June 16, The National Labor Relations Board Washington, DC Dear Chairman Liebman and Members of the Board:

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Reynold Sanders
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June 16, 2010 The National Labor Relations Board Washington, DC 20570 Dear Chairman Liebman and Members of the Board: We are writing to express our strong concern with the National Labor Relations

1 June 16, 2010 The National Labor Relations Board Washington, DC Dear Chairman Liebman and Members of the Board: We are writing to express our strong concern with the National Labor Relations Board s (NLRB) recent request for information regarding the use of electronic voting during union organizing elections. Among other adverse impacts, using electronic means to permit off-site, or remote, voting during union organizing elections will subject employees to a level of intimidation and coercion that does not occur during an on-site, private ballot election that is directly supervised by the NLRB. 1 Furthermore, electronic voting bears a striking resemblance to the card-check scheme that Americans and union households are overwhelmingly opposed to because it effectively eliminates the secret ballot. The Coalition for a Democratic Workplace (CDW), a group of more than 580 organizations, is united in opposition to legislation pending in the U.S. Congress, the Employee Free Choice Act (EFCA), because we believe this bill severely undermines the employee privacy protections that have been a long-standing hallmark of federal labor law. Similarly, CDW is committed to ensuring that the principles of EFCA--- namely, restructuring the way union elections are conducted in order to give professional union organizers an advantage at the expense of employee privacy and a full debate over the merits of unionization---are not enacted by the Board through the regulatory process or otherwise. Electronic voting from off-site locations raises the same concerns as the card-check process outlined in EFCA. The most glaring flaw in a plan to employ electronic voting is the inability of the NLRB to oversee the actual casting of ballots. By requiring employees to vote from their home computer or other location where the Board cannot ensure privacy equal to that of the ballot booth, the 1 While the Board currently allows mail ballot elections in rare situations where barriers exists to conducting an onsite election because eligible voters are scattered due to locations, work schedules, strikes or lock outs, the RFI suggests services are sought to replace secret ballot elections rather than the Board s existing mail ballot procedures. Specifically, the RFI states, The NLRB's requirements are for the acquisition of electronic voting services to support conducting secret ballot elections to determine representation issues.

2 Board will expose employees to increased risks of intimidation and coercion by professional union organizers or co-workers. The National Labor Relations Act currently allows professional union organizers to target individuals by visiting them at their homes, and any other location outside the workplace; a privilege of which they regularly take advantage. It does not take much imagination to envision a professional union organizer visiting an individual s home to make sure they had voted electronically, and even offering to help them cast their vote. The departure from the traditional, private ballot election would be a drastic change that could have a negative impact on hard-working men and women throughout the country, subjecting them to greater harassment during union organizing campaigns, and potentially imposing on them a union they did not want. Such a dramatic policy change should not be enacted through regulatory fiat or other Board action. And, finally, CDW has often recognized that the current private ballot process benefits both the employee and the unions. NLRB annual reports consistently show that a majority of elections are conducted within 38 days (down from 50 days in 1980), and that more than 90% of elections are conducted in less than two months. Along with that, in 2009, unions won 68.5% of workplace elections held. These numbers hardly seem to merit sacrificing the employee protections that come with on-site, NLRB-supervised, private ballot elections. Thank you for your consideration of our concerns, and we hope that the Board will continue to act in the best interest of employees rather than special interests. Sincerely, The Coalition for a Democratic Workplace 60 Plus Advanced Supply Chain International Aeronautical Repair Station Aerospace Industries Affiliated Chambers of of Greater Springfield (MA) Alabama Chapter of ABC Alabama Restaurant Alaska Cabaret, Hotel, Restaurant & Retailers Alaska Chapter of ABC Alaska Hotel & Lodging Alliance for Worker Freedom Aluminum American Apparel & Footwear American of Homes & Services for the Aging American Bakers American Beverage American Boiler Manufacturers American Concrete Pressure Pipe American Conservative Union American Council of Engineering Companies American Fire Sprinkler American Foundry Society American Frozen Food Institute American Health Care American Home Furnishings Alliance American Hosptial American Hotel & Lodging American International Automobile Dealers

