Tag Archive for Federal Mediation and Conciliation Service

$348 Million Measure Q for Solano Community College: Yes on Q Campaign Fails to Submit Latest Legally-Required Campaign Finance Report

UPDATE: The Yes on Q campaign for Solano Community College District submitted its overdue Form 460 today (Monday, October 29, 2012). Better late than never.

As of October 20, 2012, the campaign has raised over $200,000. Big contributions between October 1 and October 20 include $15,000 from Swinerton (a construction management firm) and $10,000 from MuniBond Solar, run by someone named Steve Nielsen, which has collaborated with companies such as SunPower Corp to secure “Qualified Energy Conservation Bonds” (QECBs) for several California educational districts. (An executive with SunPower Corp also contributed $1000.) As shown in this May 2, 2012 Solano Community College Financial and Budget Planning Advisory Council meeting, MuniBond Solar wants a relationship with Solano Community College District.

Other contributors include the usual suspects: architects, construction trade unions, and unionized construction associations that look forward to a Project Labor Agreement.


Yesterday (October 26, 2012) I went to the Solano County Registrar of Voters office to obtain the paper copies of the Form 460 reports that the “Yes on Q – Solano College” campaign must legally submit to the county. These reports are meant to inform the public about campaign receipts and expenditures. The staff there was quite professional and helpful, but I left knowing that the Yes on Q campaign was breaking the law and getting away with it.

Measure Q asks Solano County voters to let the Solano Community College District Governing Board borrow $348 million for construction by selling bonds to institutional investors. Solano County taxpayers must pay this money back to the investors – with interest! It will cost at least $500 million – perhaps more if the district is lured into selling Capital Appreciation Bonds.

The Solano Community College District Governing Board wants to borrow $346 million by selling bonds

The Solano Community College District Governing Board wants to borrow $348 million by selling bonds.

The Solano College governing board voted 6-1 in 2003 and 2004 to require its construction contractors to sign Project Labor Agreements with unions as a condition of working on projects funded by bonds authorized by the $124.5 million Measure G, barely approved by 55.6% of Solano County voters in November 2002. A majority of governing board members are likely to again make a deal to give unions control of additional projects funded by Measure Q. Project Labor Agreements raise costs and cut competition, as shown by the failure of the Project Labor Agreement pilot project at Solano Community College in 2005. (No one on the board cared at the time.)

The Yes on Q campaign finance report for the period from October 1 to October 20 was due by October 25, but it was not at the Solano County Registrar of Voters on October 26. After further inquiry, I learned this afternoon that an official of the Solano County Registrar of Voters had contacted the treasurer of the “Yes on Q – Solano College” campaign to check on the status and was told the report would not be turned in until Monday or Tuesday of next week.

So much for openness and transparency for citizens as they fill out their absentee ballots this weekend. I guess the local newspapers won’t be informing the voters in their Sunday editions who is giving to the Yes on Q campaign and who is getting from the Yes on Q campaign. Does anyone care?

I did get a copy of the campaign finance report of the “Yes on Q Solano College” for the period from July 1, 2012 to September 30, 2012. Here are a few items of interest:

1. This Campaign Is a Sitting Duck for Accusations of “Pay-to-Play”

Here’s a list of all of the campaign contributors through September 30, 2012, with links to the company web sites, the amounts contributed, and the business interest of the contributor.

DONOR INTEREST AMOUNT
Piper Jaffray Investment Bank/Bond Broker $25,000
Kitchell Construction Construction Manager for Solano College Measure G $25,000
RBC Capital Markets Investment Bank/Bond Broker $18,000
Steinberg Architects Architect $10,000
VBN Architects Architect $10,000
[Sheet Metal Workers Local Union No. 104] Bay Area Industry Promotion Fund Construction trade union-affiliated Labor-Management Cooperation Committee $5,000
Stradling, Yocca, Carlson and Rauth Bond counsel – worked before with Solano College on bond sales $3,500
Keenan and Associates Insurance broker for school districts $2,500
B&L Properties Property holding company in Fairfield $2,500
Dannis Woliver Kelley Law firm for school & college districts $2,500
The Lew Edwards Group Political consulting firm in Oakland, works to pass bond measures $1,000
LPAS Architect $1,000
Roy Stutzman Consulting Financial consulting for school & college districts $1,000
Student Insurance Insurance company for school districts $1,000
Fairbank, Maslin, Maullin Metz & Associates Polling firm for political campaigns $500
Bricklayers and Allied Craftsworkers Local Union No. 3 Construction trade union $200
Sarah Chapman Solano College Board Member $100
Rosemary Thurston Solano College Board Member $100
Anne Marie Young Solano College Board Member $100
James Dekloe Solano College Faculty Member $100
TOTAL $109,100

There’s very little financial participation in this campaign from anyone in Solano County, but there is much interest from various professional service firms that do business with Solano Community College District and/or want business if voters approve Measure Q and let the Governing Board sell $348 million in bonds. I guess that’s how the world works, but taxpayers will pay the bill.

