SB 369 adds Section 2946 to the Fish and Game Code to require that state agencies contracting for Salton Sea restoration projects costing more than $1,000,000 include an enforceable contractual commitment that every bidder, contractor, subcontractor, or other entity at every tier use a “skilled and trained workforce” to perform work that falls within apprenticeship occupations in the building and construction trades. The requirement attaches to contracts entered on or after January 1, 2026, and explicitly allows an alternate compliance path when the entire project is covered by a project labor agreement that already mandates a skilled and trained workforce.
The bill targets procurement language and definitions: “every tier” reaches suppliers and manufacturers of off-site aggregate materials (but not transportation), and key terms are defined by cross-reference to existing Labor and Public Contract Code provisions. Its stated purpose is to expand apprenticeship training and raise wages, safety, and quality for communities around the Salton Sea, especially in Imperial County.
At a Glance
What It Does
Requires state agencies undertaking Salton Sea restoration projects over $1,000,000 to insert an enforceable commitment in contracts that all work falling within apprenticeship occupations be performed by a skilled and trained workforce, as defined in existing law. Contracts entered on or after January 1, 2026 are covered; a project labor agreement that already meets the standard is an exception.
Who It Affects
The Natural Resources Agency, Department of Water Resources, Department of Fish and Wildlife (the department), prime contractors, subcontractors at every tier, and manufacturers or suppliers of off-site aggregate materials used on projects. Local apprenticeship programs and construction trade employers in Imperial Valley are also directly implicated.
Why It Matters
The bill embeds labor and apprenticeship standards directly into procurement for a high-profile restoration program, shifting compliance obligations onto bidders and the supply chain and likely increasing demand for apprenticeships in the region. Procurement officers, contractors, and workforce developers need to adapt to a procurement-driven labor policy.
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What This Bill Actually Does
SB 369 requires that state agencies contracting for Salton Sea restoration projects above a $1,000,000 threshold secure, as part of each covered contract entered on or after January 1, 2026, an enforceable commitment that any work which falls into an apprenticeship occupation in the building and construction trades be performed by a “skilled and trained workforce.” The bill does not create a new statutory definition of that phrase; instead it points to the Public Contract Code definition for what counts as a skilled and trained workforce, tying the requirement into California’s existing apprenticeship framework.
The measure reaches the full contracting chain: it defines “every tier” to include contracts at any level, and explicitly includes contracts for supply and manufacture of off-site aggregate materials used on the project, while excluding transportation services. If a covered project is fully subject to a project labor agreement that already requires a skilled and trained workforce, the statute leaves that project outside the new requirement.
The bill also defines “entity” and the relevant state agencies by cross-reference to existing Labor and Public Contract Code provisions.Legislative findings in the bill frame the requirement as an economic and public-health intervention for Imperial County: the text links the workforce mandate to goals of higher wages, expanded apprenticeship training, better health coverage, and improved safety and quality on restoration projects. Practically, procurement teams will need to update bid documents and contract clauses, and bidders will need systems to demonstrate that their labor force — and labor used by subcontractors and certain material suppliers — meets the apprenticeship-linked definition of “skilled and trained workforce.”
The Five Things You Need to Know
Threshold and effective date: The requirement applies to Salton Sea restoration projects costing more than $1,000,000 and to contracts entered on or after January 1, 2026.
PLA exception: The statute does not apply if all construction work on the project is already covered by a project labor agreement that requires a skilled and trained workforce.
Every-tier reach: “Every tier” includes all contracts at any level to carry out the project and expressly includes contracts for the supply and manufacture of off-site aggregate materials; transportation services are excluded.
Defined cross-references: The bill relies on existing definitions—“entity” from Labor Code §1777.1 and “skilled and trained workforce” from Public Contract Code §2601—rather than creating new statutory definitions.
Scope of covered work: The mandate applies only to work that falls within an apprenticeship occupation in the building and construction trades and to activities defined as Salton Sea restoration (erection, construction, alteration, repair, or improvement of ecosystem structures, buildings, roads, or other improvements).
Section-by-Section Breakdown
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Findings and legislative intent
This opening section lays out the bill’s policy rationale: declining Salton Sea inflows, exposed lakebed and dust concerns, and socioeconomic indicators for Imperial County (low insurance coverage, high poverty, and lower wages). The Legislature ties the workforce requirement to goals of raising wages, expanding apprenticeship training locally, and improving safety and quality on restoration projects. For implementers, these findings signal that workforce development and local economic impact are primary drivers—useful context for interpreting compliance priorities and procurement weighting.
