HomeMy WebLinkAboutSweeney 97-05-15IN THE MATTER OF AN ARBITRATION
BETWEEN:
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(FOR ACADEMIC EMPLOYEES)
(the "Union")
-
AND –
MOHAWK COLLEGE OF APPLIED ARTS
AND TECHNOLOGY
(the "College")
AND IN THE MATTER OF THE GRIEVANCES OF MICHAEL SWEENEY
(OPSEU FILE NOS. 96C782 & 96C783)
BOARD OF ARBITRATION Robert D. Howe, Chair
Michael Sullivan, Union
Nominee
Jacqueline Campbell, College
Nominee
APPEARANCES
For the Union Michael McFadden, Counsel
Fred Deys
Michael Sweeney
For the College Patricia G. Murray, Counsel
Steve Evans
Kathy Verspagen
Nicole Wharton
Hearings in the above matter were held on December 3, 1996,
and on April 22 and 29, 1997, in Hamilton, Ontario.
A W A R D
Two related grievances filed by the grievor, Michael
Sweeney, on March 14, 1996 have been referred to this Board of
Arbitration (the "Board") for determination in these proceedings. The
statement of grievance in the first one reads:
I GRIEVE THAT I HAVE BEEN IMPROPERLY LAID OFF, IN VIOLATION OF THE
COLLECTIVE AGREEMENT, SPECIFICALLY BUT NOT EXCLUSIVELY ARTICLES #6, 27
AND 29. THERE ARE POSITIONS IN THE COLLEGE OCCUPIED BY EMPLOYEES WITH
LESS SENIORITY WHICH I HAVE THE COMPETENCE, SKILL AND EXPERIENCE TO
FILL. FOR EXAMPLE THERE IS A POSITION OCCUPIED BY WALTER DRAKE IN
MOTIVE POWER AND SEVERAL OTHER POSITIONS OCCUPIED BY EMPLOYEES WITH
LESS SENIORITY. IN IMT\MECHANICAL THERE ARE THE POSITIONS OCCUPIED BY
BARRY WILSON AND OTHER EMPLOYEES WITH LESS SENIORITY. IN COUNSELLING
THERE ARE THE POSITIONS OCCUPIED BY IAYNN MILLER, AND EMPLOYEES WITH
LESS SENIORITY. THERE ARE ALSO POSITIONS IN INTERNATIONAL PROJECTS
OCCUPIED BY PETER YOUNG AND OTHER EMPLOYEES WITH LESS SENIORITY.
The statement of grievance in Mr. Sweeney's second
grievance reads:
I GRIEVE FURTHER THAT THE COLLEGE HAS, IN VIOLATION OF THE COLLECTIVE
AGREEMENT, SPECIFICALLY BUT NOT EXCLUSIVELY ARTICLES 6, 27, 28, AND
29, AND THE CLASS DEFINITION SECTION, INAPPROPRIATELY AND FALSELY
CLAIMED THAT MY WORKLOAD HAS CHANGED AND MY POSITION DISAPPEARED.
The relief requested in both grievances is:
The parties agreed to proceed with the second grievance
first, because the essence of that grievance is that the grievor
should not have been given a lay-off notice, and the first grievance
(alleging a violation of bumping rights) only becomes relevant if the
College was entitled to give the grievor that notice.
Three persons were called as witnesses during the three
days devoted to hearing that grievance: Michael Sweeney, the
aforementioned grievor; Sharon Stanshall, a Co-op Consultant (included
in the support staff bargaining unit); and Kathy Verspagen, the
College's Director of Co-operative Education and Technology Marketing.
In addition to their testimony, the Board has before it 23 exhibits
which were entered during the course of the proceedings. In making
the findings and reaching the conclusions set forth is this award, the
Board has duly considered all of that oral and documentary evidence,
as well as the able submissions of counsel.
The College's Co-operative Education Department operates a
variety of programs in a co-operative education mode, in conjunction
with other departments of the College. The following introductory
passages are included in the Co-operative Education portion of the
General Information section of the College's most recent calendar:
Co-operative Education extends the academic learning process into the
workplace through on-the-job learning experiences that are integrated
with the learning objectives of the program of studies.
The Co-operative Education Department, in conjunction with
other faculty and departments, is responsible for:
- Providing opportunities for paid, supervised
off-campus work semesters in co-operating business,
industry or government agencies.