3 American Meat Institute American Moving & Storage American Mushroom Institute American Nursery & Landscape American Pipeline Contractors American Rental American Rental of California American Rental of Maryland American Rental of Massachusetts American Rental of Nebraska American Rental of Wisconsin American Resort Development American Seniors Housing American Shareholders American Society for Healthcare Human Resources Administration American Society of Employers American Staffing American Supply American Trucking s American Wholesale Marketers Americans for a Limited Government Americans for Prosperity Americans for Tax Reform Antelope Valley Chamber of API Arcadia (CA) Chamber of Arizona Builders Alliance of ABC Arizona Chamber of & Industry Arizona Hotel & Lodging Arizona IEC Arizona Restaurant & Hospitality Arkansas Associated Builders & Contractors Arkansas Hotel & Lodging Arkansas IEC Arkansas Rental Arkansas State Chamber of Asheboro/Randolph (NC) Chamber of Ashland & Tri State Area Chapter IEC Asian American Hotel Owners Assisted Living Federation of America Associated Builders & Contractors Associated Builders & Contractors Heart of America Chapter Associated Builders & Contractors of Alabama Associated Builders & Contractors of Hawaii Associated Builders & Contractors of Los Angeles/Ventura Associated Builders & Contractors of Michigan Associated Builders & Contractors of Texas Associated Equipment Distributors Associated General Contractors Associated Industries of Massachusetts Associated Rental Stores of Kansas City for Manufacturing Technology of Equipment Manufacturers of Millwork Distributors of Washington Business of Woodworking & Furnishings Suppliers Atlanta Hotel Council Automotive Aftermarket Industry Baltimore Metro Chapter of ABC Bearing Specialists Brick Industry Burnsville (MN) Chamber of Business & Industry of New Hampshire Business Solutions California Chamber of California Delivery California Hotel & Lodging California Manufacturers & Technology California Restaurant California/Nevada/Arizona Automotive Wholesalers Camarillo (CA) Chamber of Capital Associated Industries Inc Carolina Ready Mixed Concrete Carolinas Chapter of ABC Center for Freedom & Prosperity Center for Individual Freedom Center for the Defense of Free Enterprise

4 CenTex Chapter IEC Central Alabama Chapter IEC Central California Chapter of ABC Central Florida Chapter of ABC Central Indiana IEC Central Michigan Chapter of ABC Central Missouri IEC Central Ohio AEC/EIC Central Ohio Chapter of ABC Central Pennsylvania Chapter of ABC Central Pennsylvania Chapter of IEC Central Texas Chapter of ABC Central Washington IEC Centre County (PA) IEC Chamber of of Southwest Indiana Chamber of Medford/Jackson County (OR) Charleston (SC) Metro Chamber of Chattanooga Area (TN) Chamber of Chesapeake Chapter of ABC Chesapeake IEC Chicago Auto Trade Chicagoland Chamber of Cincinnati Regional Chamber of Citizen Outreach Project Cleveland-Bradley (TN) Chamber of Coalition of Franchisee s College & University Professional for Human Resources Colorado of & Industry Colorado of Homes & Services for the Aging Colorado Concern Colorado Hospital Colorado Hotel & Lodging Colorado Restaurant & Industry of New Jersey Connecticut Business & Industry Connecticut Chapter of ABC Connecticut Restaurant Consumer Electronics Copper & Brass Servicenter Cornhusker Chapter of ABC Costa Mesa (CA) Chamber of Council for Citizens Against Government Waste Cumberland Valley Chapter of ABC Custom Electronic Design & Installation Dakotas Inc IEC/Dallas Chapter IEC Daytona Beach/Halifax (FL) Chamber of Delaware Chapter of ABC Delaware Restaurant Denver Metro Chamber of Detroit (MI) Regional Chamber of Duluth (MN) Area Chamber of East Tennessee Chapter of ABC East Tennessee IEC East Texas IEC Eastern Pennsylvania Chapter of ABC Eastern Shore Chapter of ABC Eastern Washington Chapter IEC El Paso Chapter IEC Electronic Security Empire State Chapter of ABC Environmental Industry s Equipment Marketing & Distribution Fairfax County (VA) Chamber of Federation of American Hospitals Fertilizer Institute (The) Flagstaff (AZ) Chamber of Florida Chamber of Florida East Coast Chapter of ABC Florida First Coast Chapter of ABC Florida Gulf Coast Chapter of ABC Florida Independent Concrete & Associated Products, Inc. Florida Restaurant & Lodging Florida West Coast Chapter IEC Food Marketing Institute Forging Industry Fort Worth/Tarrant County IEC

