EAP Pre-Draft Proposed Rule Language (Second Version)

(Submitted on 11/26/18 by Phil Costello, Zip's Drive In)

My name is Phil Costello. I own/operate a Zip's Drive In and am proud to employ 25 people in Spokane.

If these rules were adopted as currently proposed, I would be forced to raise my prices even more than I already will because of the increases in minimum wages over the next two years. We are already at a major disadvantage with the large players in our segment, i.e. McDonalds, Wendy's, Burger King etc. who can afford through their purchasing power to run value menu deals and draw consumers to their much lower menu prices.


My manager is already at the bottom of this threshold and has health insurance, and a bonus plan based on her performance every year. Any increases to our labor have to be paid for by eliminating these types of opportunities.

Thank you for the opportunity to submit comments on behalf of the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act including the update of overtime exemptions and the salary threshold.

We understand that an update on this topic is appropriate; however, I would like to raise several concerns with elements of the updated pre-draft proposal. My first concern is about the future of the hospitality industry and its career ladder.

As a business operator, I am proud to be able to invest in my employees, see them gain valuable skills and transfer them into leadership opportunities as they advance their careers. I am concerned that tying the salary overtime threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the minimum wage will discourage my ability to provide more upward career growth opportunities. Adopting any multiplier of the minimum wage would create a wage gap between my employees and management. Undercutting and harming my employees by removal of the middle-management career ladder rungs would not benefit them, my business or the state economy.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules will grow the urban/rural wage gap even further and grow the wage gap among industries.

I am asking Labor and Industries to wait for the federal government to update their rules before moving forward with this process. We need alignment at the local, state and federal levels of government.

I appreciate the opportunity to be a part of the solution and submit my comments to you.

(Submitted on 11/26/18 by Michael McQuay)

My name is Michael McQuay. I own/operate 2 restaurants in Port Angeles and employ 60 people.

If these rules were adopted as currently proposed, I would I would have to eliminate my first tier management positions. We use these positions to teach and groom future leaders. This woul not only put an undue burden on our company, but would also make it more difficult to bring people up in the ranks.

Thank you for the opportunity to submit comments on behalf of the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act including the update of overtime exemptions and the salary threshold.

We understand that an update on this topic is appropriate; however, I would like to raise several concerns with elements of the updated pre-draft proposal. My first concern is about the future of the hospitality industry and its career ladder.

As a business operator, I am proud to be able to invest in my employees, see them gain valuable skills and transfer them into leadership opportunities as they advance their careers. I am concerned that tying the salary overtime threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the minimum wage will discourage my ability to provide more upward career growth opportunities. Adopting any multiplier of the minimum wage would create a wage gap between my employees and management. Undercutting and harming my employees by removal of the middle-management career ladder rungs would not benefit them, my business or the state economy.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules will grow the urban/rural wage gap even further and grow the wage gap among industries.

I am asking Labor and Industries to wait for the federal government to update their rules before moving forward with this process. We need alignment at the local, state and federal levels of government.

I appreciate the opportunity to be a part of the solution and submit my comments to you.

(Submitted on 11/26/18 by Ami Grubbs, Talarico’s)

My name is ami I own/operate Talarico’s and am proud to employ 42 people in Seattle .

If these rules were adopted i would not be able to employ as many individuals. I would have to restructure our business model by eliminating entry level positions, so we can afford to pay higher salaries. I’m saddened that early high school and college students are not getting the opportunities to work in the current workforce.

As a business operator in our state I wanted to ensure my voice is heard in the rulemaking process for the Executive, Administrative and Professional exemptions from the Minimum Wage Act, including overtime exemptions and an update of the salary threshold. As a member of Washington’s hospitality industry, I am particularly interested in preserving my ability to provide my employees with opportunities to advance their careers.

As written, the pre-draft rules propose to tie the minimum wage to the salary threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the state minimum wage. Adopting a salary threshold tied to any multiplier of the minimum wage would erase those mid-career management positions that are critical to climbing the hospitality career ladder. Removal of the mid-career positions and leaving all managerial positions to upper management would undercut the workforce in an already tough labor market.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I am proud to serve my community and provide all levels of jobs for my employees. I ask Labor and Industries to consider the overall economic impact and harm these updated pre-draft rules could have on our state’s economy. The hospitality industry is not the only sector that may have to drastically shift because of the outcome of these rules.

