HomeMy WebLinkAbout12-16-22 CalPERS Board of Directors - Limited Duration
December 16, 2022
CalPERS Board of Directors
Pension & Health Benefits Committee
400 Q Street
Sacramento, CA 95811
VIA E-Mail: Regulation_Coordinator@calpers.ca.gov
Re: Proposed Regulation for the Definition of Limited Duration Employment
Dear CalPERS Board of Directors,
The City of San Luis Obispo would like to share our concerns with the proposed regulation
of the definition of “limited duration employment”. The proposed language is overly restrictive
and may prevent the City from being able to perform essential services to our community.
The proposed regulation would define “limited duration” as a limit of 24 consecutive months
per appointment for retired persons serving after retirement, with an option of two extensions
of 12 consecutive months per extension. The City of San Luis Obispo understands the
intentions of the proposed regulations but given the current hiring environment finds that
they are overly restrictive, and the City would be better served by more flexibility.
The City of San Luis Obispo is located in a geographically isolated area and as a result has
a limited local labor pool. The proposed new regulations will negatively impact the City.
Given the current labor market nationwide, it is already difficult to recruit qualified candidates
for many positions. That challenge is even greater when it comes to recruiting for individuals
with specialized skillsets such as planners, engineers, information technology professionals,
and specialty positions such as transit managers.
Further exacerbating the ability to recruit quality candidates are changes to CalPERS
retirement system brought about by the PEPRA retirement tier. These changes, while
necessary, have already put the City at a competitive disadvantage to the private sector as
the City can no longer point to the retirement benefits as a reason to leave higher pay in the
private sector for the public sector. Allowing the City to hire retirees as limited-duration
employees gives the City access to high-quality employees for short periods of time to fill
gaps in the local labor pool, to accomplish knowledge transfer and new staff developm ent,
and to continue providing services to the community.
The City uses limited-term positions prudently to meet the needs of the City, but due to
recruitment, retention and training needs, sometimes that results in individuals with
specialized skills working for more than a few years in a limited -term capacity, or being
needed during successive staff transitions. The City and its residents who rely on the
Re: Proposed Regulation for the Definition of Limited Duration Employment
quality and consistency of its services are best served by flexibility at the local level to
make these decisions about when to hire a limited-term position. One-size fits all rules at
the state level cannot easily accommodate the volatile, fluid and evolving nature of labor
markets like we are now experiencing and cannot accommodate rapidly evolving and
unique changes in the day-to-day operational needs of most cities.
The City urges CalPERS not to adopt these proposed regualtions and continue to allow
local hiring decisions to be made at the local level, where decisions can be informed by the
unique needs of a particular city and can accommodate evolving local labor market
flucutations.
Sincerely,
Erica A. Stewart
Mayor
City of San Luis Obispo
c: Senator John Laird, Email: Senator.Laird@senate.ca.gov
Assemblymember Dawn Addis, via Legislative Director Julie.Cravotto@asm.ca.gov
Johnnie Pina, League of California Cities, jpina@cacities.org
League of California Cities, Email: cityletters@calcities.org