5 Freedom Works Fruita Area Chamber of Gases and Welding Distributors Georgia Chamber of Georgia Chapter of ABC Georgia Hotel & Lodging Georgia IEC Georgia Restaurant Glendale (AZ) Chamber of Golden Gate Chapter of ABC Goleta Valley (CA) Chamber of Grand Junction Area (CO) Chamber of Greater Albuquerque (NM) Chamber of Greater Bakersfield (CA) Chamber of Greater Cincinnati IEC Greater Columbia (SC) Chamber of Greater Columbus (GA) Chamber of Greater Decatur (IL) Chamber of Greater Delray Beach (FL) Chamber of Greater Elkhart (IN) Chamber of Greater Findlay (OH) Chamber Inc. Greater Hamilton (OH) Chamber of Greater Houston Chapter of ABC Greater Lafayette Chamber of (LA) Greater Louisville (KY) Inc. Greater Medina (OH) Chamber of Greater Pittsburgh (PA) Chamber of Greater Pittsburgh (PA) Hotel Greater Raleigh (NC) Chamber of Greater Reading Chamber of Greater Shreveport Chamber of Greater Spokane Incorporated Greater St. Louis IEC Greater Syracuse (NY) Chamber of Green Bay Area (WI) Chamber of Guam Contractors of ABC Hampton Area (NH) Chamber of Hampton Roads Chapter IEC Hartford (CT) Chamber of Hawaii Hotel & Lodging Hawaii Restaurant Healthcare Distribution Management Heart of America Chapter of ABC Heating, Airconditioning & Refrigeration Distributors International Henderson (NV) Chamber of Hilliard (OH) Chamber of Hispanic Alliance for Progress Institute Hobbs (NM) Chamber of Hospitality of South Carolina Hotel of New York City Hotel of Washington DC Houma Chamber of Idaho IEC Idaho Lodging & Restaurant Illinois Chamber of Illinois Chapter of the Associated Builders & Contractors Illinois Hotel & Lodging Illinois IEC Illinois Restaurant Independent Electrical Contractors Inc Indian River County (FL) Chamber of Indiana Chamber of Indiana Chapter of ABC Indiana Motor Truck Industrial Fasteners Institute Industrial Supply Inland Pacific Chapter of ABC Interlocking Concrete Pavement Institute International of Amusement Parks & Attractions International of Refrigerated Warehouses International Council of Shopping Centers International Dairy Foods

6 International Foodservice Distributors International Franchise International Housewares International Sign International Truck Parts International Warehouse Logistics Iowa of Business & Industry Iowa Chapter of the Associated Builders & Contractors Iowa Restaurant Iowans for Right to Work Kansas Chamber (The) Kansas City IEC Kansas Restaurant & Hospitality Kentuckiana Chapter of ABC Kentucky & Southern Indiana Chapter IEC Kentucky Chamber of Kentucky Electrical Contractors Kentucky Motor Transport Kentucky Restaurant Keystone Chapter of ABC Lake Havasu Area (AZ) Chamber of Larue County Chamber of Las Vegas (NV) Chamber of Las Vegas Chapter of ABC Licking County (OH) Chamber of Little Rock (AR) Chamber of Long Beach Area Chamber Louisiana of Business & Industry Louisiana Rental Louisiana Restaurant Louisiana Retailers Lower Bucks County (PA) Chamber of Lubbock Chapter IEC Maine Chapter of ABC Maine Innkeepers Maine Restaurant Management of Illinois (The) Manufactured Housing Institute Manufacturers of NW Pennsylvania Maryland Hotel, Motel & Resort Maryland Motor Truck Massachusetts Chapter of ABC Massachusetts Restaurant Material Handling Equipment Distributors MEC-IEC of Dayton, OH Messenger Courier of the Americas Metals Service Center Institute Metro Washington Associated Builders & Contractors Metro West (MA) Chamber of Michigan Beer & Wine Wholesalers Michigan Chamber of Michigan Manufacturers Michigan Restaurant Mid Gulf Coast Chapter of ABC Mid Tennessee Chapter of ABC Mid-America Lumbermens Mid-Oregon Chapter IEC Mid-South Chapter IEC Midwest Equipment Rental Midwest IEC Minnesota Chapter of ABC Minnesota Grocers Minnesota Lodging Minnesota Rental Minnesota Restaurant Minnesota Trucking Mississippi Associated Builders & Contractors Mississippi Economic Development Council Mississippi Hospitality & Restaurant Mississippi Manufacturers Missouri Restaurant Monroe (LA) Chamber of Montana Chamber of Montana IEC Montana Motor Carriers Montana Restaurant