Thank you for the opportunity to be engaged with this process through the submission of my comments.

(Submitted on 11/26/18 by David Magee, Hawks Prairie Casino)

My name is David Magee. I operate the Hawks Prairie Casino and am proud to employ 130 people in Lacey.

If these rules were adopted as currently proposed, I would need to change some managers status to hourly and lower what they are currently making to allow for them to work extra hours during the rare times that we have vacations to cover or have a special project to complete. I would also require them to use vacation pay for all days off instead of giving them extra days off to make up for any extra hours worked in a particular week.

Thank you for the opportunity to submit comments on behalf of the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act including the update of overtime exemptions and the salary threshold.

We understand that an update on this topic is appropriate; however, I would like to raise several concerns with elements of the updated pre-draft proposal. My first concern is about the future of the hospitality industry and its career ladder.

As a business operator, I am proud to be able to invest in my employees, see them gain valuable skills and transfer them into leadership opportunities as they advance their careers. I am concerned that tying the salary overtime threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the minimum wage will discourage my ability to provide more upward career growth opportunities. Adopting any multiplier of the minimum wage would create a wage gap between my employees and management. Undercutting and harming my employees by removal of the middle-management career ladder rungs would not benefit them, my business or the state economy.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules will grow the urban/rural wage gap even further and grow the wage gap among industries.

I am asking Labor and Industries to wait for the federal government to update their rules before moving forward with this process. We need alignment at the local, state and federal levels of government.

I appreciate the opportunity to be a part of the solution and submit my comments to you.

(Submitted on 11/26/18 by Barry Galen, CCR)

My name is Barry Galen. I own/operate CCR and am proud to employ 58 people in Snohomish Washington.

If these rules were adopted as currently proposed, I would have to stop offering salary positions in my business.

As a business operator in our state I wanted to ensure my voice is heard in the rulemaking process for the Executive, Administrative and Professional exemptions from the Minimum Wage Act, including overtime exemptions and an update of the salary threshold. As a member of Washington’s hospitality industry, I am particularly interested in preserving my ability to provide my employees with opportunities to advance their careers.

As written, the pre-draft rules propose to tie the minimum wage to the salary threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the state minimum wage. Adopting a salary threshold tied to any multiplier of the minimum wage would erase those mid-career management positions that are critical to climbing the hospitality career ladder. Removal of the mid-career positions and leaving all managerial positions to upper management would undercut the workforce in an already tough labor market.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I am proud to serve my community and provide all levels of jobs for my employees. I ask Labor and Industries to consider the overall economic impact and harm these updated pre-draft rules could have on our state’s economy. The hospitality industry is not the only sector that may have to drastically shift because of the outcome of these rules.

Thank you for the opportunity to be engaged with this process through the submission of my comments.

(Submitted on 11/26/18 by Mike McKinnon)

My name is Mike McKinnon. I own/operate 6 restaurants and am proud to employ 300 people in Thurston County.

If these rules were adopted as currently proposed, I would have to look at my entire benefit and pay structure related to restaurant management. While it's rare for me to have managers go into large amounts of overtime, I also don't penalize my staff if they're unable to work their 40 hr work week. It's a give and take that's worked well for my company for 30+ years.

Thank you for the opportunity to submit comments on behalf of the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act including the update of overtime exemptions and the salary threshold.

We understand that an update on this topic is appropriate; however, I would like to raise several concerns with elements of the updated pre-draft proposal. My first concern is about the future of the hospitality industry and its career ladder.

As a business operator, I am proud to be able to invest in my employees, see them gain valuable skills and transfer them into leadership opportunities as they advance their careers. I am concerned that tying the salary overtime threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the minimum wage will discourage my ability to provide more upward career growth opportunities. Adopting any multiplier of the minimum wage would create a wage gap between my employees and management. Undercutting and harming my employees by removal of the middle-management career ladder rungs would not benefit them, my business or the state economy.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules will grow the urban/rural wage gap even further and grow the wage gap among industries.

