Cal Chamber

JOB KILLER

April 6, 2022

The Honorable Evan Low California State Assembly 1021 O St., Ste. 6110

Sacramento, CA 95814

SUBJECT:        AB 2932 (LOW) WORKWEEK: HOURS AND OVERTIME OPPOSE/JOB KILLER- AS AMENDED MARCH 24, 2022

 

Dear Assembly Member Low:

The California Chamber of Commerce respectfully OPPOSES AB 2932 (Low), which has been labeled as a JOB KILLER. AB 2932 imposes a tremendous cost on employers and includes provisions that are impossible to comply with, exposing businesses to litigation under PAGA. AB 2932’s impact on labor costs in California will discourage job growth in the state and likely reduce opportunities for workers.

AB 2932 Imposes Significant Costs on Employers by Reducing the Weekly Overtime Threshold to 32 Hours and Mandating that Employees’ Base Rate of Pay Be Increased:

 

The additional labor costs imposed by AB 2932 will be untenable for many businesses. Presently, California employees are entitled to overtime pay for any time worked after eight hours in a day or 40 hours in a week. Overtime is paid at 1.5 times the employee’s regular rate of pay. Significantly, that is not the base rate of pay. The regular rate of pay is a complex calculation that takes into account bonuses, commission, and other forms of compensation.

California is one of the only states with the eight hours per day requirement. The remaining states all comply with the federal Fair Labor Standards Act (FLSA), which only requires overtime after 40 hours in a week. Now, California is proposing to be the only state to differ from the FLSA in two ways: both the daily eight hour requirement and lowering the 40 hour weekly overtime threshold to 32 hours. That is a minimum 10% increase in wages per employee per week.

But- AB 2932 does not stop there. The language provides that “[t]he compensation rate of pay at 32 hours shall reflect the previous compensation rate of pay at 40 hours”. This language may be interpreted as requiring the employer to pay the employee the same total compensation that they are presently earning at 40 hours for 32 hours of work. By way of example, an employee making $20 per hour presently makes

$800 after 40 hours of work. Now, they would be required to make $800 after just 32 hours of work, meaning their hourly rate would become $25 per hour, a 25% increase. If the employer needs the employee to work overtime, the regular rate of pay1, becomes $37.50 per hour. A business would be paying $37.50 for every hour worked on the fifth day, an 87.5% increase from $20 per hour.

This significant rise in labor costs will not be sustainable for many businesses. Labor costs are often one of the highest costs a business faces. Such a large increase in labor costs will reduce businesses’ ability to hire or create new positions and will therefore limit job growth in California. This is especially true now as businesses are still recovering from the impacts of COVID-19 and resulting rises in supply chain costs. The repeated assumption by the Legislature that businesses with more than 500 employees can absorb

1 This assumes there is no other form of compensation for this employee that needs to be factored into the regular rate of pay calculation.

these costs is deeply flawed. It does not take into account that businesses often operate on thin profit margins and that the number of employees you have does not dictate financial success.

It is also likely that an unintended consequence of AB 2932 will be a reduction in hours for workers. Many businesses have already scaled back their hours as a result of increased costs and labor shortages. This will force them to do so even more and will make them reluctant to offer workers 40 hours’ worth of work.

AB 2932’s Requirement that Employers Not Adjust an Employee’s Regular Rate of Pay is Impossible to Comply With:

 

AB 2932 provides that “an employer shall not reduce an employee’s regular rate of pay as a result of this reduced hourly workweek requirement.” This is impossible to comply with. The regular rate of pay is not the base rate of pay set by the employer. It is a complex calculation that, for many employees, fluctuates from pay period to pay period. To calculate the regular rate of pay, you must include a number of different kinds of compensation, such as hourly earnings, commissions, and non-discretionary bonuses. If an employee earns a bonus for work performed in the prior month or quarter, the employer has to retroactively adjust the employee’s regular rate of pay for those prior pay periods. The regular rate therefore fluctuates significantly depending on how much overtime an employee works and the performance or attendance bonuses or commissions they receive, much of which is dependent on the employee or general performance of the business in any given week, not factors solely under the employer’s control. That rate will inevitably be reduced in some pay periods compared to others. Employers would face steep penalties under the Private Attorneys General Act (PAGA) for a violation that they have no ability to correct.