2. Underwriters Among Top Contributors – These Firms Get Fees When Selling Bonds

After the investment bank/bond underwriter Piper Jaffray got smacked around along with other financial service firms earlier this year about contributing to campaigns for bond measures for which it subsequently became the underwriter for those bonds, I figured that firm would back off from the practice. I was wrong.

Piper Jaffray $25,000 campaign contribution to Yes on Measure Q Solano College November 2012

Piper Jaffray $25,000 campaign contribution to Yes on Measure Q – Solano College (November 2012)

Piper Jaffray is tied with Kitchell Construction – the construction management firm for Solano Community College’s Measure G (2002) program – for making the largest contribution to the Yes on Q campaign.

3. Another Labor-Management Cooperation Committee Contributes to a Campaign.

Bay Area Industry Promotion Fund - $5000 Contribution to the Yes on Measure Q Solano College

Bay Area Industry Promotion Fund – $5000 Contribution to Yes on Measure Q Solano College

I snickered when I saw this one: how many people in Solano County know about the Bay Area Industry Promotion Fund? There’s only one place on the web where you’ll read about labor-management cooperative trusts, and you’re reading it now. These trusts are arcane entities authorized by the obscure Labor-Management Cooperation Act of 1978, a law signed by President Jimmy Carter and implemented by the Federal Mediation and Conciliation Service. There are no federal or state regulations specifically addressed toward these trusts, and these trusts do not have any reporting requirements to the U.S. Department of Labor’s Office of Labor-Management Standards.

This committee receives employer payments as indicated in the Master Labor Agreement negotiated between the Sheet Metal and Air Conditioning Contractors’ National Association (SMACNA) and the Sheet Metal Workers International Association Local Union No. 104. Here are references to the Bay Area Industry Promotion Fund in their Master Labor Agreement. It says the fund pays to replace stolen tools, but says nothing about political contributions, of course. Note also that employer payments to the Bay Area Industry Promotion Fund are incorporated as part of “Other” into the State of California’s government-mandated construction wage rates (so-called “prevailing wages”).

4. If Yes on Q Raised $109,100 by September 30, 2012, How Was It Spent?

Solano County newspapers have noted the lack of visible campaign activity in support of Measure Q. In fact, this situation apparently deprived Yes on Q of an endorsement from the Vacaville Reporter newspaper:

The Reporter Editorial Board likes the vision and very much wants to support it. But board members have qualms about this bond. The impact of the state’s fiscal mess has meant the college can’t afford to operate the programs it has now. Is it wise to add new programs before the state’s budget is under control?

There are also qualms about the way the bond campaign has been mishandled. In July, when the Editorial Board supported trustees’ decision to put the bond on the ballot, it was with the caveat that an aggressive campaign be mounted to educate the community about its need.

Instead, the campaign has been lackluster and late, not ratcheting up until after mail-in ballots were already out. Where are the trustees, who can speak as individuals in support of the measure and who should have lined up supporters to drive it? Where are the other public agencies and private businesses that stand to benefit from these plans? Where is the faculty, whose union put on a get-out-the-vote drive for Propositions 30 and 32 without even mentioning Measure Q in its publicity? Does the lack of organization in the campaign reflect a lack of organization and follow-through by campus leaders?

I drove on the major thoroughfares of Vacaville, Fairfield, and Vallejo on October 26. I only saw THREE signs supporting Measure Q – all close to the entrance to the main Solano Campus campus in Fairfield.

An elusive Yes on Q campaign sign in Solano County.

An elusive Yes on Q campaign sign in Solano County.

Not that I put much value on campaign signs stuck in public areas, but I would have expected more for a campaign that already had over $100,000 by the end of September. This lack of visibility is so pitiful that it was tied with the three No on Q signs I saw in Solano County. That campaign is a small, committed group of informed local taxpayer activists with very little money to spend.

