[il-talk] Fwd: FW: Comments Needed to Ensure that Executive Order Doesn’t Exempt 14c Entities from Paying New Minimum Wage

Mon Jul 28 01:00:01 UTC 2014

sorry so last minute, here is my comment, Rose, feel free to change the
header if it is better addressed differently:

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

Dear Ms. Ziegler:

Both as a disabled American and member of the National Federation of the
Blind, I am pleased that the DOL’s Notice of Proposed Rulemaking referring
to the executive order *Establishing a Minimum Wage for Contractors *does
not leave out disabled workers in the definition of “workers”—who currently
are being paid under section 14c of the Fair Labor Standards Act, which for
decades has left them unprotected from subminimum wage exploitation.

It is important that disabled workers be presumed as people first, entitled
to the same consideration of ability potential, and standard of pay as non
disabled workers, and that disabled workers be able to gain skills in
rehabilitation programs that begin with the belief that they can be
rehabilitated and fully productive people, rather than subject to working
conditions that so often use the identity of disability as a convenient
avenue to cheap labor. For disabled workers to become more fully integrated
into the full benefits of American life, it is crucial that we be included
with other workers protected by the minimum guarantee given to all.

As Executive Order 13658, gives a minimum wage guarantee of $10.10 to
federally contracted workers, I am glad that now, disabled workers are
among them, and it is my hope that there will be no exemption for the
AbilityOne Procurement List (PL), so that these disabled workers too can
rest assured they will not endure discriminatory sub-minimum pay in the
future, that closes doors to opportunity and discourages those who
influence their lives and careers to invest in their potential. This is
what I would want and expect if I were in the same situation, to be
considered for my pay based not on my disability.

I look forward to the future and hope the President and Department of Labor
continue to work for and with stakeholders, including the disabled
community, to advance Americans’ rights, equality, and quality of life.

Sincerely,

Glenn R. Moore III

Treasurer, National Federation of the Blind of Illinois

-Glenn III

On Mon, Jul 21, 2014 at 1:48 PM, Rose Sloan via il-talk <il-talk at nfbnet.org>
wrote:

> 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 visit www.nfb.org/ImaginingOurFuture.
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