Instead of Burdening Employers with More Costs, the Legislature Should Provide More Flexible Work Options that Benefit Employers and Employees:

 

Like many of the bills and regulations that have been introduced over the past year, AB 2932 again proposes that California’s employers subsidize costs in the name of workplace flexibility instead of considering alternative solutions that could benefit both employers and employees. Instead of imposing new costs on employers, the Legislature should reform California’s unnecessarily rigid wage and hour laws to allow employees flexibility in their weekly schedules that would better align with the modern workplace. Presently, California’s inflexible Labor Code, steep penalty system, and convoluted alternative workweek schedule process dissuade employers from allowing employees to have more flexibility during their workday. Added costs such as split shift premiums, daily overtime, meal and rest break premiums, and a broad expense reimbursement requirement make workplace flexibility too expensive for employers to consider. Many employers are hesitant to continue to offer telecommuting after the pandemic because these wage and hour laws were not designed with telecommuting employees in mind. Any failure to adhere to certain rules immediately triggers penalties and attorney’s fees under various Labor Code provisions, including PAGA.

Employees want flexibility, whether it be through a more flexible daily schedule, alternative workweek schedule, or the ability to continue to telecommute after the conclusion of the pandemic. Yet, bills that propose increased flexibility are often not even set for a hearing. Updating these laws to provide more opportunities for flexibility is an important issue that benefits both employees while not significantly raising costs on employers as proposed by AB 2932. This concept is very popular among California voters. In a recent survey conducted by the California Chamber of Commerce, 91% of polled voters agree (56% strongly) that the state’s labor laws should be changed to allow for more flexibility. As to specific changes:

• 88% support changing overtime requirements to allow individualized alternative workweek

• 82% support allowing employees to take rest periods at any time of their

• 80% support allowing employees to forgo their 30-minute meal period to go home

• 79% support allowing employees to split their shifts to accommodate personal

The Legislature should thoughtfully consider these alternative solutions to provide workers with flexibility instead of simply continuing to raise costs on employers.

For these and other reasons, we respectfully OPPOSE your AB 2932 as a Job Killer. Sincerely,

Ashley Hoffman Policy Advocate

California Chamber of Commerce

cc: Legislative Affairs, Office of the Governor AH:am

May 16, 2022

TO:                   Members, Senate Committee on Environmental Quality

SUBJECT:        AB 1001 (C. GARCIA) – ENVIRONMENT: MITIGATION MEASURES FOR AIR QUALITY IMPACTS: ENVIRONMENTAL JUSTICE

HEARING SCHEDULED – JUNE 1, 2022

OPPOSE / JOB KILLER – AS AMENDED MARCH 22, 2022

 

The California Chamber of Commerce, the California Building Industry Association and the organizations listed respectfully OPPOSE AB 1001, as amended, which CalChamber has labeled a Job Killer and CBIA has marked a Housing Killer. The bill proposes to expand the California Environmental Quality Act (CEQA) to further exacerbate known problems with the statute by limiting local land use discretion and imposing burdensome and unworkable new legal obligations on lead agencies. In attempting to address environmental justice concerns through CEQA as the bill proposes, AB 1001 winds up substantially aggravating one of the state’s most intractable problems: California’s housing crisis inextricably linked to its inability to produce housing quickly and cost effectively. The historical environmental injustices that have

transpired in California should continue to be remedied in more suitable areas of California law– but CEQA is not one of those areas.

CEQA already prohibits lead agencies from approving projects with significant environmental effects to any community, including disadvantaged communities, if there are feasible alternatives or mitigation measures that would substantially lessen or avoid those effects. AB 1001 will worsen CEQA’s most problematic aspects and further depress housing and other development in California by expanding the statute to create new avenues of CEQA litigation and limit agency discretion necessary to comply with CEQA. It is entirely unnecessary to upend CEQA when every single city and county in California is already going through the process of overhauling their long-term comprehensive General Plans to incorporate a new Environmental Justice land use element, as required per SB 1000 (Leyva). For the reasons outlined below, we oppose expanding CEQA and limiting agency discretion necessary to comply.

