Matches for: “staffing” …

What ASU really achieved in 2013

We were pretty struck by the article on ASU’s homepage: What we achieved in 2013! Granted, some of the achievements regarding research were pretty stellar, but the majority of the article was peppered with “achievements” such as: being one of the “greenest” schools in the country, revamping the business school building, and having the Sun Devils in a bowl game.

Noticeably absent, of course, are topics such as Michael Crow receiving a pay raise while the rest of his employees receive a measly 3% pay raise (after a 5 year pay freeze!), or the decrease in proactive policing (due to staffing issues). Therefore, we’re creating a list of what ASU also achieved in 2013. This is, by no means, a conclusive list.

 

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Our response to the Chief’s Advisory Board Meeting Minutes

We broke down the meeting minutes piece by piece to share our thoughts on the topic. We could have discussed this document in even greater depth, but we decided to make it (somewhat) concise.

1.       The Chief instructed his advisory board he wanted to keep the discussion “positive”.  How do you have a constructive discussion about the departments’ problems in a “positive” way? Where do you go if the information isn’t positive? The Integrity Report on the ASU Police Department blog? The advisory board was assembled to fix the negativity Chief’s inactions and inattention have fostered, so the underlying purpose of the board will inherently be negative, even if the discussion itself is “positive”.

2.       Make new employees feel welcome? Absolutely, always do. The people discussed in the blog, (the people Chief has protected for years), those are the people making new and old employees feel unwelcome and alienated. They have brought this organization to crisis mode, and that will continue to happen despite the number of fresh bodies you bring through the door for them to devour.

 3.       The community gives positive feedback on what we do here…that’s great. There is no correlation between a positive rating by the community and how happy/ appreciated your employees are.  It simply means we won’t compromise what we do for others, compromise our ethics and integrity simply because we get treated like garbage from our department.

 4.       In regards to your community feedback: we love our community, but they don’t know squat about policing and quite frankly, they would be appalled if they knew how ASUPD treated its employees. Of course any feedback the community would give wouldn’t address major issues like staffing and retention, namely because the public has no idea this is transpiring! If the community could see Chief’s track records from his former agencies, they wouldn’t view the department in the same positive light.

 5.       Chief has placed a lot of urgency in this meeting on greeting new employees, making the testing process more expedient, referrals, posting vacancies… everything but addressing the people who put him in the current staffing situation. Your commanders and some of your sergeants created this exodus of new employees’ year after year right under your indifferent, inattentive nose.  The only reason why Chief is “concerned” now is because it has become so obvious he can’t hide it from his superiors any longer.

 6.       For the Police Officer Recruiter position, it has yet to be filled. You are asking for higher criteria in this position than most of the ones at the police department, but with a fraction of the pay.  Nobody wants to be honest with the Chief unless it’s anonymous. Even still, Chief denies these issues exist because acknowledging them requires a measure of accountability

 7.       How is ASUPD in the 90% salary range of surrounding agencies in the East Valley?  Did you add over inflated command staff salaries to the average? The $160,000 the Chief makes, and the $70k the Sergeants make would skew the averages of salaries assessed for this statement. Let’s see the math on this.

 8.       Incentives are for FTO are good, but this isn’t the real reason you don’t have trainers. The past FTOs have seen what the predatory supervisors have done with the people they were training, and have refused to participate in the destruction of another rookie’s career.  Until you can get a solid FTO program established, and an FTO Supervisor that won’t take their own interpretation on it, the FTO program cannot function.

 9.       A security fee to supplement our budget?  Given the current ASU enrollment of approximately 76,000 students, that would total approximately 3.8 million dollars!! This is insane! The department’s total expenditures and his budget is information limited to the Chief and a few members of command staff. Does anyone but the chief know what’s in the budget or where the money is going? Does anyone know how much money is in the ASUPD budget so we can compare it to other university departments who publish what their budget is? Why the secrecy? This is a public university funded with public tax dollars!

 10.   The suggestion made by Cpl. Khalid on doing ride-alongs with an FTO is ridiculous. Focus your attention and efforts on retaining your CURRENT employees. Besides, having a prospective employee witness first-hand how ASUPD treats its employees will drive them away.  However, the suggestion to look at how other departments are doing things is a good valid suggestion that will be ignored like the rest of the good ideas suggested by the advisory board.