7 Montgomery Area (AL) Chamber of Motor & Equipment Manufacturers Mountain States Employers Council, Inc. Nashville IEC Natchitoches Area (LA) Chamber of National Alliance for Worker & Employer Rights National Apartment National of Chemical Distributors National of Home Builders National of Manufacturers National of Mutual Insurance Companies National of Real Estate Investment Trusts National of Sign Supply Distributors National of Theatre Owners National of Wholesaler- Distributors National Automobile Dealers National Center for Assisted Living National Club National Council of Agricultural Employers National Council of Chain Restaurants National Council of Farmer Cooperatives National Council of Textile Organizations National Electrical Manufacturers National Federation of Independent Business National Franchisee National Grocers National Lumber & Building Material Dealers National Mining National Multi Housing Council National Newspaper National Pest Management National Petrochemical & Refiners National Precast Concrete National Private Duty National Propane Gas National Ready Mix Concrete National Restaurant National Retail Federation National Roofing Contractors National Small Business National Solid Wastes Management National Stone, Sand & Gravel National Systems Contractors National Tank Truck Carriers, Inc. National Taxpayers Union National Tooling & Machining National Utility Contractors Nebraska Chamber of & Industry Nebraska Grocery Industry Nebraska Hotel & Motel Nebraska Restaurant Nevada Hotel & Lodging Nevada Manufactures Nevada Restaurant New England IEC New Hampshire Lodging & Restaurant New Hampshire/Vermont Chapter of ABC New Jersey Business & Industry New Jersey Chapter of ABC New Jersey Electrical Contractors New Jersey Food Council New Jersey IEC New Jersey Motor Truck New Jersey Restaurant New Mexico Chapter of ABC New Mexico Lodging New Mexico Restaurant New Orleans/Bayou Chapter of ABC New York State Hospitality & Tourism New York State Restaurant Newspaper of America North Alabama Chapter of ABC

8 North American Equipment Dealers North Carolina Chamber of North Carolina Restaurant & Lodging North Dakota Chamber of North Dakota Hospitality North Florida Chapter of ABC North Las Vegas (NV) Chamber of Northeastern Retail Lumber Northern Allegheny County (PA) Chamber of Northern Kentucky Chamber of Northern New Mexico IEC Northern Ohio Chapter of ABC Northern Ohio Electrical Contractors Northern Palm Beach Chamber Northwest Pennsylvania IEC Northwest Washington IEC NPTA Alliance Offshore Marine Service Ohio Chamber of Ohio Hotel & Lodging Ohio Manufacturers Ohio Restaurant Ohio Valley Chapter of ABC OKC Inc IEC Oklahoma Chapter of ABC Oklahoma Hotel & Lodging Oklahoma Rental Oklahoma Restaurant Oklahoma State Chamber Optical Laboratories Oregon IEC Oregon Lodging Oregon Restaurant Owatonna Area (MN) Chamber of & Tourism Oxnard (CA) Chamber of Pacific Northwest Chapter of ABC Pacific Printing & Imaging Pelican Chapter of the Associated Builders & Contractors Pennsylvania Chamber of Business & Industry Pennsylvania Restaurant Pennsylvania Tourism & Lodging Petroleum Equipment Institute Plumbing-Heating-Cooling Contractors Portland Cement Precision Metalforming Printing & Graphics Mid Atlantic Printing & Imaging Mountain States Printing & Imaging of Georgia, Inc. Printing & Imaging of Mid America Printing & Imaging of New York State Printing of Florida, Inc. Printing Industries Inc. Serving Northern Kentucky & Ohio Printing Industries of San Diego (CA) Printing Industries of the South, Inic. Printing Industries, Inc. of Arizona Printing Industries, Inc. of Southern California Printing Industries of America Printing Industries of Michigan, Inc. Printing Industries of New England Printing Industries of Northern California Printing Industries of St. Louis (MO) Printing Industries of the Gulf Coast Printing Industries of the Midlands, Inc. Printing Industries of Utah Printing Industries of Virginia Printing Industries of Wisconsin Printing Industry of Illinois/Indiana Printing Industry of Minnesota, Inc. Printing Industry of the Carolinas, Inc. Professional Beauty