Say "No" to $348 Million Bond - No on Q - Taxed Enough Already!

Say “No” to $348 Million Bond – No on Q – Taxed Enough Already!

The September 30 campaign report for Yes on Q shows about $25,000 spent on consultants, slate mailers, some apparent development of signs and mailers, and people at phone banks. It will be interesting to see how the remaining money was spent, provided the Yes on Q campaign ever submits its campaign finance reports.

Feds Need Better Oversight of Labor-Management Cooperation Committees, Such as the Union Slush Fund that Spent $1.1 Million in the June 2012 Election in the City of San Diego

An August 27, 2012 article on the Investigative Newsource – Southern California web site contains the latest fleeting news reference to the California Construction Industry Labor-Management Cooperation Trust. The last two paragraphs of “Outside Donors Fuel Prop. Opponents, Fund Mayoral Hopefuls” states the following about Proposition A campaign in the City of San Diego for the June 6, 2012 election:

The California Construction Industry Labor Management Cooperation Trust, a nonprofit located in Sacramento that promotes and protects project labor agreements around the state, donated more than $1 million to try unsuccessfully to defeat Prop. A, which banned project labor agreements. The agreements set some of the terms of employment, such as wage rates, on construction projects.

The Trust gets much of its money from laborers themselves. Clauses in some project labor agreements dictate that a portion of money per hour worked goes to the Trust.

The same Investigative Newsource was alone among news media groups in highlighting the extensive campaign involvement of this obscure organization before the June 6, 2012 election. From the May 25, 2012 article “Business Groups, Builders and Labor Battle over Propositions:”

All of the money for the one of the committees opposing Proposition A has come from the same donor.

Since March 18, the California Construction Industry Labor Management Cooperation Trust donated $675,000 to Taxpayers to Preserve Community Jobs.

The California Construction Industry Labor Management Cooperation Trust is a tax-exempt Sacramento-based organization, which says its mission is, among other things, to “improve public awareness of the benefit of using organized labor contractors and workers.” The group is not required by the IRS to list specific sources of funding, but in general, it reported on its 2010 tax returns collecting $678,000 in membership dues. It reported more than $3 million in assets.

And the trust fund is also cited in the June 1, 2012 Investigative Newsource article “Fundraising Amps Up for Proposition A, B Committees:”

In the past week, a union trust gave an additional $320,000 into defeating Proposition A, a ballot measure that would ban project labor agreements for San Diego city projects if passed.

That brings to $1.18 million the amount raised by the anti-Prop. A forces, far outpacing the business interests pushing Proposition A. That committee, Fair and Open Competition, has raised $755,000 so far.

Taxpayers to Preserve Community Jobs — an anti-Prop. A committee — has benefited mainly from the California Construction Industry Labor Management Cooperation Trust. The trust is responsible for more than 90 percent of its donations.

The labor trust is “heavily involved” with promoting and protecting project labor agreements (PLAs) around the state, according to secretary/treasurer Scott Strawbridge. A PLA is a type of collective bargaining agreement that a city can enter into with workers for city projects.

“We think (PLAs) are good business for our contractors and union members,” Strawbridge said.

A big part of the money in the trust comes from laborers themselves, he said. Clauses in certain PLAs specify that a small amount of money per hour worked goes into the trust.

The San Diego Union-Tribune briefly and generally mentioned the fund after the election, in the June 7, 2012 article “Impact of Proposition A on State Funds in Dispute:”

The major backer of the No on A campaign was a Sacramento-based group headed by Robert Balgenorth, the president of the State Building and Construction Trades Council of California, a statewide union, which donated $1.1 million to stop it from passing.

This brief public reference was enough to provoke Scott Strawbridge (cited in the Investigative Newsource article above) to defend the California Construction Industry Labor-Management Cooperative Trust publicly with an opinion piece in the Union-Tribune. (“In Response: Prop. A Put San Diego Citizens in Difficult Position,” June 22, 2012)

In doing so, he provided a public service in highlighting the unregulated slush fund that spent $1,095,000 to oppose Proposition A, a fair and open competition ordinance approved by 58% of San Diego voters on June 5.

This mysterious, Sacramento-based California Construction Industry Labor-Management Cooperative Trust is authorized by the obscure Labor-Management Cooperation Act of 1978, a law signed by President Jimmy Carter.