 11.   On the “gossiping” issue: people talk in private because they see what happens to people when they talk openly about issues. If things are jacked up and employee complaints have been continually ignored then people are going to talk about it. If you are not happy with people talking about it then do something to fix the problem they are talking about!  Unfortunately, a clique does run the department in the form of most of the commanders and a number of senior sergeants.

 12.   On the “Internal Affair Investigation Retention Program”:  Your one and a half year of data leaves out the years of pattern IA’s that prove the point everyone already knows. How about an audit from the time the chief started until now? Look at the IA post cited here on the blog. Quite a different picture than the one being painted at the advisory board.

 13.    If a person was subject to so many IA’s why would the chief want to keep them in the PD? Because the chief has always needed people on the ground to continue doing the job making him look good . If you put enough internal generated IA’s in officer’s files you can keep good people from leaving.  Other agencies hear the word “IA” and think about serious allegations of wrong doing; ASUPD’s “IAs” amount to silly nonsense that almost every other PD wouldn’t have the time or energy to investigate.

 14.    If the chief is complaining about not hearing about what’s going on, about the communication lines not reaching him, about people not speaking,  up he only has to look here on the blog and read. It won’t get any more open and honest than here. Sure there are some snarky comments on occasion, but the everything asserted here is valid information this. The next chief can use this information to make this place a real good place to work!

 15.   Since you’ve been made aware of these problems, address them chief! It’s  been two months and counting and the only thing done you’ve accomplished is speeding up requisitions for equipment and attempting to get more bodies in the door? You still haven’t address the REASON why people are leaving!

 16.    You have plenty of employees making six figures who should be offering you suggestions to fix the department, but instead you only get one with a plan: a civilian police aide making  $30,000 a year. He has taken the time, done the research, planning, and implementing solutions the rest of your overpaid command staff can’t be bothered to do, or doesn’t have the mental capacity to do.

 17.   Party Patrol and Tempe Bike positions are highly political, and ASUPD’s solution is to loan them a few officers while secretly relying on Tempe PD’s officers to solve ASUPD’s staffing shortage. Tempe PD should NOT be a crutch to solve ASUPD’s problems!! When shit hits the fan, we all know Tempe PD, Phoenix PD (Downtown), and Mesa/Gilbert PD (Poly) will be the ones saving ASUPD’s ass.

 18.   The only additional training ASUPD’s officers is by MS Powerpoint and Blackboard. We need the outside police training because we can’t do it ourselves, it obviously isn’t working. We need active shooter training too! WE GET NONE!!

 19.    There is no uniformity in employee evaluations. Sergeants send up evaluations and frequently get them marked down to lower numbers by people who have never worked with the employee. The criteria for higher ratings changes from one supervisor to the next.  How about having employees do evaluations of their supervisors to stay ahead of issues before they get out of control and affect more employees?

 20.   Promotions are not taken seriously when everyone at the department sees you pass over more qualified candidates’ process after process. The notes from the advisory board clearly state this problem:  “a six year ASU officer will be promoted over a 30 year officer from another agency”. There is no incentive to stay.

 21.   Morale doesn’t exist. The ASUPD Indeed.com reviews, this blog, the chief’s advisory board all make this alarmingly clear, but ASUPD command ignores it all calling it, “…a few disgruntled people.”

 22.   You want honest assessments? Ask past employees,  pay them to do an assessment so you can see the shocking reality of how awful ASUPD treats their employees. Otherwise, stand at attention and wait for the blog to report.

 23.   The report has just too few pages to get the ball moving down field. The thing is, it doesn’t matter how many pages are filled with solid answers to problems when the chief hears them and STILL does nothing.  If the chief and his command are unable to put things in motion while the department falls apart it is time to find fresh new employees that can. The troops will be sure to give them warm welcomes and make them feel at home because they would provide hope that ASUPD could be a better place to work at.

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DPS uncovers ecstasy manufacturing operation in ASU dorm room

Yet another side effect of having a PD completely paralyzed by staffing issues: they are completely unable to function in a police capacity. Prime example is this major drug bust DPS did on a dorm room at Vista Del Sol. The irony here is Vista is merely a few blocks from the PD.

From abc15.com:

TEMPE, AZ – Arizona Department of Public Safety detectives have uncovered an ecstasy manufacturing operation inside an Arizona State University dorm room.

