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Comment 34

Proposed Rules
Chapter 815

From: stephen amberg

Sent: Wednesday, January 16, 2019 10:02 PM
To: TWCPolicyComments
Subject: Platform employee rule

CAUTION: Email not from TWC System. Use care when clicking links and
opening attachments.

To the Texas Workforce Commission:

I have been a researcher of employment and labor policy for 30 years. I would like to comment
on the Commission's recent decision to treat workers whose employment arrangements are made
via a platform company as contractors. I believe this is a mistake.

In my judgment, these workers are employees under federal employment law. To treat them as
independent contractors denies the facts of the determination of the conditions of their work and
denies them their employee rights.

Your decision negatively affects thousands of workers, many of whom are working part-time
and/or trying to earn income to supplement other low-paid employment. They are not contractors
in any historical meaning of the term.

This issue should not be treated as a matter of power politics by the platform companies. The
Commission is not the venue to make a declaration to reinterpret employment law.


Stephen P. Amberg

Associate Professor
Department of Political Science
University of Texas at San Antonio
One UTSA Circle
San Antonio, Texas 78249