The law lists specific purposes for these trusts: “improving labor-management relationships, job security, organizational effectiveness, enhancing economic development or involving workers in decisions affecting their jobs including improving communication with respect to subjects of mutual interest and concern.” And many trusts operating under this law do just that.

Nevertheless, the California Construction Industry Labor-Management Cooperative Trust circumvents these purposes without consequence.

The Federal Mediation and Conciliation Service hasn’t implemented regulations to monitor or limit how such trusts operate. And these trusts don’t have any reporting requirements to the U.S. Department of Labor’s Office of Labor Management Standards.

Who wouldn’t enjoy having a slush fund with minimal oversight and controls?

The California Construction Industry Labor-Management Cooperative Trust recently gave $100,000 to the Apollo Alliance, $250,000 to a campaign committee opposing reforms to state eminent domain laws, and $770,000 to the biased California Construction Academy of the University of California Miguel Contreras Labor Program. It also gave $164,550 to “Other.”

How does the California Construction Industry Labor-Management Cooperative Trust get its money? Do people contribute to it through the goodness of their hearts?

Actually, owners of proposed power plants (and their construction contractors) fund it when they sign Project Labor Agreements (PLAs) that require payments to it.

Power plant owners don’t sign these union agreements because they want union monopolies on construction or appreciate the California Construction Industry Labor-Management Cooperative Trust.

Instead, they sign them to discourage California Unions for Reliable Energy (CURE) from exploiting environmental laws to interfere with approval of their proposed power plants at the California Energy Commission and other government agencies.

It’s a tangled conspiracy. Especially intriguing is that one union official is the head of the State Building and Construction Trades Council of California, the California Construction Industry Labor-Management Cooperative Trust, and California Unions for Reliable Energy.

Another interesting angle: when publicly-owned utilities sign these Project Labor Agreements, their electric customers ultimately fund the California Construction Industry Labor-Management Cooperative Trust through their bills.

Senate Bill 790 – signed into law by Governor Jerrry Brown in 2011 – allows publicly-owned utilities to pass through to ratepayers the cost of payments to trusts authorized by the Labor Management Cooperation Act of 1978.

In its annual Form 990 statements to the IRS, the California Construction Industry Labor-Management Cooperative Trust classifies its receipts as “membership dues.” How do “members” such as the Northern California Power Agency and the Southern California Public Power Authority decide to contribute $1,095,000 to the No on A campaign in the City of San Diego?

It’s time to stop these abuses. If Mitt Romney is elected President, his appointees to oversee the Federal Mediation and Conciliation Service and the Office of Labor Management Standards need to implement reasonable regulations for trusts authorized under the Labor-Management Cooperation Act of 1978.

California’s Top Construction Union Boss Opens the Slush Fund Hydrant: $1.14 Million Full-Blast Against San Diego’s Proposition A Voter Initiative

Here’s yet another scoop from the Dayton Public Policy Institute about how unions are influencing the June 2012 elections in California: one supreme union official based in Sacramento has pumped $1.14 million into San Diego to defeat a city voter initiative called Proposition A. And some of the cash originally comes from utility ratepayers.

For readers unfamiliar with Proposition A, read immediately below. Those who know about Proposition A can proceed down to read about the union sources of $1.14 million for the No on A campaign.

Who Supports Proposition A in San Diego, and Why?

In 2011, San Diego voters signed petitions to qualify a Fair and Open Competition ordinance for consideration in the June 5, 2012 election. It was the first measure placed by voters on the city ballot since 1998. Now designated on the ballot as Proposition A, the Fair and Open Competition ordinance would prohibit the City of San Diego from requiring construction companies to sign a Project Labor Agreement (PLA) with unions as a condition of working on a taxpayer-funded project. It also contains language requiring the city to post certain contract information on-line.

The campaign to enact Proposition A is strongly supported by construction companies and construction trade associations. This is no surprise, since most construction companies work directly with their employees (either individually or collectively through a union) to determine the terms and conditions of work. They don’t want two-bit local politicians to negotiate separate 30-page to 60-page labor agreements with union officials (i.e. the politicians’ campaign contributors) and then impose those agreements on their businesses.

Many companies refuse to bid on work that includes a government-mandated Project Labor Agreement in the bid specifications. The resulting reduction in the number of bidders competing for contracts results in higher costs for taxpayers (as academic studies, basic economic theory, and common sense would predict).

See the YES on A campaign web site here and contributors to the YES on A campaign here.

Who Opposes Proposition A in San Diego, and Why?