A DPS officer on Wednesday stopped a vehicle on Interstate 17 near Thomas Road for an HOV violation.

During a search of the vehicle, the officer found the 20-year-old driver’s backpack to be filled with ecstasy pills and cocaine, DPS said.

DPS was able to secure search warrants for the suspect’s home in Goodyear and for his dorm room at Apache and Rural roads near the ASU campus.

According to DPS, detectives found 30 pounds of product used to make ecstasy pills in his dorm room. They also found thousands of ecstasy pills.

DPS said the dorm room was “essentially a pill factory which included a ‘pill press’ complete with a motor.”

The 20-year-old is facing the following charges: possession of marijuana, possession of a dangerous drug, possession of a dangerous drug for sale, transportation of a dangerous drug for sale, manufacturing of a dangerous drug and conducting an illegal enterprise and conspiracy.

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ASU students swarm ticket office, assault an officer, and nearly riot!

Following ASU’s football victory over the U of A Wildcats last Saturday night, ASU decided to allow students to purchase tickets for the PAC-12 Championship. Obviously, emotions are pretty high amongst the student populous, and everyone converged upon Wells Fargo Arena in a rush to purchase tickets. After several hundred  students (well over a thousand, easily) swarmed WFA, ASU decided to shut down ticket sales, which ignited the crowd. The students at WFA began throwing barriers, fighting, and one of our own was assaulted.

As if the horrible planning on behalf of the university wasn’t enough of an insult, the appalling staffing levels ASUPD displayed at this event should do the trick. Low staffing in ANY situation is bad, but having a couple of officers to manage several hundred angry students IS NOT ACCEPTABLE. The sad thing is several additional officers were pulled from on-duty patrol, which means if something massive were to break out elsewhere, ASUPD would be unable to respond.

If something more serious had happened, has ASUPD even given its officers adequate enough training to be able to respond to the situation? Several other major universities–Ohio State University, Michigan State University, University of Georgia–all have Special Response Teams (SRT) specially trained in riot/crowd control, among other things. Why? Because they’ve had riots or other major incidents on campus they’ve had to respond to. We’re not suggesting ASUPD should form an SRT team soon (there is no staffing!!), but it should be included in future plans of the department as the university grows.

Bottom line: ASUPD should NOT place its officers KNOWINGLY into a situation where the officer must rely on a “nothing will happen!” mentality. This is NOT a realistic, safe, or stable strategy. You are running a bare-bones operation at THE COST OF YOUR EMPLOYEES’ SAFETY! It does not take any formal training in law enforcement for a REASONABLE person to observe that the aforementioned scenario is bad!!

We are glad the officer involved is OK, and relieved the situation was not worse, but we are concerned about how quickly ASUPD’s predicament is turning ugly. We should NOT have to wait and find out how much more violence will transpire before ASUPD removes Chief Pickens.

http://www.myfoxphoenix.com/story/24111992/2013/12/02/asu-student-arrested-after-fans-swarm-ticket-office

http://www.youtube.com/watch?v=mcK35ZZyVAA

 

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Internal Affairs Spotlight: A Look at the Numbers

Tonight’s post comes courtesy of a guest writer, A.I. Thanks for the insight!!

Internal Affairs Spotlight:  Policing Ourselves in a Police State – A Look at the Numbers

ASU Police Department boasts regularly that they are proud of the fact that the majority of internal affairs (IAs) are generated internally and do not come from outside sources.  This is typical, backwards, ASU PD logic.  How is having more internal complaints better than having more external complaints?

If you look at the 3rd training bulletin on Blackboard for 2013 , there is a significant difference in the number of sustained complaints in the external complaints (hardly any) versus the number of sustained complaints in the internal complaints category (significantly higher).

This internal complaint system is perpetrated by a very select number of employees, referred to across the department as “the click”.  How are 4 employees responsible for more than 25% of internal complaints out of more than 130 employees?  The main five members of “the click” represent roughly 5% of the department staffing yet are responsible for the 25% of our internal IAs.  That is a huge red flag regarding these employees’ characters.  The Chief has acknowledged that there is a click and yet has done nothing to deal with it.  This unchecked power base stemming from line level supervisors to Commander shows how corrupt police management can lead to internal issues.

Here are some of the highlights of “The Click” and ACTUAL internal affairs investigations!!

