Good Jobs and the New York City FRESH Program: Evaluation and Recommendations

Executive summary

New York City’s FRESH (Food Retail Expansion to Support Health) program is designed to promote access to healthy foods, particularly in underserved areas, by providing financial and zoning incentives to new grocery stores. This fiscal note brings together a range of qualitative research, analysis, and stakeholder conversations to evaluate the program and propose improvements. In particular, we focus on job quality and community impact.

Section I offers background on FRESH and context for this report. In practice, FRESH refers to two separate programs: a tax incentive program administered by the New York City Industrial Development Agency (IDA), and a zoning incentive program administered by the Department of City Planning (DCP). The IDA program’s tax benefits are substantial, including exemptions to property tax, sales tax, and the mortgage recording tax.

Section II summarizes existing research on programs to improve food access in underserved areas, including FRESH. A variety of studies have emerged in the past decade around these programs’ impact on local food availability, consumption habits, and health outcomes. Both national and FRESH-specific studies provide mixed evidence of program efficacy—at best, they seem to have a small impact on desired outcomes.

Section III reviews the policies and practices of grocery store incentive programs in other cities and states. The comparison reveals a variety of factors which other jurisdictions prioritize when reviewing applications which FRESH currently does not—priorities around collective bargaining, wages, local hiring, sustainability, and more.

Section IV details the program’s geographic reach, applicant selection process, and cost. There is noticeable clustering of FRESH stores in areas of central Brooklyn, northern Manhattan, and the Bronx. The program itself is small, distributing $3-4 million per year in tax breaks.

Section V reviews job quality trends in New York’s retail grocery industry and examines how FRESH-subsidized stores compare to non-subsidized stores. For several decades, unionization in the industry has declined, making jobs more precarious and less desirable. The FRESH program has a mixed record on subsidizing union versus non-union stores. Additionally, the program does not collect detailed information on the wages FRESH recipients pay once operational.

Section VI concludes by offering two strategies to strengthen the FRESH program. The first is to prioritize applicants that meet specific criteria for job quality and community impact. In rough order of importance, these criteria are:

• Labor practices: collective bargaining status, adequate wages, and employee health insurance;
• Local hiring;
• Minority & Women-owned Business Enterprise (M/WBE) ownership; and
• Sustainability and transit access.

In addition, eligibility requirements should be updated to include SNAP, WIC, and other food assistance program participation, along with a cap on nearby grocery store concentration.

The second strategy is to strengthen post-project reviews to ensure stores are accountable for their commitments around wages, health insurance affordability, and job quality.

I. Introduction and context

Food Retail Expansion to Support Health (FRESH) is a tax and land use incentive program intended to bring “healthy and affordable food options to communities by lowering the costs of owning, leasing, developing, and renovating supermarkets.”

FRESH was established in 2009 following a Department of City Planning report which highlighted the “lack of neighborhood grocery stores providing fresh food options in several NYC communities.” Since the program’s inception, at least 53 FRESH stores have opened or are under development.

Functionally, FRESH operates as two separate programs: a tax benefit program administered by the New York City Industrial Development Agency (IDA)—which itself is staffed by and housed within the New York City Economic Development Corporation—and a zoning benefit program administered by the Department of City Planning (DCP).

Program eligibility and benefits

To be eligible for benefits, a store must meet several minimum floor area requirements.^[1] Projects must also be located in designated eligibility areas. Importantly, IDA tax incentive eligibility areas are distinct from—but partially overlap with—DCP zoning incentives eligibility areas. Section IV discusses eligibility zones and the application review process in greater detail.

If approved by IDA, the potential tax benefits for a FRESH project are substantial:

• Land taxes are partially or fully abated for up to 25 years,^[2]
• Building taxes are stabilized at pre-improvement tax amounts for up to 25 years,^[3]
• Sales tax is waived on materials used to construct, renovate, or equip facilities, and
• Mortgage recording tax is reduced from 2.8 percent to 0.3 percent.