- Providing comprehensive career development services
for co-operative education students within the
academic curriculum.
- Enhancing the potential for graduate employment
through occupational socialization and career
development in jobs commensurate with student
aspirations and training.
The grievor commenced employment with the College in April
of 1981 as a Co-operative Education Co-ordinator, which is a position
included in the academic bargaining unit. (The position of Co-
operative Education Co-ordinator will also be referred to as "Co-
ordinator" in this award, for ease of exposition). In that capacity,
he was initially responsible for the College's Industrial Mechanic and
Fitter/Welder co-op programs. However, by the mid 1980's he had
become the Co-operative Education Co-ordinator for the College's Civil
Engineering Technology, Construction Engineering Technician, and
Transportation Engineering Technology programs, which remain three of
the eighteen College programs currently operating in a co-operative
education mode.
As of September of 1986, the job description for Co-
ordinators read, in part, as follows:
A co-op educator is responsible for academic leadership and for
developing effective learning environments through the delivery of co-
operative education. Functions include:
(a) Consulting with program and course directors and
other members, advisory committees, accrediting
agencies, employers and students in the design,
revision and updating of the academic curriculum
including that of the work semester....
(b) The facilitation of learning including:
* ensuring student awareness of course objectives,
approach and evaluation techniques;
* preparing students to become independent
learners;* providing an appropriate learning
environment in
the form of work semesters in business, industry
and government to meet the needs and
qualifications of the students.
* teaching as assigned;
* evaluating student progress/achievement and
assuming responsibility for the overall
assessment of student co-op learning.
(c) Tutoring and academic counselling of students....
(d) The provision of academic leadership including:
* providing guidance to employees and teaching
faculty relative to the co-op experience;
* participating in the work of curriculum and other
consultative committees as requested.
In accordance with that job description, the duties which
the grievor performed in his position as a Co-ordinator included
classroom teaching in co-op preparation classes covering topics such
as resume writing, interviewing techniques, ethics, career goal
setting, and report writing; meeting with students on an individual
basis to provide additional information, clarification, and
counselling; marketing the co-op program to employers to ensure that
there were a sufficient number of paid work term co-op jobs available
for students; evaluating employment environments to determine their
suitability for co-op students; visiting workplaces during the co-op
work terms to provide support and guidance for the students and their
employers; and evaluating the students' work term reports. In
performing those tasks, he spent approximately seventy percent of his
time with students.
During the workplace visits, it was the grievor's practice
to meet first with the students' supervisors to get their perspective
on how the students were doing, and to discuss the students' goals and
objectives. He would then meet with each of the students to go over
their workplace logs and to discuss whether they were satisfied with
their progress, and also to discuss the extent to which their
employers had assisted them in meeting their goals. If the student
was experiencing problems with the placement, the grievor would meet
with the employer with a view to correcting those problems.
The grievor would also meet with employers from time to
time for the purpose of developing new co-op job opportunities for
students. Since the grievor wanted the students to work in an
environment in which they could learn and grow, he considered a number
of factors in determining whether a new job would be suitable,
including the type of student the employer was willing to hire (i.e.,
a first year, second year, or third year student), the nature of the
employer's operations, the type of work the employer intended to have
the student perform, and the extent to which the employer was prepared
to permit student participation.
In addition to the grievor and seven other Co-operative
Education Co-ordinators, the College also employed four Placement
Officers (included in the support staff bargaining unit) in its Co-
operative Education Department. Their duties and responsibilities
included assisting the Co-ordinators with co-op preparation classes,
troubleshooting and facilitating the application and interview
process, providing in-school student and employer support, and
engaging in informal job development activities. When the Co-
ordinators were not on campus (as was often the case due to their
workplace visitation responsibilities), Placement Officers would also
review and analyse information received from employers by telephone or
fax concerning jobs proposed for inclusion in the co-op programs, and
post those that they considered to be suitable so that students could
apply for them.
When the College first became involved in co-operative
education in the early 1980's, there were relatively few co-op
students and co-op education fees were non-existent or very low.