I am asking Labor and Industries to wait for the federal government to update their rules before moving forward with this process. We need alignment at the local, state and federal levels of government.

I appreciate the opportunity to be a part of the solution and submit my comments to you.

(Submitted on 11/26/18 by David Vitt, Kulshan Brewing Company)

My name is David Vitt and I started Kulshan Brewing Company in Bellingham. We have 2 taprooms here in Bellingham and we distribute cans and bottles throughout the western part of the state. We employ about 40 people, 4 of whom are exempt managers. I can proudly say that the annual salary for these folks is well above comparable salaries for similar positions in our industry. I also have these employees clock in so that I know how many hours they work and their hours per week are almost always below 40 hours. Of course, there are occasionally times when they attend a conference or beer festival over the weekend and are essentially working a little extra, but I'm confident that they do not feel like they've ever been taken advantage of, especially considering the fact that their schedule can be much more highly flexible on a daily basis. There is a lot of value for employees like this to work from home, take few hours off to attend a child's school event or care for an ill family member without cutting into their PTO. As a company we offer full benefits and ample PTO to cover vacations as well as sick time.

If these rules were adopted as currently proposed, I would be forced to put these employees on an hourly wage which would certainly offer them less overall dollars through the year as well as less flexibility. I would also be forced to extremely limit continuing education, industry conferences, Brewers Association events, Hop purchasing in Yakima, beer festivals, the list goes on. I can say confidently that my employees find these activities valuable to their career and they appreciate the ability to do them.

As a business operator in our state I wanted to ensure my voice is heard in the rulemaking process for the Executive, Administrative and Professional exemptions from the Minimum Wage Act, including overtime exemptions and an update of the salary threshold. As a member of Washington’s hospitality industry, I am particularly interested in preserving my ability to provide my employees with opportunities to advance their careers.

As written, the pre-draft rules propose to tie the minimum wage to the salary threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the state minimum wage. Adopting a salary threshold tied to any multiplier of the minimum wage would erase those mid-career management positions that are critical to climbing the hospitality career ladder. Removal of the mid-career positions and leaving all managerial positions to upper management would undercut the workforce in an already tough labor market.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I am proud to serve my community and provide all levels of jobs for my employees. I ask Labor and Industries to consider the overall economic impact and harm these updated pre-draft rules could have on our state’s economy. The hospitality industry is not the only sector that may have to drastically shift because of the outcome of these rules.

Thank you for the opportunity to be engaged with this process through the submission of my comments.

(Submitted on 11/26/18 by Paul Sandhu, Holiday Inn Hotel Tacoma WA)

My name is Paul Sandhu. I own/operate Holiday Inn Hotel Tacoma WA and am proud to employ 45 people in Tacoma WA.

If these rules were adopted, It would be hurtful to middle managers and our business and we'd have to Increase thd cost of lodging for our customers to offset but customers already complain that hotel rents are high.

I appreciate the opportunity to express my thoughts on the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act, including the update of overtime exemptions and the salary threshold.

I am a hospitality industry operator who is proud to provide jobs at all levels to people in my community. The hospitality industry is an industry of opportunity that offers everything from first-time jobs to lifelong careers. I want to continue to invest in my employees and provide them with opportunities to advance their careers in hospitality or elsewhere.

I am very concerned about tying the salary overtime threshold to a range of 2 – 2.5 times the minimum wage or a salary of $49,920 - $62,400 and adjusted annually. Adopting a salary threshold tied to any multiplier of the state minimum wage will create a wage gap between my employees and management and will ultimately harm jobs by eliminating middle-management positions.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I ask Labor and Industries to align any proposed changes to these exemptions with federal rules. As a business operator, we need alignment at the local, state and federal levels of government to help reduce confusion.

I am a proud member of my community and want to continue to provide jobs for employees at all levels, including middle-management positions. I ask for Labor and Industries to consider the impact of these pre-draft rules on the hospitality careers and our community and economy.

