[Iabs-talk] Reminder! Comments regarding the Executive Order are needed by Sunday!

Sat Jul 26 17:29:54 UTC 2014

Here is what I wrote.  Has anyone else sent in their comments?

							Patti S. Gregory-Chang Esq.
							6919 W. Berwyn Ave. 
							Chicago, IL 60656
							(773) 307-6440

Ms. Mary Ziegler
Director of the Division of Regulations, Legislation, and Interpretation
U.S. Department of Labor, Wage and Hour Division
200 Constitution Avenue, N.W., Room S-3510
Washington, DC 20210

Re:  Notice of Proposed Rulemaking: Establishing a Minimum Wage for Contractors RIN: 1235-AA10

Dear Ms. Ziegler:

I write in two capacities, as an individual with a disability and as the President of the largest organization of the blind in Illinois, the National Federation of the Blind of Illinois.  I have personally spoken with blind people who were paid less than the minimum wage despite their having been awarded productivity plaques from the same employer who paid minimum wage to less productive sighted employees.  This is a travesty which must stop.  

I fully support the Notice of Proposed Rulemaking (NPRM) of the executive order “Establishing a Minimum Wage for Contractors.” I sincerely thank the president and the Department of Labor for formulating this executive order as I feel that it is an important first step toward ensuring equality in the workplace for American workers with disabilities.

I applaud the Department of Labor for including people with disabilities whose wages are calculated under Section 14(c) of the Fair Labor Standards Act in the definition of “worker.” People with disabilities are indeed workers, and with the proper training and support can be just as productive as non-disabled peers. I believe that the biggest obstacle that people with disabilities face to equal employment is low expectations. When we are held to the same standards as our non-disabled peers we will rise to the occasion and perform to the level that is expected of us. We may need accommodations to do this, but laws such as the Americans with Disabilities Act and Rehabilitation Act legally grant us these reasonable accommodations.

Executive Order 13658 states that any new or renewed federal contract that provides services starting on or after January 1, 2015 will be required to pay all employees at least $10.10 an hour. I hope that the contracts placed on the AbilityOne Procurement List (PL) will not be exempted from this wage floor requirement. Although these contracts, once placed on the PL, are exempted from external competition, they are subject to renewal and renegotiation as any other contract. Most importantly, these contracts employ workers with disabilities that (if the contracts are exempted) would not benefit from the increase wage provided through the executive order as intended.

I believe that excluding people with disabilities from the protection of the minimum wage is discriminatory, and the NPRM of the executive order “Establishing a Minimum Wage for Contractors” takes an important first step in eliminating the practice of paying people with disabilities subminimum wages. I hope that the Department of Labor and the president will continue to work with stakeholders to ensure that Americans with disabilities are guaranteed the protections in the workplace that we deserve. Thank you for considering my feedback.

Sincerely,
Patti S. Gregory-Chang Esq. 
_______________

Live the Life You Want.

Patti Gregory Chang
National Federation of the Blind of Illinois, President
NFB Scholarship Committee Chair 
pattischang at gmail.com
www.nfbofillinois.org

Begin forwarded message:

From: "Sloan, Rose via Nfb-legislative-directors" <nfb-legislative-directors at nfbnet.org>
Subject: [Nfb-legislative-directors] Reminder! Comments regarding the Executive Order are needed by Sunday!
Date: July 25, 2014 9:04:31 AM CDT
To: "'Nfb-legislative-directors at nfbnet.org'" <Nfb-legislative-directors at nfbnet.org>
Reply-To: "Sloan, Rose" <rsloan at nfb.org>, NFB Legislative Directors List <nfb-legislative-directors at nfbnet.org>

Dear Federation Family,

This is a friendly reminder that comments regarding the notice of proposed rulemaking are due to me (Rsloan at nfb.org) this Sunday at 8 PM.  Please see below for more information.  This is an easy way to have our voices heard and ensure that AbilityOne contracts will be required to obey the Executive Order. 

When you send a letter, please include your full mailing address. 

Thanks in advance.