Since the job market was quite strong and there were no external
competitors for co-op jobs (other than the University of Waterloo),
co-op jobs were relatively plentiful. Thus, the main task of the Co-
ordinators was to work with students to convince them of the value of
the co-op experience, to prepare them for the world of work, and to
counsel them before, during, and after their work terms. However, in
the ensuing years the emphasis gradually shifted to co-op "marketing"
as a result of changes that occurred in the social and economic
environment, including the increased number of co-op students, the
relative shortage of co-op jobs, and the strong competition for those
jobs from universities, secondary schools, other community colleges,
and unemployed graduates. Higher co-op fees and the reduced
availability of "summer jobs" also gave rise to greater co-op job
placement expectations on the part of the College's co-op students,
and placed greater pressure on the Co-ordinators to "find" co-op jobs.
Those changes, combined with the economic necessity of
operating the Co-operative Education Department on a more cost
effective basis, prompted the College to develop and implement an
alternate model of operation designed to maintain academic integrity
while providing a more cost-effective sales and marketing component.
Under that new model, the number of Co-ordinators has been reduced
(from eight to four) and the number of support staff has been
increased, with the position of Placement Officer being replaced by
the newly-created position of "Co-op Consultant".
Co-op Consultants are responsible for marketing various
training programs and services available through the Faculty of
Engineering Technology, such as contract training initiatives,
apprenticeship, and unpaid work placement. They are also responsible
for performing the co-op job development marketing functions
previously performed primarily by the Co-ordinators. Co-op
consultants determine whether jobs offered by employers for inclusion
in the program are associated with a program of studies offered by the
College on a co-op basis. Any questions they have in that regard are
referred to academic staff for resolution. Their responsibilities
also include visiting workplaces during the co-op work terms to
provide support and guidance for the students and their employers, and
to promote job development for future co-op placements. The
efficiency of those workplace visitations has been increased by
dividing them among the Co-op Consultants on a geographical basis,
rather than on a program basis as had been the case when they were
performed by the Co-ordinators. In describing the purpose of those
visits, Ms. Stanshall (a Placement Officer who became a Co-op
Consultant under the new model) gave the following testimony:
Basically I'd say it's a P.R. [public relations] visit. I ask a
series of questions to the employer and to the student, and the
ensuing conversation will usually indicate to me the level of
satisfaction the employer has with the student and also how satisfied
the student is with the job.
She also testified that, in terms of her role, she perceives both the
employer and the student to be "customers". If during those visits
any problems surface which the Co-op Consultant feels incapable of
handling, they are referred to the appropriate Co-ordinator or
academic department.
Under that new model, Co-op Consultants continue to
provide the in-school employer support which had previously been
provided by Placement Officers, but no longer provide in-school
student support (such as the counselling and assistance which they had
previously provided to students on an individual basis regarding
matters such as resume writing and job search skills). The reduced
number of Co-ordinators continue to teach co-op preparation classes.
They also provide an increased amount of in-school student support, as
the elimination of their job monitoring functions makes them more
readily available on campus to provide guidance and counselling to
students. Co-ordinators remain responsible for student evaluation.
They perform work term evaluations through a compilation of monitoring
information provided by the employers (who provide an interim and
final evaluation of each student) and the students' work term reports.
The aforementioned work site visits are not given a grade in this
process, and no academic evaluation occurs when the Co-op Coordinators
visit the work site.
The restructuring of the duties and responsibilities of
those positions brought Mohawk College more closely in line with what
was occurring at other colleges in the Ontario community college
system, and made the duties and responsibilities of the positions in
question more reflective of those typically carried out by persons in
similar positions at other colleges. Indeed, it is clear from Ms.
Verspagen's evidence that in carrying out that restructuring, the
College relied upon the arbitral jurisprudence which has been
developed as a result of grievances filed in respect of similar
changes which have occurred at other Ontario community colleges.
In commenting on the disparity which exists between the
current marketing focus of the work place visits and the more academic
focus described in the co-operative education guide prepared in 1993
by the College Co-operative Educators of Ontario (of which the College
is a member), Ms. Verspagen testified, in part, as follows:
She also described the co-op work terms as "an added value work
experience in addition to a full program of studies".
The restructuring described above resulted in the
elimination of four Co-operative Education Co-ordinator positions,
including the position held by the grievor. In determining which Co-
ordinators were to be laid off, the College went strictly by
seniority. Two of the other Co-ordinators who were given notice of
lay-off (Elaine Tuc and Nick Urquhart) had more seniority than the
grievor, who had more seniority than the fourth Co-ordinator who was
given that notice.