Contract-level requirement for skilled and trained workforce
This is the operative mandate: for projects over $1,000,000 a state agency must obtain, as part of a contract entered on or after January 1, 2026, an enforceable commitment that every bidder and every entity at every tier use a skilled and trained workforce for apprenticeship-occupation work. The phrase “as part of a contract” means the commitment is contractual—procurement documents, bid forms, and subcontracts will need language or clauses that create enforceable obligations on primes and subcontractors.
Project labor agreement exception
The statute creates a clear compliance alternative: if the entire construction work is subject to a project labor agreement that already requires a skilled and trained workforce, the section does not apply. Agencies and contractors will need to assess whether existing or proposed PLAs meet the statutory threshold to avoid duplicative requirements or uncertainty during procurement.
Coverage across the contracting chain and exclusions
Subsection (c) spells out how broadly the rule reaches. It adopts the Labor Code’s definition of “entity” and defines “every tier” to include all contracts—whether negotiated or advertised—at any level, and specifically calls out supply and manufacture contracts for off-site aggregate materials as covered. The explicit exclusion of transportation services narrows the supply-chain reach but creates a practical line agencies must police when drafting scope and solicitation documents.
Agency and term definitions; project scope
The statute names the Natural Resources Agency, Department of Water Resources, and the department (Fish and Wildlife) as the covered state agencies. It also cross-references the Public Contract Code for the definitions of project labor agreement and skilled and trained workforce, and defines “Salton Sea restoration project” to include erection, construction, alteration, repair, or improvement of ecosystem structures, buildings, roads, or other improvements tied to restoration. That means typical construction activities on restoration sites fall squarely within the statute’s scope.
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Who Benefits
- Local apprenticeship programs and training providers in Imperial County — the statute increases projected demand for apprenticeships by channeling state-funded restoration work toward apprenticeship occupations, potentially expanding enrollment and funding opportunities for training organizations.
- Tradespeople and apprentices in the building and construction trades — workers performing apprenticeship-occupation work should see more opportunities for higher-wage, benefits-linked employment that meets the Public Contract Code’s ‘‘skilled and trained workforce’’ standard.
- Local communities around the Salton Sea — the bill is designed to link workforce standards to project quality, safety, and economic investment in a region the Legislature identified as economically disadvantaged.
- Unions and organized labor (where active) — organizations that operate apprenticeship programs and can supply certified apprentices stand to gain leverage and placement opportunities through procurement-driven demand.
Who Bears the Cost
- Prime contractors and subcontractors (including nonunion and small firms) — they must meet the contractual commitment across their subcontracting chain, which could raise labor costs, change hiring practices, or require engagement with apprenticeship programs.
- Manufacturers and suppliers of off-site aggregate materials included in the ‘‘every tier’’ reach — firms that supply or manufacture covered materials may need to demonstrate workforce compliance for the portion of work the statute treats as part of the project.
- State agencies (Natural Resources Agency, DWR, Fish and Wildlife) — procurement, contract management, and compliance units will face additional drafting, monitoring, and enforcement responsibilities with no funding language attached.
- Project budgets and taxpayers — imposing skilled-and-trained workforce standards tends to increase labor costs on public construction, which can raise overall project budgets or reduce the scope of work achievable within existing appropriations.
Key Issues
The Core Tension
The bill attempts to reconcile two legitimate objectives—raising wages, benefits, and apprenticeship opportunities for a disadvantaged region while delivering Salton Sea restoration work efficiently and affordably—by making procurement the lever. That creates a classic trade-off: strict workforce standards help workers and training programs but can increase costs, narrow the pool of eligible contractors, and shift administrative burdens onto agencies and suppliers, potentially slowing restoration work the bill is meant to advance.
The bill ties a procurement-based labor standard to a specific environmental program but leaves significant implementation questions open. It requires an ‘‘enforceable commitment’’ in contract language without prescribing verification, reporting, or penalties; agencies will need to decide how to prove compliance, whether via payroll audits, apprenticeship records, or third-party certification.
That gap creates litigation and administrative risk: contractors may challenge compliance steps as vague or burdensome; agencies could struggle to apply a uniform standard across a complex subcontracting chain.
The statute’s reach into supply and manufacture of off-site aggregate materials broadens traditional labor-focused procurement controls into portions of the supply chain not typically subject to apprenticeship rules, which could disrupt suppliers or incentivize recharacterization of those activities. The PLA exception reduces duplication but raises a secondary question: will agencies prefer PLAs to gain clarity, and if so, how will that affect competition and small-business participation in the region?
Finally, stronger labor requirements will likely increase project costs and could slow procurement cycles—tension with restoration timelines and funding constraints is a realistic implementation risk given the bill includes no budgetary support for compliance oversight.
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