder CalPERS. By exempting retired
a:nnuitants fi•om the provisio11s of AB 1522, retired persons wlll be able to retum to work
while stlll receiving their pension annuity,
Ji'/exlbitlty for Existing Paid Siok Leave Plans: Prlo1· to the signing of AB 1522, some
employei·s were already engaged in the p1·aotice of providing paid leave or paid time -off. This
bill will 0~1ri(y that employers are not required to provide additional paid sick days if the
employer had a policy prior to Janual'y l, 2015 that meets ce1·tah1 conditions, as specified,
Alt:ernaUve Accrual for Non-Hourly Payroll: The payroll systems fur many employe1·s do not
track their employees on·!\11 hourly basls. This blll .will allow employers to comply with state
law lf they aCl)l'ue or :front-load thek sick leave policies so employees receive three paid sick
days by the' 120th day of the year.
Labor-.Mana.gement Con1·entW! In Speo(fio lndustr.les: TI1e motion picture and broadcasting
lndustty commonly uses different third party payl'O!l companies on each production, This bill
will extend the start date fo1· wl'itten notice requli'e111e11ts to Janmwy 2 J, 20 J 6 as agreed to by
both· employer ·and labor representu.tives in tj1e industry,
l
Flexthl/1/y for Calculating Siok Pay: Nonexempt employees ot\e11 perform work nt varying
!'ates of pay, which can nmke it diftlcult t.o calcul11te the rates at which sick leave Is paid to
employees. TI1is biH wl11 ,tllow employers to choose be\weon the methodology required
under AB 1522 as well as the "regular 1·ate of pay" that is more familiar to many employers,
3, B,emaining Conoerns:
co·mmittee staff h1,s. received ln:formation regiwding some Ul11'eso.lved oonco1·113 with the
provisions of the paid sick days law and its implementation. Speo.iflcally, swkeboldera aro
seeking clarification In the fullowlng areas:
Ca/ou/at/ng Paid Sick Leave for Employees Wm·klng on Commission: Concerns have been
raised regarding the calculatlo11 of wages to be paid for a11 employee working on oommlssion
that takes their accrued· paid sick days, ·
The bill provides that a.n employer shall ca.lculate paid sick leiwe using any of the following:
a) For nonexempt employees: , ·
I) In the same manner as the regular rate of pny fot• the wol'kwoek in which the
employee uses paid sick time, whe(hor 01· 11ot he/she works overtiine it\ tlw.t week,
ii) By divkling tl1e employee's total wages, mt incJud ing overtime premium pay, by
the employee's total hoi.n·s worked in the fiill pay periods of the pl'io1• 90 days.
b) Paid sick tirne for exempt e11111Ioy(l()s (exempt as an administrative, exequt/ve, or
professional employee under a wagl' order ofthe Industrial We/fare Commts.l'ion)
shall be calculated .in the same manner as tl1e employer cnloulates wages for other
forms of paid leave time.
The concern is 1hat an outside sales person that essentially sets their own hours and Is highly
comp1~nsated ·could 'ganw' the system by planning when to l'equest the paid slok days in
AB 304 (Gonzalez) Page 5 of6
ol'der to get a highe1· rate by timing li1e receipt of ihelr Income. Staff was given the example
of property and casualty inslll'ance agents and brokers who al'e pald on commisslon .and have ·
both renewal lnoonte as well as income based 011 new sales closed during the· yea1·, As an
examp.le, they ofte1· the following scenqrlo: M employee that eams $300,000 ann1mlly but
iakes a smaller monthly draw, say $8,000 per month, but toward the end of the yem· drnws
clown the.. remai11der of 01e income 9wed would be able to game tho system because the
balloon payments toward the end of the yom wm allow that person (fur the next 90 days) to
request sick pay i\t 11 mi1oh higher 1·atc tl1ai1 if tl1e slok pay was detel'mlned bas~d mi the.
Income paid over ilie entire 12 months, .