It is the Union's position that the assessment and
selection of job opportunities, and the visitation of work sites
during co-op work terms are both inherently academic activities. It
is also the Union's position that the scheme of the Colleges
Collective Bargaining Act (the "Act") is that community college
employees are either engaged in academic activity or anything else,
and that if a job or task is inherently academic it has to be
performed by a member of the academic bargaining unit. In this
regard, he referred the Board to the following provisions of the Act:
1. In this Act and in the Schedules,
"bargaining unit" means the academic staff bargaining unit of
employees or the support staff bargaining unit of employees set out in
Schedules 1 and 2;
"employee" means a person employed by a board of governors of a
college of applied arts and technology in a position or classification
that is within the academic staff bargaining unit or the support
staff bargaining unit set out in Schedules 1 and 2;
SCHEDULE 1
The academic staff bargaining unit includes the employees of
all boards of governors of colleges of applied arts and technology who
are employed as teachers, counsellors or librarians but does not
include,
[The schedule lists ten categories of managerial and other exclusions,
the details of which are not germane to the instant case.]
SCHEDULE 2
The support staff bargaining unit includes the employees of
all boards of governors of colleges of applied arts and technology
employed in positions or classifications in the office, clerical,
technical, health care, maintenance, building service, shipping,
transportation, cafeteria and nursery staff but does not include,
[The schedule lists eleven categories of managerial and other
exclusions, the details of which are not germane to the instant case.]
In commenting on those provisions, counsel for the Union
also drew our attention to an unreported Ontario Labour Relations
Board decision dated September 19, 1984 (File No. 1668-83-M) between
the Union and Fanshawe College, in which the O.L.R.B. wrote, in part,
as follows regarding a Co-op Liaison Officer:
1. This is an application under section 81 of the Colleges
Collective Bargaining Act (hereinafter referred to as the Act) for a
determination of the employment status of Mr. D. Blay who is
classified as a Co-op Liaison Officer.
5. The Board has adopted a two-stage approach in determining a
person's status under the Act. The first step involves determining in
which bargaining unit the person should be placed if found to be an
employee. The second step is to determine whether the person in
question is in one, or more, of the categories expressly excluded from
the relevant schedule.
6. If Blay is to be included in the academic bargaining unit
described in Schedule 1, he must be found, on the evidence before the
Board, to be either a teacher, a counsellor or a librarian. The
evidence clearly establishes that Blay is neither a teacher nor a
librarian. There is evidence, however, that he does have contact with
students and does give them advice with respect to the cooperative
programme and the preparation of resumes for presentation to
prospective employers. He also advises students in order to help them
prepare for job interviews. The evidence of Blay is that he had been
a teacher at Fanshawe College but said he would have to distinguish
"very much" between what he did as a teacher and what he does as a Co-
op Liaison Officer II. In the latter occupation he is engaged in
preparation of students basically for the reality of going out to
work. The evidence of Blay is that while he imparts certain practical
knowledge to the students, his role is different to that of teaching
because the job is to promote co-operative programmes to employers and
to students. He sees his job to be a marketing function and
completely different to the teaching function. The job takes the Co-
op Liaison Officer outside the College in order to enable him to
promote the programme with employers.
7. It is the view of the Board that the word " counsellor" set
out in Schedule 1 "secures its particular context from being lumped
together with 'teachers and librarians' all of whom are in direct
functional contact with students and therefore comprise a bargaining
unit constituting 'the academic staff'" (Ontario Public Service
Employees' Union and The Board of Governors of Algonquin College,
[1977] OLRB Rep. May 257). In our view the marketing of cooperative
programmes to students and employers does not fit into the academic
context in which the word " counsellor" appears in Schedule 1 together
with "teachers and librarians". In the result, the Board finds that
the Co-op Liaison Officer would not fall into the academic unit if he
were found to be an employee, but that he would be properly included
in the support staff bargaining unit provided he does not fall within
the exclusions set out in Schedule 2.