(Submitted on 11/26/18 by Bryon Hammock, Rainier Golf and Country Club)

My name is Bryon Hammock, I operate Rainier Golf and Country Club and am proud to employ in peak season 104 people in the hospitality field.

If these rules were adopted, it would be compiled to the escalating wage increases by state and cities creating more of a burden to employ the amount of people it takes for my industry. Just last year, I was forced to reduce expenses that equated in terminating two full time positions, good people and we all know... good people are hard to find. The social aspect of these changes IS changing the workforce. The expectations of the unskilled people looking for "top" dollar has created a labor pool that businesses cannot even hire from.

But back to the salary issue. When a person moves from hourly to salary, they should be smart enough to perform the math, if its going to work for them or not. To pay additional OT to a salary individual is taking away the last piece of wage incentive a business has and now creating lazy or expectations of managers much like the hourly labor pool.

I think the state is over stepping its authority and creating its own "union style" wage and labor force to increase wages, that in turn increases taxes, that increases governmental spending.

I appreciate the opportunity to express my thoughts on the updated pre-draft rules for the Executive, Administrative and Professional exemptions from the state Minimum Wage Act, including the update of overtime exemptions and the salary threshold.

I am a hospitality industry operator who is proud to provide jobs at all levels to people in my community. The hospitality industry is an industry of opportunity that offers everything from first-time jobs to lifelong careers. I want to continue to invest in my employees and provide them with opportunities to advance their careers in hospitality or elsewhere.

I am very concerned about tying the salary overtime threshold to a range of 2 – 2.5 times the minimum wage or a salary of $49,920 - $62,400 and adjusted annually. Adopting a salary threshold tied to any multiplier of the state minimum wage will create a wage gap between my employees and management and will ultimately harm jobs by eliminating middle-management positions.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I ask Labor and Industries to align any proposed changes to these exemptions with federal rules. As a business operator, we need alignment at the local, state and federal levels of government to help reduce confusion.

I am a proud member of my community and want to continue to provide jobs for employees at all levels, including middle-management positions. I ask for Labor and Industries to consider the impact of these pre-draft rules on the hospitality careers and our community and economy.

Submitted on 11/26/18 by Chris Siemens, Mustard Seed and Noodle Express Restaurant Group)

Dear Washington State Dept. of Labor & Industries,

My name is Chris Siemens. I own/operate the Mustard Seed and Noodle Express Restaurant Group and am proud to employ over 150 people in Washington State.

If these rules were adopted as currently proposed, I would expect to see challenges within the Hospitality Industry due to these rule changes creating a negative impact to the young up and coming leaders. The restaurant industry in particular, is one key area where young people gain their early entry into management roles. These young managers have likely never had much opportunity to enter the ranks of leadership, and we (restaurant industry) becomes a key grooming and early learning situation. As these positions don't afford for base salaries being over $40,000 to 45,000 per year, but come with Medical/Dental benefits and many other professional level improvements, your proposed changes occur would force us to implement an hourly recording for these position. This would dramatically diminish the professional appearance and moral for these positions, and thereby hurt these young future leaders from seeing this as a good position to seek. So, I would ask you to refrain from making these proposed changes.

As a business operator in our state I wanted to ensure my voice is heard in the rulemaking process for the Executive, Administrative and Professional exemptions from the Minimum Wage Act, including overtime exemptions and an update of the salary threshold. As a member of Washington’s hospitality industry, I am particularly interested in preserving my ability to provide my employees with opportunities to advance their careers.

As written, the pre-draft rules propose to tie the minimum wage to the salary threshold to a range of $49,920 - $62,400 adjusted annually or 2 – 2.5 times the state minimum wage. Adopting a salary threshold tied to any multiplier of the minimum wage would erase those mid-career management positions that are critical to climbing the hospitality career ladder. Removal of the mid-career positions and leaving all managerial positions to upper management would undercut the workforce in an already tough labor market.

Additionally, I oppose any type of phase-in period because the result would still be the same with the salary threshold tied to a multiplier of the minimum wage. These pre-draft rules would grow the urban/rural wage gap even further and grow the wage gap among industries.