This Is a shnllar concern fur employees who earn btmuses. Stakeholders would like the
provisions to align to Ja.9t yei\l''~ 1·egular rate of pay conoept which stated, "lfthe employee !h
the 90 days of employment befu1·e taking accJ'ued sick leave had different hom·ly pay 1·ates,
was paid by commission or piece rate, or was a nonexempt salaried employee, then ilie rate
of pay shall be calculated by dividing the employee's total wages, not lncludlng overtime
premium pay, by the employee's total houl's worked 1n tl1e fill! pay periods of fue priol' 90
days of employment." ·
Continuous 90-day employment: Concerns have been raised by the Cily and Cou1,ty of San
Francisco 1·egardlng an indivklmil that wot-ks fo1· an employe1· for part of the yel\l'; leaves that
job nnd Jate1· 111 the year retul'lls to work ful' lhe same employe1·; Tbe concern lies hi the
ability of tha:t employee to 1·trgal11 access to any balance paid sick days if tl1ey had such 11Coess ·
ut the time of separation, Specifically, the ooncertJ is tl1at an employee might work tbt 30
days, ti1e11 l'eturn 8 months latet• and fue employer would have to stitch together the .Previous
employment with the new employment to figure out when 90 days of employment is
cumulatively met. They propose the. fullowlng olarification; "246, (~(2) If an employee
separates from an employer 90 or more di1ys a(ter he 01: slm wns hired and ls rehired by the
employo1· witbfn one year 'll·om the date of sepa.1•atlo11, pl'eviot1sly accrued and unused paid
sick days shall be reillstated., ," They believe ci1at thh revt~ion would allow the employee
access to tho balance but if the e1nployee did not have access when he/she lei\, the clock
would resta1t Jf rehire,d like any other new hirn,
4, Proponent Arguments:
According to the author, In order to help employers meet requirements, clal'ily pi'ovlsians and
ensure· the s1nooth implementation of tho Healthy Workplaces, Healdl)' Families Act of 2014,
tl1ls blll alms to oonfui·m state law governing CalPERS retirnd rumuitants, provide Hexibility
fur existing paid sick leave phms, allow fu1· alternative accri.1111 fur 11011-bourly payroll,
provide fo1· labor-management consensus In specific iridustrios, . allow for flexibility h1
oalculatJng sick pay·for nomxompt employees and make a m1mber of minor changes that are
cla!'llying and technical in nature. Proponertts state that this blll make~ important changes to
the sick ![;}aye law so that its pnwisions work b~tter for employers and wol'kers and fuollitate
an orderly implementation,
5, Opp<>nent Arguments: .
None received,
AB 304 (GollZl\lez)
Pa.ge 6 of6
6, Pri01· Legislation:
AB 11 (Gonznloi) of2015: Hekl In Assembly Appropriations Committee
AB ll, efleotive July 1, 2016,wo1dd extend the provisions of paid sick days reglslntion
enacted 'Jiist year to lnclude provlders of in.. home supportive services, as described,
AB 1522 (Gcmznl~z) of 2014: Chaptet-ed
AB 1522 enacted the Healthy Workplaces, Healthy Families Act of 2014 (disc11sst1d above)
which 1·equires employers to provide paid sick days to employees •who work 30 ot· mo1-e dnys
within a year from commencement ofemployment
SUPPORT
Air Conditioning Sheet Metal Association
Ai1·-Conditioning & Refrigeration Conttactors Association
Bl'Ocade Com111unio11,tlons Systems, Inc, · .
California Chapte1's o:fthe National Eleot!'ica I Corrtmctors Associ~tlon
Califurnla Employment Law Cmmoil _
Califumla Legislative Co11furnnce of the Plumbing. Heating and Piping Indus\:l'y
Califu1;nia Sta:te Association of Counties
Finishing Contractors Assoclatiot1 of Southern Cal!fornla
Let1gue of California Cities
Motion Piotwi'e A~sociatio 11 of America
State Build Ing ~nd Cohstruotion Trndes Council
United Contractors
Wall and Ceilit1g Allirmce
Wlne lnstiMe
OPPOSTI'ION
None received
•• ll:ND ••