Union counsel submitted that the O.L.R.B. decision is not
determinative of the instant case because it does not detail the facts
which led to the conclusion that the work performed by the individual
in question constituted a marketing function. He further submitted
that even if that decision is not distinguishable from the instant
case, we are not bound by it, nor by any of the other cases relied
upon by the College, by virtue of Isabelle v. Ontario Public Service
Employees Union (1981), 122 D.L.R. (3d) 385 (S.C.C.), which held that
although the Act provides for centralized collective bargaining (in
which the Council of Regents is statutorily authorized to bargain for
all of the colleges), neither the Act nor the collective agreement
provide for centralized arbitration under which an arbitration award
issued in respect of a grievance against one college is binding upon
all of the other colleges.
As indicated above, the remedy requested by the grievor in
both of his grievances is rescission of his layoff and reassignment to
a Co-operative Education Co-ordinator position (or another full time
position), with full restitution of lost salary and benefits with
accrued interest.
However, the remedy requested by Union counsel during the course of
his submissions is a declaration that the tasks of job clearance (for
inclusion in the co-op program) and job monitoring are academic in
nature and properly performed by the academic bargaining unit. (He
also requested the Board to remain seised, and to allow the parties an
opportunity to work out how that remedy would play out in practice.)
Counsel for the College submitted that the grievan ce to
which this award pertains cannot succeed because the Union called no
evidence to suggest that the position occupied by the grievor prior to
his lay-off still exists, as alleged in the grievance. She further
submitted that even if the Union had called such evidence, the grievor
would not be entitled to the job because two of the other laid off Co-
ordinators have more seniority than he has. It was also her
contention that the remedy sought by the Union cannot be granted
because both it and the way in which the Union has framed the case in
an attempt to obtain that remedy are significantly different from the
grievance as filed by the grievor.
In her alternative submissions dealing with the merits of
the case as framed by Union counsel, counsel for the College submitted
that although the goals of the College's co-operative education
program remain the same, the College is entitled to reorganize the
manner in which it delivers that program. She submitted that neither
job clearance nor job monitoring are inherently academic in nature,
and that the evidence adduced in these proceedings demonstrates that
the manner in which they are currently being carried out does not
involve an academic function.
In commenting on Isabelle v. Ontario Public Service
Employees Union, supra, College counsel argued that the Union's
attempt in that case to enforce contempt proceedings against one
college based upon an arbitration award involving another college
differs markedly from the College's position in the instant case that
prior arbitration awards involving other colleges should be followed
unless they are manifestly wrong, because to depart from them would be
harmful to labour relations. In this regard, she contended that we
should follow the following awards in which job development, job
placement, and work site visitation were found to be support staff
functions: Georgian College and Ontario Public Service Employees Union
(OPSEU File#89B533), unreported award dated October 17, 1990
(Carter); Fanshawe College and Ontario Public Service Employees Union
(OPSEU File#87B41), unreported award dated December 4, 1987 (Kates);
Fanshawe College and Ontario Public Service Employees Union(OPSEU
File#89D310), unreported award dated June 18, 1991 (Brent); Fanshawe
College and Ontario Public Service Employees Union(OPSEU File
#96C008), unreported award dated August 20, 1996 (Burkett); and
Fanshawe College and Ontario Public Service Employees Union(OPSEU
File#87Z12), unreported award dated May 9, 1990. (Brent).
In his repl y submissions, Union counsel suggested that it
remains to be determined whether there is enough of the aforementioned
work (which the Union contends to be inherently academic) to fill an
academic position. He further suggested that the Board need not be
concerned about the two laid off Co-ordinators who have more seniority
than the grievor, because they have not grieved their lay-offs. He
submitted that the arbitration cases relied upon by the College do not
address the Union's contention that it is a feature of the Act on
which the parties' collective agreements are premised that the work is
divided into academic work and non-academic work. Although he
indicated that he was advocating a completely watertight division, he
contended that adopting the approach advocated by the College could
lead to substantial abuses and would be inconsistent with the Act's
attempt to distinguish between academic tasks and non-academic tasks.
In Fanshawe College and Ontario Public Service Employees
Union(OPSEU File#87B41), supra, the majority of an arbitration board
chaired by Mr. Kates concluded that a Co-operative Liaison Officer
employed by the College to supervise and monitor the work term
component of its co-operative education program and the practical
training component of its stationary engineering program was not
engaged in a teaching capacity and, therefore, was properly included
in the support staff bargaining unit. In that case, the evidence
indicated that the employee in question "would visit the students
periodically once placed in a facility to iron out any difficulties",
and "would speak to the supervising employer representative to ensure
that the student is achieving the programme's object in terms of the
type of work that is being assigned".
