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Exhibit D <br />Mike Hogan, Chairman <br />January 26, 2015 <br />Page 3 <br />deserving cases. <br />8. (New) Article 26.05: Local 2201 rejects the Special Magistrate's recommendation with <br />respect to the addition of various restrictions on employees who request leave. First, other <br />than the County falsely accusing a particular employee of being a "sick leave abuser," the <br />County submitted no evidence in support of its proposal. Second, items in the County's <br />proposal make no sense such as requiring an employee to schedule treatment by a doctor 72 <br />hours in advance. Finally, the Special Magistrate provided no justification for his <br />recommendation. <br />9. (New) Article 26.06: Local 2201 rejects the Special Magistrate's recommendations with <br />respect to charging leave as identified in (new) Section 26.06(A), (B), and (C). Again, the <br />employer provided no evidence in support of its proposal and the Special Magistrate <br />provided no explanation for his recommendations. <br />10. Article 28 - Annual Leave: Local 2201 rejects the Special Magistrate's recommendation to <br />add a sentence to Section 28.03 as the employer provided no justification; the Special <br />Magistrate provided no explanation; and both the County and the Special Magistrate ignored <br />concrete evidence on comparisons. <br />11. Article 33 - Incentive Pay: Local 2201 rejects the Special Magistrate's recommendation with <br />respect to Section 33.10 which would require the Fire Chief to fill solo paramedic slots <br />which the County funded and which allow protocoled medics to obtain solo medic status. <br />Filling funded solo paramedic slots and allowing protocoled paramedics to obtain solo <br />paramedic status is supported by comparables, the interest and welfare of the public, the <br />peculiarities of employment, and the availability of funds. <br />12. Article 34 - Salaries: It is not clear that the Special Magistrate had any idea what he was <br />doing. He initially made recommendations covering four fiscal years. That statement <br />provides at least one basis for the rejections identified below. <br />First, Local 2201 accepts the Special Magistrate's recommendations with respect to the three <br />percent COLA increase; the maintenance of the status quo of a nine -step level and five <br />percent wage increase for all employees eligible; and lump sums payments to employees who <br />do not receive the step level increases. However, Local 2201 rejects the recommended <br />effective date of Union ratification and County approval. As cause, Local 2201 would note <br />that the Special Magistrate ignored substantial evidence with respect to comparisons; the <br />interest and welfare ofthe public; the peculiarities of employment; and the availability funds. <br />Furthermore, as noted above, the Special Magistrate apparently did not even understand that <br />the first year at impasse was fiscal year October 2013 through September 2014. <br />Second, Local 2201 rejects the Special Magistrate's recommendations with respect to Article <br />34 - Salaries for fiscal years 2015-2016 and 2016-2017 which were later changed to <br />recommendations for fiscal years 2014-2015 and 2015-2016. As cause, Local 2201 would <br />49 <br />