Exacerbates Known CEQA Abuses by Injecting Highly Subjective, Non-quantifiable and Litigation- bait Standards in CEQA

 

AB 1001 seeks to expand CEQA to incorporate the issue of discriminatory land use policies. Specifically, the bill creates two new legal standards under CEQA. First, it forces all public agencies when complying with CEQA to “act consistently with the principles of environmental justice … by ensuring the fair treatment and meaningful involvement of people of all races, cultures, incomes, and national origins.” Second, it creates a new requirement under CEQA that all mitigation pertaining to air quality impacts be directly mitigated in the affected disadvantaged communities. Both requirements present substantial ambiguities, legal challenges and additional liability for lead agencies and project applicants without any additional environmental protections.

Local governments already spend significant time and resources complying with CEQA, and then substantially more time and resources having to defend their decisions against CEQA lawsuits often brought by housing opponents under the guise of environmental protection. AB 1001 overlays over CEQA’s existing and quantifiable environmental standards new subjective standards, such as whether the agency’s findings were “fair” or “meaningfully involving” all races, cultures, incomes and national origins. CEQA already is the most robust public disclosure, public participation and environmental protection law in the country, if not the world – and it is enforced entirely by citizen lawsuits where the identity of the plaintiff can be legally obscured. Until major CEQA reform is passed that addresses NIMBY abuses of the statute, it is paramount that the Legislature avoid creating new avenues of litigation under CEQA.

CEQA Already Requires Feasible Mitigation of Significant Impacts on Disadvantaged Communities

 

CEQA is an extraordinarily complex and all-encompassing environmental law. CEQA and its multitude of substantive and procedural requirements are implicated for nearly every type of land use project in the State of California. CEQA’s “substantive mandates” already prohibit lead agencies from approving projects with significant environmental effects if there are feasible alternatives or mitigation measures that would substantially lessen or avoid those effects. (Mountain Lion Foundation v. Fish and Game Commission (1997) 16 Cal.4th 105, 134.) Furthermore, as part of CEQA’s enforcement process, “[i]n order to ensure that the mitigation measures and project revisions identified in the EIR or negative declaration are implemented,” the local agency must also adopt a program for mitigation monitoring or reporting. (CEQA Guidelines, § 15097, subd. (a).) “The purpose of these [monitoring and reporting] requirements is to ensure that feasible mitigation measures will actually be implemented as a condition of development, and not merely adopted and then neglected or disregarded.” (Federation of Hillside and Canyon Assns. v. City of Los Angeles (2000) 83 Cal.App.4th 1252, 1261.)

Additionally, where a local lead agency has determined that a project may cause significant impacts to a particular community or sensitive subgroup, the alternative and mitigation analyses must address ways to reduce or eliminate the project’s impacts to that community or subgroup. (See CEQA Guidelines, § 15041, subd. (a) [noting need for “nexus” between required changes and project’s impacts].) By requiring a nexus, CEQA already requires local lead agencies to feasibly mitigate significant impacts from a proposed project on all communities including disadvantaged communities where there is a nexus between the project’s

impacts and that population. By specifying disadvantaged communities, the measure implies that other affected people or resources are not deserving of protection. However, CEQA currently requires consideration of effects on all human beings. (See, Public Resources Code section 21083(b)(3)). Most importantly, the bill incorrectly focuses attention on mitigation in certain areas of effect rather than at the source of the pollution. Mitigation at the source protects all people and resources and allows the use of project design features which are under the control of the applicant and the lead agency. For example, AB 1001 could require an infill project in San Francisco to mitigate air emissions in a disadvantaged community in the south-central valley (wind patterns typically blow air pollutants from the Bay Area into the central valley) instead of at the source of where the emissions are generated. This is both impractical and contrary to existing CEQA provisions that require mitigation of significant impacts to all impacted communities.

Accordingly, AB 1001 will create substantial new legal liability for local governments by substantially limiting their discretion to determine what projects should be approved and how and where mitigation should be applied to reduce significant impacts to less than significant on impacted communities.

Environmental Justice is Already Being Incorporated in California’s Planning and Zoning Laws

 

CEQA does not need to be expanded to incorporate environmental justice. Environmental justice is already substantially addressed in California’s planning and zoning laws and policies. This Legislature passed SB 1000 (Leyva, 2016) to advance Environmental Justice (EJ) in CA’s planning and zoning law by requiring every city and county to adopt new EJ land use elements in their comprehensive, long-term General Plans. The Governor’s Office of Planning & Research recently released 2020 EJ Guidance to cities and counties for implementation of SB 1000 – cities and counties are still going through this process. By requiring an environmental justice element inside all General Plans, cities and counties already must identify objectives and policies to reduce the health risks in their disadvantaged communities and promote civil engagement in the public decision-making process – exactly what AB 1001 is unnecessarily trying to force into CEQA. The Legislature should allow local governments to implement SB 1000 before greatly expanding CEQA.