In the Georgian College case, a majority of the
arbitration board chaired by Professor Carter held that although there
was "an important counselling and teaching component to the job"
performed by the college's Co-operative Education Consultants, their
"core function" was "to locate suitable job openings in the workplace
and to maintain contact with employers during the period of the work
experience". Thus, the majority concluded that "[s]tudent
counselling, while important, [was] only an ancillary component of the
position and not sufficiently substantial so as to bring [the
position] within the [academic] bargaining unit". They also wrote, in
part, as follows in commenting on that distinction (at pages 9 and 10
of the award):
The distinction we draw in this ca se is quantitative rather
than qualitative. We are not saying that the type of counselling and
teaching carried out by the Co-operative Education Consultant is not
academic in nature, but only that there is absent a sufficiently
substantial component of these responsibilities to warrant inclusion
of the position within the academic bargaining unit....
A "core function" test of the type referred to in that
case has also been applied in a number of other community college
arbitration awards. See, for example, Fanshawe College and Ontario
Public Service Employees Union(OPSEU File#96C008), in which the
majority of an arbitration board chaired by Mr. Burkett wrote, in
part, as follows (at pages 12 and 13) after citing with approval two
earlier awards which had applied that test:
The core function test ... is the best measure for deciding whether an
employee is more appropriately in the academic unit or more
appropriately in the support unit when, as here, there are overlapping
duties and responsibilities.
Reference may also usefully be made to the following
passage from page 31 of the majority award in Fanshawe College and
Ontario Public Service Employees Union(OPSEU File#89D310), supra:
We respectfully agree with and adopt the reasoning
contained in that award and the other aforementioned awards which
applied the "core function" test to determine whether a position falls
within the academic staff bargaining unit or the support staff
bargaining unit. Moreover, we do not view that approach as being in
any way inconsistent with the Act. Although Union counsel suggested
that it is a feature of the Act that the work performed by community
college employees is divided into academic work and non-academic work,
the Act and its schedules do not refer to academic work, non-academic
work, or any other kind of work in describing the two bargaining
units. Rather than being defined by a description of the work or
tasks performed, the bargaining units are defined in the Act by
reference to the positions or classifications included in them and
excluded from them. Since the academic staff bargaining unit includes
only College employees who are employed as "teachers, counsellors or
librarians" (subject to specified exclusions), it is entirely
appropriate to assess whether the core function of a position is
academic in nature in determining whether the position is, in
substance, that of a teacher, counsellor, or librarian and, therefore,
within the scope of that bargaining unit.
The evidence adduced in these proc eedings suggests that
the manner in which the grievor performed the tasks of assessing and
selecting job opportunities, and visiting work sites during co-op work
terms, may well have involved an academic component, although it is
clear from the evidence that his performance of those tasks also
involved administrative and marketing functions which cannot
legitimately be characterized as academic in nature. However, the
evidence adduced regarding the manner in which those tasks
have been performed since the aforementioned restructuring that gave
rise to the grievor's lay-off casts considerable doubt on whether
those tasks retain any academic component, in view of the emphasis
placed on marketing and public relations. Moreover, even if we were
to conclude that those tasks do retain some academic aspects, it is
clear from the totality of the evidence that the core function of the
Co-op Consultant position consists of marketing, public relations, and
administrative tasks. Accordingly, we are satisfied that the Co-op
Consultant position is properly included in the support staff
bargaining unit, and that there is no basis for granting the
declaratory relief sought by counsel for the Union in his able
submissions on behalf of the grievor. In this regard, we respectfully
agree with and adopt the conclusions reached in the aforementioned
arbitration awards, as well as in the aforementioned O.L.R.B.
decision, that persons performing functions analogous to those
performed by Co-op Consultants in the instant case are not "teachers,
counsellors or librarians", and are properly included in the support
staff bargaining unit.
For the foregoing reasons, the grievor's second grievance
is hereby dismissed. The hearing of his first grievance will proceed
on June 4 and November 17, 1997, as agreed by the parties..ls1
DATED at Burlington, Ontario this 15th day of May, 1997.
______________________________
Robert D. Howe
Chair
I concur (with an addendum to follow).
"Michael Sullivan"
Union Nominee
I concur.
"Jacqueline Campbell"
College Nominee