Yours in the fight for fair wages,

Rose

Rose Sloan
Government Affairs Specialist
NATIONAL FEDERATION OF THE BLIND

“Eliminating Subminimum Wages for People with Disabilities”
http://www.nfb.org/fairwages

From: Nfb-legislative-directors [mailto:nfb-legislative-directors-bounces at nfbnet.org] On Behalf Of Sloan, Rose via Nfb-legislative-directors
Sent: Monday, July 21, 2014 8:56 AM
To: 'Nfb-legislative-directors at nfbnet.org'
Subject: [Nfb-legislative-directors] Comments Needed to Ensure that Executive Order Doesn’t Exempt 14c Entities from Paying New Minimum Wage

Fellow Federationists:

As you know, President Obama has issued an executive order that raises the minimum wage for federally contracted service providers—including those employees who are being paid under Section 14(c) of the Fair Labor Standards Act. The Notice of Proposed Rule Making (NPRM), the interpretation of this executive order, has been released by the Department of Labor (DOL). They will be accepting comments until July 28.

It is important that we express our support for the Executive Order. We’ve heard that some people might urge DOL to exempt some organizations that use 14(c) certificates, and we want to outnumber that kind of feedback.

I encourage each of you to send me comments that you would like submitted. For your convenience, I have provided a sample letter. Please feel free to use some of this language in the comments you wish to be sent, specifically the part about AbilityOne’s Procurement List (PL) contracts.

###

Ms. Mary Ziegler
Director of the Division of Regulations, Legislation, and Interpretation
U.S. Department of Labor, Wage and Hour Division
200 Constitution Avenue, N.W., Room S-3510
Washington, DC 20210

Re:  Notice of Proposed Rulemaking: Establishing a Minimum Wage for Contractors RIN: 1235-AA10

Dear Ms. Ziegler:

I fully support the Notice of Proposed Rulemaking (NPRM) of the executive order “Establishing a Minimum Wage for Contractors.” I sincerely thank the president and the Department of Labor for formulating this executive order as I feel that it is an important first step toward ensuring equality in the workplace for American workers with disabilities.

I applaud the Department of Labor for including people with disabilities whose wages are calculated under Section 14(c) of the Fair Labor Standards Act in the definition of “worker.” People with disabilities are indeed workers, and with the proper training and support can be just as productive as non-disabled peers. I believe that the biggest obstacle that people with disabilities face to equal employment is low expectations. When we are held to the same standards as our non-disabled peers we will rise to the occasion and perform to the level that is expected of us. We may need accommodations to do this, but laws such as the Americans with Disabilities Act and Rehabilitation Act legally grant us these reasonable accommodations.

Executive Order 13658 states that any new or renewed federal contract that provides services starting on or after January 1, 2015 will be required to pay all employees at least $10.10 an hour. I hope that the contracts placed on the AbilityOne Procurement List (PL) will not be exempted from this wage floor requirement. Although these contracts, once placed on the PL, are exempted from external competition, they are subject to renewal and renegotiation as any other contract. Most importantly, these contracts employ workers with disabilities that (if the contracts are exempted) would not benefit from the increase wage provided through the executive order as intended.

I believe that excluding people with disabilities from the protection of the minimum wage is discriminatory, and the NPRM of the executive order “Establishing a Minimum Wage for Contractors” takes an important first step in eliminating the practice of paying people with disabilities subminimum wages. I hope that the Department of Labor and the president will continue to work with stakeholders to ensure that Americans with disabilities are guaranteed the protections in the workplace that we deserve. Thank you for considering my feedback.

Sincerely,

_______________

###

Please send your comments to me at rsloan at nfb.org no later than 8 PM on Sunday, July 27th. Thanks for all that you do, and I look forward to reading your comments!

Yours in the fight for fair wages,

Rose

Rose Sloan
Government Affairs Specialist

National Federation of the Blind
200 East Wells Street
Baltimore, MD 21230
Phone: (410) 659-9314, extension 2441
Email: rsloan at nfb.org

“Eliminating Subminimum Wages for People with Disabilities”
http://www.nfb.org/fair-wages

The National Federation of the Blind knows that blindness is not the characteristic that defines you or your future. Every day we raise the expectations of blind people, because low expectations create obstacles between blind people and our dreams. You can live the life you want; blindness is not what holds you back.

To make a donation to the National Federation of the Blind Imagination Fund, please visitwww.nfb.org/ImaginingOurFuture.

_______________________________________________
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