Commander William Orr

  • ACTUAL IA: Illegally seized an employee’s personally owned firearm.  Tsk. Billy.  Didn’t your mother teach you that you can’t take things that aren’t yours?
  • ACTUAL IA: Busy chasing employees out of the department with bogus firearms issues. Well, I guess if Pam, Aston, and Louis couldn’t get you I will!!

Commander Louis Scichilone 

  • ACTUAL IA: Busy wasting time targeting an employee and trying to catch them sleeping on duty, numerous times. Great job Lou!!  The knees on your paints are looking warn from kneeling down to kiss so much of the Chief’s ass!
  • ACTUAL IA: Investigated an employee for driving 5 miles off of campus. Yes, 5 whole miles! Running code at 60 mph it would take exactly 1 minute to get to an emergency call.
  • Ran to Command Staff when an employee who was in the police association left a copy of an email talking about a staffing survey was found by Lou.  Again, get a life.  Oh wait, you make life size Star Wars characters. Enough said!
  • ACTUAL IA: Writing up employees who were late to work. Great use of the IA system Lou! It is clearly proves that you have nothing better to do then to mess with employees.

Sergeant Pam Osborne

  • Ran the FTO unit into the ground.  Proud of her FTO “failure rate”.  Too incompetent to understand that isn’t something to be proud of.
  • ACTUAL IA: Investigated employees for not using in-car video (which don’t work half of the time) on a traffic stop.  Really?  Maybe Pam should have spent time investigating why our equipment regularly doesn’t work instead!!
  • Talks down to employees she doesn’t like.  Pretends to know more about police work but is a coward and afraid to leave the station.  Want an IA ASUPD?  Go investigate how many times Pam actually leaves the station.
  • Ran a female police officer out of the department because she didn’t like her.  Refused to let the employee see her training records or DORS.  It’s because she had to go back and change things in order to get rid of this employee. Corrupt!

Sergeant Mark Aston

  • ACTUAL IA: Busy writing up Police Aides for not wearing a bicycle helmet. Great supervision there Sarge!
  • ACTUAL IA: Investigated a Police Aide for damaging a wall at a cop shop with a Segway.  Words escape me on this one!
  • ACTUAL IA: Was accused of racial bias from a citizen. Although, he was cleared this time look at the majority of people he has targeted with IAs or bullshit write ups:  Ray Kizee, Damion White, Matt Parker, Tony Momon, Luke Khalid, Rudy Freese (anyone noticing a “racial” pattern here). 

Also, notable is that every IA the Chief himself has initiated has been sustained findings.  If he is the accuser and the finder of facts doesn’t that amount to an obvious conflict of interest?  If the Chief initiates an IA shouldn’t an outside agency investigate the findings if it involves an employee’s termination?  Like a former female officer who was railroaded out of the department? One would think but not with “Slim” Pickens at the wheel.

Even better is the continuous violating of officers rights under Arizona law.  The department engages in a process called an “administrative review” instead of conducting an IA.  They do this so the rights for police officers under Arizona law do not apply.  Again, here is another example of police mismanagement and abusing employees.

Here is my message to the Chief: Take a hard look at the state of the department.  People are leaving in droves because they refuse to put up with the bullshit.  You have done this to the department and the morale because these people go unchecked.  You have created a “police state” inside of a “police department” instead of honorable and trustworthy employees.  Stop the nepotism, favoritism, and politicalism and get rid of the poisonous leeches that are ruining the department. 

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Mismanagement of state agencies: ADOC and CPS have had their turn…is ASUPD next?

Within the past few months, two very major state entities–Arizona Department of Corrections, and Child Protective Services–have been under major scrutiny, due to issues ranging from fiscal mismanagement, low staffing, to poor leadership. Many Arizona lawmakers have began to ask the question…what else is happening at the state level?

ADOC has been critically understaffed for years; according to an article written by abc15.com, it is common practice to have 2-4 officers watching anywhere from 100-200 inmates. Staffing is so bad it has created an unsafe environment for its employees; ADOC averages 335 officer assaults A YEAR!! Or what about the ridiculously low salary most of its corrections officers make (about $31k), yet ADOC’s budget is $1 billion dollars?! (Sound familiar?)