While additional discussions about how to further support environmental justice communities are important, they do not and should not include upending and expanding CEQA, especially when doing so is unnecessary because existing laws already accomplish what this bill is trying to do, will increase liability on local lead agencies, exacerbate CEQA’s existing NIMBY abuse problem and worsen the state’s housing crisis.

For all of these reasons, we respectfully OPPOSE AB 1001 as a JOB KILLER.

 

Sincerely,

Adam J. Regele,

Senior Policy Advocate for the California Chamber of Commerce On behalf of the following organizations:

African American Farmers of CA Agricultural Energy Consumers Association Alameda Chamber & Economic Alliance American Pistachio Growers

Anaheim Chamber of Commerce Big Bear Chamber of Commerce Brea Chamber of Commerce

Building Owners and Managers Association California Apartment Association

California Association of Realtors

California Building Industry Association California Business Properties Association California Chamber of Commerce California Cotton Ginners and Growers Association

California Farm Bureau California Food Producers California Fresh Fruit Association

California Hispanic Chambers of Commerce California Hmong Chamber of Commerce

California Independent Petroleum Association California Manufacturers & Technology Association

California Metals Coalition California Railroads

California Retailers Association California Walnut Commission Carlsbad Chamber of Commerce Chemical Industry Council of California Chico Chamber of Commerce

Citrus Heights Chamber of Commerce Corona Chamber of Commerce Danville Area Chamber of Commerce Elk Grove Chamber of Commerce

Far West Equipment Dealers

Fountain Valley Chamber of Commerce Fremont Chamber of Commerce Fresno Chamber of Commerce

Garden Grove Chamber of Commerce Gateway Chambers Alliance

Gilroy Chamber of Commerce Glendora Chamber of Commerce

Greater Coachella Valley Chamber of Commerce Greater Conejo Valley Chamber of Commerce Greater High Desert Chamber of Commerce Greater Riverside Chamber of Commerce Greater Stockton Chamber of Commerce

Harbor Association of Industry and Commerce Imperial Valley Regional Chamber of Commerce Industrial Environmental Association

Kings River Conservation District Kings River Water Association

La Cañada Flintridge Chamber of Commerce Laguna Niguel Chamber of Commerce

Lake Elsinore Valley Chamber of Commerce Livermore Valley Chamber of Commerce Lodi Chamber of Commerce

Long Beach Area Chamber of Commerce

Los Angeles Area Chamber of Commerce Los Angeles County Business Federation Menifee Valley Chamber of Commerce Murrieta/Wildomar Chamber of Commerce NAIOP of California

Newport Beach Chamber of Commerce Nisei Farmers League

Norwalk Chamber of Commerce Oceanside Chamber of Commerce Orange County Business Council

Pacific Grove Chamber of Commerce & Tourist Centers

Palos Verdes Chamber of Commerce Paradise Ridge Chamber of Commerce Pleasanton Chamber of Commerce Redondo Beach Chamber of Commerce Roseville Area Chamber of Commerce

San Juan Capistrano Chamber of Commerce San Leandro Chamber of Commerce

San Marcos Chamber of Commerce San Pedro Chamber of Commerce

Santa Clarita Valley Chamber of Commerce Santa Maria Valley Chamber of Commerce Santa Rosa Metro Chamber

Simi Valley Chamber of Commerce South Bay Association of Chambers of Commerce

Southern California Leadership Council Southwest California Legislative Council Torrance Area Chamber of Commerce Tri-County Chamber Alliance

Valley Industry & Commerce Association Visalia Chamber of Commerce

Western Agricultural Processors Association Western Growers Association

Western Independent Refiners Association Western States Petroleum Association

cc:        Gabrielle Meindl, Senate Committee on Environmental Quality Tiffany Ryan, Office of Assembly Member Garcia

Legislative Affairs, Office of the Governor Scott Seekatz, Senate Republican Caucus

AR:ll

The Honorable Monique Limón California State Senate

1021 O St., Ste. 7530

Sacramento, CA 95814

SUBJECT:        SB 1458 (LIMON) WORKERS’ COMPENSATION: DISABILITY BENEFITS: GENDER DISPARITY

OPPOSE – AS INTRODUCED FEBRUARY 18, 2022

 

Dear Senator Limón:

The California Chamber of Commerce and the organizations listed below respectfully OPPOSE your SB 1458 (Limón). SB 1458 is likely unconstitutional, undermines the workers’ compensation system, and conflicts with existing law.

