'The Safety of Our Children'
New Jersey's Recreation and Park Association says the proposed independent-contractor rule would hit youth sports coaches, umpires and more.
Here’s an interesting perspective from within the estimated 8,300 public comments that the New Jersey Department of Labor & Workforce Development uploaded last week, with regard to its proposed independent-contractor rule.
Denise Lanza, co-chair of the New Jersey Recreation and Park Association Public Affairs Committee, filed a comment that explains how the rule-making would make it a challenge for the statewide parks and recreation community to hire people like youth league umpires and coaches, or yoga instructors for senior citizens at community centers.
The comment states that the proposed regulatory interpretations:
“… will negatively affect the services provided to our communities. In particular, these may impact low income, urban residents most.”
Here is that public comment in full:
ADA and Inclusion at the Parks
Similarly, there’s a public comment filed by Dina Trunzo, who writes about how independent contractors help municipalities—specifically parks and recreation departments—comply with the Americans with Disabilities Act as a matter of inclusion.
Her public comment states that:
“This makes economic sense for these municipalities to not bring someone on as a W-2 employee when they will be working for a short time, for a minimal number of hours, or as an ‘as-needed professional.’”
Here is that comment in full:
Services for kids and seniors at parks and community centers. Low income and urban residents. That’s what these public comments are about.
They are in addition to public comments filed about people who need legal services from the Office of the Public Defender, and people who need translators for help navigating the schools and courts. All of which independent contractors help to provide every single day, too.
I’ll have more tomorrow from the thousands upon thousands of pages of public comments that have been filed New Jersey. The breadth and depth of opposition to the state’s proposed independent-contractor rule is truly staggering.
In the letter from the park’s department representative it is stated that it would be a challenge to meet all three conditions; what are these conditions?