CPS has also had their dirty laundry aired all over the news media. Since 2009, nearly 6,000 cases received from the CPS hotline hadn’t been investigated. One of CPS’ former employees has also come forward and stated that low pay and staffing issues make it impossible for CPS to function effectively (Again…familiar territory). The situation at CPS is so critical that a member of the legislature’s CPS oversight committee stated, “The public must know that this neglect of duty will never happen again and that the people responsible for this disturbing practice are held accountable. In addition, a long-term reform of the agency is warranted to restore public confidence.” Furthermore, a representative from the State House has asserted the director of CPS (Clarence Carter) must be removed for the agency to succeed. “Either the governor or Carter — one of them needs to go. This is another state agency that’s failing under her.”

Both the situation at ADOC and CPS parallel the problems that ASUPD is currently having. Mismanagement of personnel and money by higher-ups leads to staffing problems, low work productively, and high employee turnover. These state agencies which have gone largely unchecked for quite some time are starting to face scrutiny for their mismanagement…how long will it be before ASUPD and Chief Pickens’ names are also thrown into the mix?

 

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Shocking revelation! ASUPD can write citations. In other news, water is wet.

In the latest story from ASU’s State Press, Downtown Phoenix Campus students verbalized their disagreement with ASU’s new ban on smoking. Mind you, this policy is peer-enforced…has nothing to do with the PD whatsoever (despite the fact the university was initially misleading by having officers and random members of command “ask students nicely to stop smoking”).

ASUPD’s own Commander Chris “Sparky” Speranza was compelled enough to take the time out of his super busy day (ie, doing nothing) to make ASUPD look even more ridiculous. “There have been no citations for littering since the no-smoking policy went into effect”. Someone should inform him that he has two STELLAR Sergeants that have the ability to enforce the law, but that also requires them to 1) show up to work 2) dress out into their uniforms and 3) leave the Post Office. Maybe have an Officer enforce the littering law? Oh wait…they keep getting pulled to work at other campuses due to staffing concerns.

In case you were wondering about his street credibility folks, Sparky also said, “This [lack of littering citations] was not because the no-smoke policy is peer-enforced, as an ASU officer can issue a citation to any citizen”.

So just to clarify…we can write citations to any citizen. Gotcha. I was wondering what that book of citations was for!

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How many more officers can ASUPD handle losing?

One more piece of evidence that illustrates perfectly the end result of ASUPD’s mismanagement:

We’re told that a grand total of six more officers will be out of ASUPD by the end of December (this number includes the officer who just went to MCCPD). That is unreal! All six of these officers are intelligent and talented, and we’re so happy to hear that they’ve decided to move on to greener pastures. It’s not rocket science! Treat your people well, impart them with the tools to do their jobs effectively, and trust they will do the right thing! Intervene when necessary, and stamp out fires/conflicts before they fester.

If everything that has been said here on The Integrity Report is not true, Chief Pickens, then why are so many people fleeing from ASUPD in droves? You can keep trying to explain away us and postings on indeed.com as just disgruntled employees, but the proof is in the numbers. There is obvious validity to our assertations here.

All these people who have left and who are actively trying to leave have formulated their own opinions of ASUPD based on their experiences in dealing with the department, seeing how others are treated, and hearing how other PDs in the valley treat their employees.

ASUPD can’t logically function with the staffing numbers they currently have, and aren’t able to staff the satellite campuses now. How much longer are you going to claim that there’s no problem, Chief Pickens?

 

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Firearms proficieny at ASUPD: why it’s a critical issue the Chief isn’t addressing.

One major issue we here at THR haven’t been able to address yet has been firearms proficiency; partially because of the sheer magnitude and depth of the issue, and partially due to the fact that so much of the problems with firearms training have been shrouded in so much secrecy.

There are laws/policies in place which very clearly state firearms qualification requirements.

Let’s do a quick recap of what ASUPD claims its standards are. According to ASUPD’s policy manual:

 An Officer must:

  • Qualify at scheduled range sessions.
    • If the Officer fails on the first attempt, he or she will obtain immediate training from the Rangemaster, or designee, before making the second attempt.

A Rangemaster must, for any Officer who fails to qualify during the initial range session:

  • Complete a memorandum and provide copies to the Officer, the Officer’s supervisor, and the Officer’s Commander.
  • Indicate on the form that the first 30 days have been forfeited if this is the second required course during the calendar year on which the Officer has failed during the initial range session.
  • Schedule remedial training of up to eight hours and a re-qualification shoot.