The main opponents of Fair and Open Competition policies are obviously construction trade unions, which regard government-mandated Project Labor Agreements as an effective political tactic to cut bid competition and raise costs for their own benefit. With Project Labor Agreements, union organizers can completely avoid the unpleasant and time-consuming task of selling the benefits of unionization to skeptical workers. Instead, they simply ask their political allies in government to give them a union monopoly on construction!

Most construction unions in California belong under the umbrella of the State Building and Construction Trades Council of California, a union conglomerate based in Sacramento under the leadership of president Bob Balgenorth. If you look at the list of contributors to the No on A campaign (Taxpayers to Preserve Community Jobs, No on Measure A, sponsored by labor and management organizations), you’ll see the top two donors are Sacramento-based union-affiliated organizations under the direction of Bob Balgenorth. These two entities contributed $1.14 million to the No on A campaign, comprising 96% of all campaign receipts.

Let’s take a closer look at these two massive organizations funding the No on A campaign. One of them is a routine political action committee, but the other is a conspiracy theorist’s dream come true.

A Union Political Action Committee Gave One $45,000 Late Contribution, Comprising 3.8 Percent of the Contributions to the No on A Campaign

The Sacramento-based committee known as “Members’ Voice of the State Building Trades Council of California” made a late expenditure contribution of $45,000 to the No on A campaign on May 24. As you can see on the California Secretary of State’s web site, this committee collects money from various local construction unions and disburses the money to various campaigns for candidates and ballot measures. The Assistant Treasurer of the Members’ Voice of the State Building Trades Council of California is Bob Balgenorth.

A Mysterious Union Slush Fund, Authorized by an Obscure 1978 Federal Law to Encourage Better Relationships Between Unions and Manufacturers, Gave $1,095,000 to No on A – a Whopping 92% of All Receipts!

Something called the California Construction Industry Labor-Management Cooperative Trust contributed a total of $1,095,000 to the No on A campaign. This is an extraordinarily high amount for a political contribution from one entity, especially concerning a local ballot measure! The head of the California Construction Industry Labor-Management Cooperative Trust is Bob Balgenorth.

This is NOT a traditional Political Action Committee. It is an arcane type of union trust authorized by the obscure Labor-Management Cooperation Act of 1978, a law signed by President Jimmy Carter and implemented by the Federal Mediation and Conciliation Service. Inspired by the decline of unionized manufacturing in the Northeast, this federal law was meant to help industrial management and union officials build better personal relationships and cooperate against the threat of outside competition. There are no federal or state regulations specifically addressed toward these trusts, and these trusts do not have any reporting requirements to the U.S. Department of Labor’s Office of Labor-Management Standards. This is an ambiguous and forgotten law that’s ripe for abuse.

It’s Not Union Members that Give the Money to the California Construction Industry Labor-Management Cooperative Trust: It’s Utility Ratepayers and Contractors Working for Extorted Power Plant Owners

Since the 1990s, whenever an energy company or public utility submits an application to the California Energy Commission seeking approval of a new power plant, an organization called California Unions for Reliable Energy (CURE) often “intervenes” in the licensing process. Represented by a South San Francisco law firm called Adams Broadwell Joseph & Cardozo, CURE submits massive data requests and environmental objections to the California Energy Commission. The applicant by law is required to answer CURE’s submissions, at significant cost and delay. The chairman of California Unions for Reliable Energy (CURE) is Bob Balgenorth.

If the power plant owner agrees to sign a Project Labor Agreement and require its construction contractors to sign a Project Labor Agreement with the State Building and Construction Trades Council of California or its regional affiliates, CURE’s objections go away and the power plant can proceed unhindered through the licensing process. If the company or utility does not surrender to CURE’s demand, then CURE’s interference and lawsuits continue.

This racket – sometimes called “greenmail” because it’s the use of environmental laws to pressure developers to sign Project Labor Agreements – is well-known to the energy industry in California and has been extensively reported in the news media over the past dozen years. (For example, see Labor Coalition’s Tactics on Renewable Energy Projects Are Criticized – Los Angeles Times – February 5, 2011.)

For cases in which the power plant applicant succumbs to CURE’s harassment, the Project Labor Agreement that the power plant owner signs usually contains a provision requiring the owner or its contractors to make a lump-sum payment or series of payments to the California Construction Industry Labor-Management Cooperative Trust.