SB 1458 Likely Violates Both the California and Federal Constitutions

 

While Section 4 of Article XIV of the California Constitution “grants to the Legislature ‘plenary power, unlimited by any provision of this Constitution to establish and enforce a complete system of workers’ compensation,” that power is not absolute. See Yosemite Lumber Co. v. Industrial Acc. Commission of Cal., 187 Cal. 774, 780 (1922) (“Nothing is added to the force of the provision by the use of the word ‘plenary.’ If the Legislature has power to do a certain thing, its power to do it is always plenary. It is merely surplus verbiage.”) Not only are there limitations to that power, but also the California Legislature is of course still subject to the federal Constitution.

Federal Constitution: SB 1458 mandates an increase in workers’ compensation benefits for workers solely based on sex. If a man and a woman make the same salary and suffer the same injury, the claims administrator is required to pay the woman higher workers’ compensation benefits because of her sex alone. No matter how well-intentioned, this raises several constitutional concerns:

Equal Protection Clause: The Equal Protection Clause prohibits states from denying persons equal protection of law. This is “essentially a direction that all persons similarly situated should be treated alike.” City of Cleburne, Tex v. Cleburne Living Center, 473 U.S. 432, 439 (1985). Laws that differentiate between people based on characteristics like sex, race, or national origin must survive a higher level of judicial scrutiny than other laws.

Where a law treats people differently based on sex alone, the law is unconstitutional unless it is substantially related to a sufficiently important governmental interest. Courts look at how well the law serves the stated objective and whether there is a less discriminatory approach available. While wage disparity is an important government interest, the bill is likely to fail because of its approach. First, the bill does not address the underlying issue. It does not seek to identify women who are being discriminated against in their pay or increase their wages. Rather, it focuses on a sliver of the population, injured female workers, and provides an increase to one obscure benefit that the vast majority of women will never receive.

Second, the bill is based solely on assumptions, not fact. The proposed increase in workers’ compensation benefits is not based on a finding that there is indeed discrimination, but rather on the difference in average pay between men and women at the

company as shown in the company’s DFEH1 pay data report. That report itself does not show pay disparity. It instead asks employers to categorize employees across broad job categories and broad pay scales. The EEOC, which developed the report template, has explicitly stated that it “d[id] not intend or expect that this data will identify specific, similarly situated comparators or that it will establish pay discrimination as a legal matter.”2 The report also does not capture the legal, bona fide reasons under Labor Code Section 1197.5 for which there may be pay differentials between men and women.

For companies that do not file a pay data report with the DFEH, the increase in pay is even more tangential: it is based on the national average pay differential between men and women. It is unlikely that SB 1458 would pass the required heightened level of scrutiny if challenged.

Due Process Clause: The Due Process Clause prohibits the states from depriving a person or entity of procedural protections. SB 1458 deprives employers of procedural protections by presuming that every single female employee is being discriminated against in their pay. The company is not afforded any rights or procedures to determine whether that is actually true or have that issue adjudicated.

Instead, SB 1458 automatically increases all workers’ compensation benefits for women based on that assumption. A company that does not discriminate will have their workers’ compensation benefits payout increased either based on the national average wage rates or because their report shows that women make less on average than men, regardless of the fact that no unlawful or unjust conduct occurred.

Even if it is not found to be unconstitutional, SB 1458 is fundamentally flawed. The bill applies wage averages to all workers, regardless of their specific circumstances or whether there is indeed discrimination occurring. Essentially, it presumes that every woman is being unlawfully discriminated against and to the same degree.

California Constitution: Article XIV, Section 4 provides that the Legislature has the power enact workers’ compensation laws to “create and enforce a liability on the part of any or all persons to compensate any or all of their workers for injury or disability”. Courts have deemed unconstitutional laws that exceed the bounds of this authority.