The Officer’s Commander:

  • Reassign the Officer to an administrative position for up to 30 work days pending qualification.
  • Inform the Officer that he or she is not to carry any firearm in a law enforcement capacity, is not eligible for overtime duty, and is not to perform any off-duty work in a law enforcement capacity for the duration of the administrative assignment.

 Officer fails to qualify, and he or she has not previously failed in another course:

  • Instruct the Officer to remain on administrative duty pending qualification for up to 60 work days from date of the original failure to qualify.
  • Provide the Officer with a second remedial training session of up to eight hours and a qualification shoot.

 If he or she has previously failed in another course that year or has failed to qualify again after the attempt as noted above:

  • Forward a request for disciplinary action to the Chief of Police through the chain of command.
  • The Chief of Police may impose suitable disciplinary action, most often termination for failure to maintain skills necessary to perform an essential job function.
  • Probationary Officers will always be terminated for failure to qualify within the allotted time.
  • Disciplinary actions other than termination will only be considered, if there are overwhelming mitigating circumstances affecting the failure to qualify.

First of all, WHY DO WE HAVE OFFICERS STRUGGLING TO QUALIFY WHEN WE HAVE 7+ RANGE “INSTRUCTORS”?! That’s about 10 officers to every ONE instructor (with such low numbers, the officer to instructor ratio is even lower). You’re such an “elite” bunch of instructors, so PROVE IT. Being a decent firearms instructor is measured by how many officers you can get to shoot well consistently, NOT how many AR-15s you have or how many classes you’ve taken, or how well you can shoot.

Secondly, there is a great disparity in how people are treated if they have problems qualifying. There are several people who consistently fail qualification and aren’t assigned to desk duty, but instead allowed to work patrol because of staffing problems (THIS IS A HUGE SAFETY ISSUE!!! WHY IS THIS EVEN HAPPENING!?) Then are others who get put on admin leave and are threatened with the loss of their job while receiving virtually NO significant amount of training. 

Thirdly, why is no one above the rank of Sergeant required to qualify in front of others at Gila River, but instead have their peers evaluate them at Tempe PD’s air conditioned range? This includes range instructors too! They are all miraculously expert shooters.

How can the Chief look at these issues and think this system has any sort of integrity, is safe, and seems to be working? When you have people consistently failing to qualify, maybe as a leader you should look at the systemic issue, instead of dismissing it on an individual level.

Maybe instill confidence in your officers through adequate training instead of holding their jobs over their heads every time they head to the range?! That would be a good place to start.

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How ASU’s usage of comp time violates Federal labor law.

There’s been some discussion at ASUPD recently about the Fair Labor Standards Act (FLSA) and how it is applicable to law enforcement. We were doing some fact finding regarding a statement that mandatory firearms training is not considerable compensable time (ASUPD officers should be “grateful” they’re paid for training!), when we stumbled across some interesting info about compensatory time.

Compensatory—or comp time, as it is commonly referred to—is a way for a police department to pay its non-exempt employees for hours worked over 40 in a work week.  For the purpose of this discussion, the FLSA considers “exempt” employees that make a minimum salary per year, among other requirements.[i],

Therefore, all of ASUPD’s line level officers and first tier supervisors would be considered “non-exempt”. According to the FLSA, under certain prescribed conditions, a State or local government agency may give compensatory time [to non-exempt employees], at a rate of not less than one and one-half hours for each overtime hour worked, in lieu of cash overtime compensation. Employees engaged in police and fire protection work may accrue up to 480 hours of compensatory time. An employee must be permitted to use compensatory time on the date requested unless doing so would “unduly disrupt” the operations of the agency[ii].

Last we checked, on a work week longer than 40 hours, ASUPD wasn’t paying out comp time at a rate of time and ½, and beyond that, we definitely didn’t have the ability to use it. The department itself is causing “the emergency that disrupts operations” by continuously allowing critical staffing shortages, so does that mean it is an acceptable reason to deny the usage of comp time? ASUPD command likes to utilize comp time like a carrot on the end of a stick; it looks appealing in theory, but in practice, it is elusive and creates low morale.


[i] http://www1.umn.edu/ohr/toolkit/compensation/paypolicy/flsa/#

[ii] http://www.dol.gov/whd/regs/compliance/whdfs8.pdf

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