For example, the Project Labor Agreement signed by the Northern California Power Agency (a conglomerate of publicly-owned utilities) for the construction of the Lodi Energy Center required the agency to shell out $90,000 to the California Construction Industry Labor-Management Cooperative Trust. That amount was dutifully mailed to Bob Balgenorth on August 17, 2010. (For more on this payment, see High Energy: Lodi Center Designed to be a Powerhouse for Chunk of State – Stockton Record – October 4, 2011; also, the union rebuttal on the California Building Trades Council web site – ABC Falsehoods Refuted in Letter to Stockton Record – a denial that the California Construction Industry Labor-Management Cooperative Trust is used for political contributions.)

And the Project Labor Agreement signed by the Southern California Public Power Authority (another conglomerate of publicly-owned utilities) for the construction of the City of Anaheim’s Canyon Power Plant required the agency to shell out $65,000 to the California Construction Industry Labor-Management Cooperative Trust. See Section 13.1 of the Project Labor Agreement here.

The California Construction Industry Labor-Management Cooperative Trust reports these payments as “membership dues” to the Internal Revenue Service. Which brings up a question: are the local elected officials who serve as commissioners for the Northern California Power Agency and the Southern California Public Power Authority exercising their responsibilities as “members” to approve $1,095,000 in political contributions to the No on A campaign?

But Wait a Minute…Is It Legal to Have Utility Ratepayers Fund a Mysterious Union Trust Fund that Contributes to Political Campaigns, Such as No on A?

Well, in 2009 an internal committee of the Northern California Power Agency discussed whether or not a payment to the California Construction Industry Labor-Management Cooperative Trust was an illegal gift of public funds. (See here. Note the original amount to the California Construction Industry Labor-Management Cooperative Trust was supposed to be $150,000, but aggressive opposition to the Project Labor Agreement forced the unions to cut it down to $90,000 in order to win approval from the board of commissioners.)

To solve this uncertainty, in May 2011 State Senator Mark Leno (D-San Francisco) added a cryptic amendment at the request of union lobbyists and lawyers to the end of a large unrelated public utilities bill (Senate Bill 790) regarding “community choice aggregation.” It added Section 3260 to the Public Utilities Code: “Nothing in this division prohibits payments pursuant to an agreement authorized by the National Labor Relations Act (29 U.S.C. Sec. 151 et seq.), or payments permitted by the federal Labor Management Cooperation Act of 1978 (29 U.S.C. Secs. 173, 175a, and 186). Nothing in this division restricts any use permitted by federal law of money paid pursuant to these acts.”

No one in the California State Legislature – apparently not even Senator Leno – initially knew what this strange new provision meant. In the end, a few legislators such as Assemblywoman Shannon Grove (R-Bakersfield) came to understand and reveal in floor debate that it authorized public utilities to pass on the costs of payments to labor-management cooperation committees to ratepayers. Governor Brown signed the bill into law with the language tacked on the end.

For more information, see the investigative report of the Coalition for Fair Employment in Construction at this September 23, 2011 post at www.TheTruthaboutPLAs.com: A Genuine California Union Conspiracy: Senate Bill 790 and the California Building Trades Council’s Ratepayer Funded Political Slush Fund

Confused about the Conspiracy? Here’s a Chart.

A public utility or private energy company applies to the California Energy Commission for approval to build a power plant.

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California Unions for Reliable Energy (CURE) uses its “intervenor” status at the California Energy Commission to submit massive data requests and environmental complaints about the proposed power plant, as a result gumming up the licensing process and causing costly and lengthy delays for the applicant.

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Applicant for prospective power plant surrenders and agrees to sign Project Labor Agreement with State Building and Construction Trades Council of California or its regional affiliates. CURE releases its grip of legal paperwork and the project moves forward unimpeded and acclaimed as environmentally sound.

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The Project Labor Agreement contains a required payment or payments to the California Construction Industry Labor-Management Cooperative Trust. California Public Utilities Code Section 3260 – enacted by Senate Bill 790 in 2011 – allows public utilities to pass costs through to ratepayers.

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California Construction Industry Labor-Management Cooperative Trust reports those payments to the IRS as “Membership Dues,” creating questions about the rights inherent for dues-paying members.

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California Construction Industry Labor-Management Cooperative Trust makes contributions to political campaigns, such as $1,095,000 to fund 92% of the No on A campaign (Taxpayers to Preserve Community Jobs, No on Measure A, sponsored by labor and management organizations) in the City of San Diego in 2012.