I am proud to serve my community and provide all levels of jobs for my employees. I ask Labor and Industries to consider the overall economic impact and harm these updated pre-draft rules could have on our state’s economy. The hospitality industry is not the only sector that may have to drastically shift because of the outcome of these rules.

Thank you for the opportunity to be engaged with this process through the submission of my comments.

(Submitted on 11/25/18 by Devin Mettler, The Summit at Snoqualmie)

Thank you for asking for input.

My department employs approximately 750 seasonal employees and managers.

I foresee the following challenges with the suggested timeline.

1. We are currently engaged in adapting our business model to the changes in WA minimum wage. On Jan 1, 2020 minimum wage increases from $12/hr to $13.50/hr. That is a 12.5% increase in our base wages on the same day this proposal is slated to take effect, this will create an undue hardship for employers.

I suggest a phased in approach that differentiates employers with a significant portion of hourly minimum wage workers from those employers with predominantly salary based employees.

For example: 75% salary and 25% hourly should switch first. 75% hourly and 25% salary should switch within the next 2 years.

This, or something like this, would allow employers time to adjust to the changes without creating a significant hardship all on Jan 1 2020.

2. 2.5 times the minimum wage will be $70,200!! This is a ridiculously high amount of money and will end up costing people their employment status. I know my department will not be able to maintain this level of pay for our 6 salaried managers. It’s half of our labor budget. The only possible course of action for employers like my company will be to change these employees back to hourly basis which will greatly impact their ability to effectively do their jobs.

This suggestion needs to be reconsidered with the input of people who actually have employees and a labor budget.

The bottom line is that as a business operator the costs all of these wage increases is passed directly on to our customers in the form of massive price increases. If this were backed by increased productivity and quality, then that would make sense. However, because of these wage increases we are being forced to charge more and give the same. This is a poor value proposition and is detrimental to our customers.

Thanks again for asking for input. I hope you are able to come up with a phased in plan that takes into account local businesses and the impact that these decisions will have on their ability to operate.

(Submitted on 11/4/18 by Kristy Neubo)

Hi- It is very difficult for us as an employer of 3 with no HR department to follow all of these new rules and make sure that we do implement and follow them. If an employer has less than 10 employees, it should not be burdened with the hours and hours it takes to follow all of Washington's over-bearing labor laws. Raise minimum wage, and we can just pay people at least that. we have an internal minimum wage of no less than $12.00 an hour and we pay our people between $13-$21 an hour, so we try and be fair to people, and that is why they stay with us. To burden us with yet more rules, is unfair. We are older and I am in poorer health, so we are trying to sell our apartments as it is just too much with all of these new rules to keep up with them and insure that we are compliant. So a big corporation will likely buy our property, as they can keep up, where a mom and pop like us, are forced out- once again.

(Submitted on 11/21/18 by Krysten Mooney, CAI)

The small company I work for would have a tough time in the market. Increasing the minimum amount for exempt employees will cause extreme hardship to our organization. In 2019, the minimum wage is going up to 13.50 an hour, if the rate is 2.5 times that equals $70,200 and we would probably not have any employees as exempt. Let alone let our business grow or have potential to hire new employees.

(Submitted on 11/21/18 by Maureen McMillin, Corwin Health Physics

We are a small business (9 employees), of which the majority are exempt employees (professional, one executive, one administrative). Under the proposed salary threshold, a few of our employees would fall below the minimum wage. It would pose an undue hardship on our company to raise their wages to meet the threshold, because, as I said, we are a very small, local business.

My initial feedback would be to consider a lower minimum wage threshold. I feel that 1.5 times the minimum wage is reasonable.

Response to question 1:
Yes, a phased-in approach would be helpful for small businesses.
b) 2022?

Response to question 2:
NO. I think that companies in higher wage areas should have the freedom to set their own wage minimums, which will be regulated by supply and demand of desired employees.

