Caltrans Chief Deputy Director Cindy McKim says in a declaration filed in Alameda Superior Court that if the department is forced to end furloughs and repay lost wages, it "would be required to immediately, and drastically reduce expenditures," including layoffs.
McKim's four-page statement, filed Mar. 12, is part of the documentation compiled ahead of Wednesday's hearing before Judge Frank Roesch. Lawyers at the hearing will debate whether to lift the automatic stay triggered by Gov. Arnold Schwarzenegger's appeal of the judge's order to end furloughs and issue back pay to tens of thousands of state workers.
Based on McKim's declaration, the governor's side is framing Roesch's choices as letting the furlough status quo continue for a few more months (even though the judge has ruled that the policy is illegal) or ending furloughs and sending state workers to the unemployment line.
Click the following link for more details about McKim's declaration and a link to the court file.
After laying out some payroll numbers, McKim says, "In the event that the Department of Transportation was required, as of this date, to cease the implementation of three furlough days per month for all employees, the Department of Transportation's financial expenditures would exceed its available funds."
Bottom line, according to McKim:
The payment of backpay will exhaust all amounts allocated for employee compensation; accordingly DOT will run out of money for the payment of salary prior to the end of the fiscal year. In order to make a recovery from the impact, the Department's long term plan would be to reduce expenditures by slowing down project delivery which would result in eliminating staff, possibly through a layoff.
Click here to download McKim's declaration.
Hat tip to blog user J for flagging this document.