9 ProsperityAlaska.org Public Service Research Council Puget Sound Washington Chapter IEC Recreation Vehicle Industry Redwood Empire Chapter IEC Regional Legislative Alliance of Santa Barbara County (CA) Restaurant & Hospitality of Indiana Restaurant of Maryland Restaurant of Metropolitan Washington Retail Industry Leaders Rhode Island Chapter of ABC Rhode Island Hospitality & Tourism Rio Grande Valley Chapter of IEC Inc Rockwell Collins Rocky Mountain Chapter of ABC Rocky Mountain IEC Rogers-Lowell (AR) Chamber of Ruston-Lincoln (LA) Chamber of Sacramento (CA) Metro Chamber of Saginaw Valley Chapter of ABC San Antonio Chapter IEC San Clemente Chamber of San Diego Chapter of ABC San Diego North Chamber of San Jose Chamber of Sierra Nevada Chapter of ABC Snack Food Society of American Florists Society of Human Resource Management South Carolina Trucking South Dakota Retailers South Florida Chapter Inc IEC South Texas Chapter of ABC Southeast Missouri IEC Southeast Pennsylvania Chapter of ABC Southeast Texas Chapter of ABC Southeastern Michigan Chapter of ABC Southern Arizona IEC Southern Building Material Southern California Chapter of ABC Southern California IEC Southern Colorado Chapter IEC Southern Hills Business Southern Indiana Chapter-Evansville IEC Southern New Mexico IEC SPI: The Plastics Industry Trade St. Mary s County (MD) Chamber of Staten Island (NY) Chamber of Steel Manufacturers Stuart-Martin County (FL) Chamber of Taxpayers League of Minnesota Tennessee Hospital Tennessee Hotel & Lodging Tennessee Restaurant Texas Coastal Bend Chapter of ABC Texas Gulf Coast Chapter IEC Texas Gulf Coast Chapter of the Associated Builders & Contractors Truck Renting & Leasing Truckload Carriers Tucson (AZ) Metropolitan Chamber of U.S. Apple U.S. Chamber of U.S. Hispanic Chamber of U.S. Human Recourses and Ethics Services United Chambers of -SFV & Region United Fresh Produce United Motorcoach Utah Chapter of ABC Utah Hotel & Lodging Texoma IEC Textile Care Allied Trades Textile Rental Services of America The Real Estate Roundtable Tooling & Manufacturing Treasure State IEC Tri-State IEC Utah IEC Texas Hotel & Lodging Texas Panhandle IEC Texas Hospital

10 Texas Restaurant Texas State IEC Texas Warehouse Utah Restaurant Ventura Chapter IEC Vermont Hospitality Council Virginia Chamber of Virginia Chapter of ABC Virginia Hospitality & Travel Virginia Manufacturers Virginia Petroleum Convenience & Grocery Virginia Trucking Visalia Chamber of Washington IEC Washington Restaurant Washington State Hotel & Lodging WECA IEC West Chamber Serving Jefferson County (CO) West Suburban Chamber of & Industry West Tennessee Chapter of ABC West Texas IEC CC: U.S. House of Representatives U.S. Senate

January 7, Dear Member of the 111 th Congress:

January 7, Dear Member of the 111 th Congress: January 7, 2009 Dear Member of the 111 th Congress: Congratulations on being elected to the 111th Congress. Our country faces an array of serious challenges, and we commend your desire and service in helping