formal comments to the Board's proposed rule. - SEIU
formal comments to the Board's proposed rule. - SEIU
formal comments to the Board's proposed rule. - SEIU
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day, more than 80 times <strong>the</strong> number of USPS letters.’°<br />
email.<br />
2 Today, nearly all working age adults use<br />
103 As of 2007, 85% of adults reported owning a cell phone while only 71% of adults reported<br />
owning a home phone.’°<br />
4 These trends are but a few signs that <strong>the</strong> ability <strong>to</strong> transmit and receive<br />
information more cheaply and more efficiently over <strong>the</strong> phone and via email has drastically changed <strong>the</strong><br />
way Americans communicate.<br />
Indeed, even where an employer is not deliberately trying <strong>to</strong> sabotage <strong>the</strong> union’s ability <strong>to</strong><br />
communicate with workers, a mailing address is rarely <strong>the</strong> best way <strong>to</strong> reach workers. In particular,<br />
when <strong>SEIU</strong> locals have organized younger, low-wage workers, we have often found that because <strong>the</strong>se<br />
workers move around so much, <strong>the</strong>y often will use as a mailing address <strong>the</strong> address of a more stable<br />
relative. Thus, organizers have often knocked on doors only <strong>to</strong> learn that <strong>the</strong> address <strong>the</strong>y have for a<br />
worker is actually <strong>the</strong> address of <strong>the</strong> worker’s mo<strong>the</strong>r, aunt, or grandmo<strong>the</strong>r.<br />
In addition <strong>to</strong> technological changes, <strong>the</strong> <strong>proposed</strong> <strong>rule</strong> also takes in<strong>to</strong> account o<strong>the</strong>r ways <strong>the</strong><br />
country has changed in <strong>the</strong> last half-century. Over <strong>the</strong> past half-century, urban sprawl and commuting<br />
distances have both increased. In major urban centers, it is not unusual for workers <strong>to</strong> commute more<br />
than one hour in each direction. Thus, a typical hospital worker in Los Angeles might have <strong>to</strong> drive two<br />
hours in one direction in order <strong>to</strong> make a home visit <strong>to</strong> a co-worker. Also, as wages have stagnated,<br />
workers have often responded by working longer hours. The result is that workers are rarely home <strong>to</strong><br />
receive house calls. In addition, in <strong>the</strong> 1960s, many households consisted of a husband who worked and<br />
a wife who was responsible for childcare and homemaking. This arrangement left <strong>the</strong> working husband<br />
available <strong>to</strong> engage in extended conversations when a union organizer knocked on <strong>the</strong> door. Today,<br />
given <strong>the</strong> large participation of women in <strong>the</strong> workforce, particularly those with young children, both<br />
spouses typically work and share child-care duties. This means that even if a union organizer happens <strong>to</strong><br />
find a worker at home, she is typically cooking dinner and helping her child with homework, making it<br />
impractical <strong>to</strong> engage in an extended conversation about unionization.<br />
The Board should also clarify that <strong>the</strong> <strong>proposed</strong> <strong>rule</strong>s would apply <strong>to</strong> all employee phone<br />
numbers and email addresses available <strong>to</strong> employers, both work and personal. Although in some cases<br />
employers may not have access <strong>to</strong> cell phone numbers or personal email addresses, when <strong>the</strong>y do,<br />
similar access should be given <strong>to</strong> <strong>the</strong> union as well. An employee who communicates with a union over<br />
a work email address may be reluctant <strong>to</strong> speak honestly due <strong>to</strong> <strong>the</strong> understandable fear that <strong>the</strong><br />
employer can moni<strong>to</strong>r what is being said. Therefore, if personal emails are available <strong>to</strong> <strong>the</strong> employer,<br />
101 See “Projecting U.S. Mail Volumes <strong>to</strong> 2020,” at 2, www.usps.com/strategicplanningtpdf/BCG Narrative.pdf (“The U.S.<br />
Postal Service will experience profound declines in its volumes of mail. .<br />
. over<br />
<strong>the</strong> next decade... [T}he trajec<strong>to</strong>ry for <strong>the</strong><br />
next 10 years is one of steady decline, which will not reverse even as <strong>the</strong> current recession abates.”).<br />
102 “Email v. Snail Mail,” Pingdom blog, http://royal.pingdoin.com/2010/09/29/email-vs-snail-mail-infbgraphic..<br />
103 Pew Internet and American Life Project, Generations 2010, at pewinternet.orgiReports/2Ol0iGeneraiioiis-2010.aspx.<br />
‘° Harris Interactive, A Study about Cell Phone Usage, 2007.<br />
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