For example, in Six Flags, Inc. v. Workers' Comp. Appeals Bd., 145 Cal.App.4th 91 (Cal. App. 2006), the court considered whether the Legislature could statutorily extend workers’ compensation death benefits to heirs who were not dependents. The court held that the statute was unconstitutional because it exceeded the scope of the Legislature’s power:

“…the plenary power clause of article XIV, section 4, cannot be used to expand the Legislature's power beyond the purposes set forth in the other sections of article XIV, section 4, that is, to compensate workers or their dependents if the worker dies in the course and scope of employment.”

Similarly, here, SB 1458 likely exceeds the Legislature’s authority. The purpose of SB 1458 is to address one consequence of gender wage disparity (notably without actually adjudicating whether such a disparity actually exists), not to create or enforce a liability to compensate a worker for injury. The underlying purpose of SB 1458 is wholly separate from the intent and operation of the workers’ compensation system.

 

SB 1458 Undermines Fairness of the Workers’ Compensation System

 

In the present workers’ compensation system, employees are paid by a formula according to their current wages. The Labor Code sets forth specific formulas as to how to make these calculations that are adjusted annually. Those formulas include statutory minimums and maximums in benefits. The system is designed

1 Additionally, those reports are confidential, so a claims administrator has no access to them.

2 FR-2016-07-14.pdf (thefederalregister.org)

to provide claims adjustors with a fair means by which to calculate benefits so that injured workers are treated the same.

SB 1458 instead adjusts that formula based on one characteristic: sex. Multiple examples show how this would generate inequitable results between two women who suffer the same injury and earn the same wages:

Example 1:

• Woman 1 works for a company with 120 employees whose DFEH report shows that women make on average 5% less than men. Her benefits increase by 5%.
• Woman 2 works for a company with 10 employees, all of whom are female, who does not file a DFEH report. The national average difference in pay for her occupation is 20%. Her benefits increase by 20%.

Example 2:

• Woman 1 works for a company with 1,000 employees whose DFEH report shows that women make on average 5% more than men. Her benefits remain unchanged.
• Woman 2 works for a company with 10 employees, all of whom are female, who does not file a DFEH report. The national average difference in pay for her occupation is 20%. Her benefits increase by 20%.

Example 3:

• Woman 1 works for a company with 1,000 employees whose DFEH report shows that women make on average 5% more than men. Her benefits remain unchanged.
• Woman 2 works for a company with 90 If the company did file a DFEH report, it would show that women, on average, make the same as men. The national average difference in pay for her occupation is 20%. Her benefits increase by 20%.

The above examples demonstrate how ludicrous this bill would operate in practice. Even if amendments were taken to key all increases off of the national averages, which the sponsors have suggested as a potential alternative, the underlying flaw in this bill remains the same: that the proposed benefit increases rest on pure assumptions, not facts about whether a female employee is being fairly paid.

SB 1458 Conflicts with Labor Code Section 4453

 

Labor Code Section 4453 provides for minimum and maximum wages for purposes of temporary and permanent total disability payments as well as for permanent partial disability payments. If a worker were entitled to an increase under SB 1458 that pushed their payment total over those statutory maximums, this would create a conflict between the two provisions.

Further, SB 1458 does not address workers who have multiple employers and would therefore either have different DFEH reports or it is possible that one files a report and the other does not. This creates further conflicts with Labor Code Section 4453(c)(2), which provides:

Where the employee is working for two or more employers at or about the time of the injury, the average weekly earnings shall be taken as the aggregate of these earnings from all employments computed in terms of one week; but the earnings from employments other than the employment in which the injury occurred shall not be taken at a higher rate than the hourly rate paid at the time of the injury.

SB 1458 Creates Conflicts Between State Agency Authority

 

The Workers’ Compensation Appeals Board (WCAB) presently has jurisdiction over workers’ compensation benefits. However, the Department of Industrial Relations (DIR) and DFEH are tasked with enforcement of the Equal Pay Act and Fair Employment and Housing Act, which govern the underlying issue of pay discrimination. If there were any sort of dispute over whether a worker should be owed increased benefits,

it is unclear which agency properly would have jurisdiction because neither department is expected to deal with both workers’ compensation and alleged pay discrimination.

For these reasons, and others, we respectfully OPPOSE your SB 1458.

 

Sincerely,

Ashley Hoffman Policy Advocate

California Chamber of Commerce

cc: Legislative Affairs, Office of the Governor AH:am