(Submitted on 11/21/18 by Lorena Pulido, North Central Educational Service District)

My feedback is in regards to exempt employees. I think it’s important to review job duties for different positions because myself for example, I am listed as an exempt employee because I am classified as software support, however my job duties include much more. I have to create guides/job aides and documents, provide in person training to school districts on human resources and finance rules/regulations in addition to showing districts how to implement those legislative changes into a software. The main reason why I work overtime, is because I am preparing for a training or working on related duties that are not specific to software support. I think the intent with having exempt employees is that it would fall within the scope of having to work extra hours to complete a job that is not quantifiable by a set number of hours, whereas employers don’t always know or understand the intent behind specific rules, so they interpret them based on what is most cost effective to their business. I would like to see a test of what is listed as an exempt employee (much like the contractor/independent contractor test) and if any question is not passed, then the employee is not an exempt employee.

This ruling would adversely affect our small county. We have a Mental Health Emergency Treatment Center and a Counseling Center. Most of the professionals are exempt based on $48,000. This proposal would disallow 99% of our employees of becoming exempt. The cost of overtime would be a tremendous burden on citizens and would cause us to cut much needed staff in the mental health field.

I feel this should not become in effect. As Salaried workers are able to adjust there hours instead of receiving over-time. With all the new payroll increases for minimum wage, sick leave and family medical leave, employers are going out of business or struggling. I feel this should be based off how many employees they have not by location.

Your new labor laws are KILLING small businesses. I understand the reasons for all the new rules in a perfect world but as a small business owner, I can't compete under the labor laws you keep adding and adding. The new overtime law needs to exempt business with less than 25 employees. We have already added sick leave, and paid time off, when is it enough? Small businesses are the life blood of the small communities. Some of the "rule writers" need to work for a year making payroll each and every week before they can write these new laws.

I represent a rural, nonprofit child development organization. Non-profits in general, especially those in early learning operate on limited and/or stagnate funding. The majority of us go into the work because we have a helping heart, passion to serve others, and passion for our communities. These positions typically pay lower than comparable positions in the private sector and are often salaried. When working with people, we have to be able to respond to meet needs - that's typically not a 9-5 job. Our organization has worked hard over the course of the last two years to move the majority of employees to non-exempt. The follows our culture of balance and ensures employees have a better work/life balance. That being said, we have higher level managers that will be impacted by this pending rulemaking - all of our staff will become non-exempt. This is significant because while we work towards a work/home balance, these are the employees that may work more extensive hours during a specific period of time, for example annual grant writing. Our budget has no cushion to provide for overtime or additional staff, yet this is a necessary task to ensure we have funding available to meet the needs of children and families in our communities. I noted on the second pre-draft a request for feedback for a higher threshold for larger communities/areas. But, what about a lower threshold for rural communities. Rural communities, especially in Eastern Washington have a much lower median wage. For 2017, Washington State was at $68,550, King County $89,142, Spokane County $53,809, and Okanogan County $44,250. There is a significant difference between larger areas, and those of us in smaller communities in Eastern Washington, like Okanogan County. I recognize we are seeing wage increases based upon minimum wage increases, but we will still see the median wage discrepancy between areas of our state. In addition, employers in our rural communities are still struggling to budget for continued mandated minimum wage increases - this is already causing compressed wage scales in many of our organizations. Bottom line, this rulemaking has the potential to put non-profits out of business or require them to serve less folks for more money, which doesn't make sense. While I don't disagree that the exemption rules need another look, it makes much more sense at this point to save time and money to see what the Feds are doing first. Then take a realistic view of what this looks like in our state keeping in mind various types, sizes, and locations of businesses and organizations. If this must be prioritized now, I encourage you to look towards a lower Threshold rate of 1.5% or less.

I represent a church where we have only about 10 employees. Each of us knew when we took our jobs that we were choosing to work for a church (non-profit) where the pay may not be as high but we chose to take our jobs because we believe in what this church is doing in its community. We value our employees and as such having qualified employees be paid a salary gives them flexibility of hours. The church also provides their health care benefits. If the threshold goes up that high we will be forced to take away the flexibility of hours as well as we may not be able to provide 100% of our employee’s health care benefits. This will hurt the employees that you claim to be helping. I believe that this proposal will close many doors of small businesses especially those of non-profits putting employees out of work and ultimately hurting the communities in which they are located.