FRESH zoning benefits are comparatively minor. Projects located within a FRESH zoning area are allowed additional residential development rights for mixed-use buildings, a reduction in required minimum parking, and larger stores as-of-right in Light Manufacturing (M1) districts.^[4]

Context

The New York City Comptroller is one fifteen members of IDA’s Board of Directors. In this role, the Office has a vote in the Agency’s approval of discretionary tax abatements and subsidies, including those administered under the FRESH program.

In March 2023, the Comptroller’s Office declined to vote in favor of a supermarket subsidy application under the FRESH program, to be located in Kensington, Brooklyn. In part, the vote reflected our belief that the neighborhood was already served by existing quality grocers. Our Office was also concerned that the subsidy, which was for a non-union supermarket, would lead to unfair competition with a unionized supermarket nearby.

Following the vote, we initiated a more comprehensive review of FRESH to understand whether the program meets its goals and consider whether its standards or priorities should be revised.

To this end, our report brings together a range of qualitative research, data analysis, and relevant stakeholder conversations. The report focuses on understanding and improving IDA’s FRESH tax benefit program, but details on DCP’s FRESH zoning program are included for comparison.

II. Relevant studies

The FRESH program aligns with initiatives across the country to increase access to healthy foods in underserved neighborhoods. A variety of studies have examined the extent to which placing a full-service supermarket in a “food desert,” a neighborhood with limited access to fresh produce and other healthy food options, impacts food availability and local dietary habits.^[5] Evidence has been mixed, and even when an effect on these outcomes is observed, it is a small one.

A nationwide review published by the National Bureau of Economic Research, for example, explores local nutritional response to the entry of grocery stores into previously underserved neighborhoods. The authors find that “the healthfulness of household consumption responds minimally to improvements in local retail environments,” and note that geographic access accounts for at most one third of existing socioeconomic disparities in nutritional consumption—likely significantly less.^[6]

At least two studies have sought to evaluate whether FRESH impacts local food availability, consumption habits, and health outcomes. Like nationwide studies of grocery store access programs, they provide mixed evidence of effectiveness.

A 2022 study examines the association between FRESH supermarket subsidies and local childhood obesity. The authors analyze height and weight data of over 50,000 K-12 students. They find that students who resided within 0.5 miles of a FRESH supermarket showed a small but statistically significant decrease in BMI in the 3- to 12-month period after a FRESH store opened, compared with the control group.^[7] They conclude programs like FRESH “may contribute to a small decrease in child obesity risk near those supermarkets, if part of a comprehensive policy approach.”^[8]

A 2015 study of two Bronx neighborhoods, however, found no such effect. The authors compare how household food availability and children’s dietary habits changed in Morrisania, where a FRESH store opened in 2011, relative to trends over the same period in nearby Highbridge, a demographically and socioeconomically similar neighborhood where no new supermarket opened. Using street-intercept surveys and dietary recalls from a large sample of predominantly low-income minorities in each neighborhood, they find that the FRESH store’s opening “did not result in significant changes in household food availability or children’s dietary intake.”^[9]

III. Grocery store incentive programs in other states and cities

Grocery store tax incentive and assistance programs for low-food-access areas are found across the country, including city-level programs in San Francisco and New Orleans; state programs in New Jersey, California, Pennsylvania, Minnesota, and North Dakota; and even a federal program administered by USDA.

These programs vary in the way they prioritize and approve applicants. Some notable factors which different programs incorporate into their evaluation process include:

• SNAP and WIC acceptance: New Jersey, Pennsylvania, Minnesota, and New Orleans all require stores accept benefits from state and federal aid programs, such as SNAP and WIC.
• Labor practices
  • Union labor: New Jersey’s Food Desert Relief Program offers additional tax benefits “if the developer commits that workers at the supermarket will be covered by a Labor Harmony Agreement or collective bargaining agreement.”
  • Prevailing/living wages: New Jersey’s program requires that project construction workers be paid at or above the prevailing wage rate, while Pennsylvania’s Fresh Food Financing Initiative preferences applicants who pay living wages, as determined by M.I.T.’s Living Wage Calculator.
  • M/WBE ownership: Many programs prioritize minority- or women-owned business enterprises (M/WBEs), including those in California, Pennsylvania, and Seattle.
• Local hiring, sourcing, and community support: Pennsylvania’s program gives preference to projects that hire employees “from the surrounding neighborhoods,” source in-state food, and “have a demonstrated history of including local communities and customers into its operations.” New Orleans’ evaluation criteria include whether the project demonstrates support from community groups, and whether they will carry food items produced locally.
• Non-saturation: New Jersey allows no more than two Food Desert Relief Program projects per “food desert community” and the second store sees significantly reduced benefits relative to the first.
• Transit access: Pennsylvania’s program also gives preference to stores which will be accessible via public transportation.
• Sustainability: New Orleans considers whether a project incorporates “environmentally responsible practices,” including site improvements, water conservation, energy efficiency, and use of sustainable materials.

IV. FRESH in practice

This section provides further detail on the operations and economics of the FRESH program, using EDC-provided public data along with qualitative commentary and insights from administrators at IDA, DCP, the Mayor’s Office of Food Policy, and the three largest labor unions representing retail grocery workers in New York City: Local 338 RWDSU/UFCW (the Retail, Wholesale, and Department Store Union, from here on referred to as RWDSU), UFCW Local 1500, and UFCW Local 342.

Eligibility areas and store locations

Chart 1 maps the most recent set of eligibility areas for IDA tax incentives (grey) and DCP zoning incentives (green), along with the location of completed FRESH projects.

Chart 1. FRESH supermarkets and eligibility zones

Source: EDC 2023 data

Subject to City Council’s approval, the Department of City Planning controls zoning incentive eligibility areas, which are delineated at the Community District level. In 2018, the agency developed a “Supermarket Needs Index” to help select eligible community districts based on their supermarket concentration and local population data.^[10],[11] Today, 23 of New York City’s 59 community districts are eligible for FRESH zoning benefits.

FRESH tax incentive eligibility areas are defined differently. The State’s General Municipal Law holds that, for the most part, IDA can only offer incentives to retail projects in “severely distressed” census tracts or their adjacent census tracts.^[12]

The map above shows that to date, FRESH projects have mainly appeared in northern Manhattan, the Bronx, and central Brooklyn, sometimes clustered in close proximity to one another.

As of Fiscal Year 2023, 11 of 27—over 40 percent—of projects receiving tax incentives (red and purple dots) are within a half-mile of another tax incentive-recipient store.

Applicant selection

For zoning benefits, DCP notes that so long as a project is in a zoning eligibility area (and doesn’t violate the saturation provision, described below), FRESH zoning benefits typically function “as close to as-of-right as possible, without actually being so.”

In December 2021, DCP added a saturation provision to FRESH zoning incentives, clarifying that no more than 40,000 square feet of FRESH-benefit grocery stores can exist in a given half-mile radius. IDA, on the other hand, has no saturation provision for tax benefits. Taken together, our Office views this situation as backward—while there is little reason to deny applicants a pro-density zoning bonus, tax subsidies are costly and should be used with clear justification.

IDA does, however, have an established review process for discretionary FRESH benefits. The agency undergoes a two-month due diligence for each applicant, during which they conduct a background check on the company, an environmental impact analysis, a cost-benefit analysis of the project, a project financing review, and an inducement evaluation (i.e., whether the project would not occur but for IDA’s incentives). They note that each year around 25-30 projects reach out about FRESH benefits, of which only a few applications make it before the Board for a final vote.

The agency’s Executive Director stated that while IDA has not instituted a formal saturation provision, they conduct a supermarket concentration analysis for each FRESH project and have turned down past applicants based on proximity to other grocery stores.

When asked what other factors might make IDA reject a FRESH application, they noted that a poor result on the company background check is an automatic disqualifier, as is an inability to demonstrate project financing.

Ultimately, all projects are meant to comply with IDA’s Uniform Tax Exemption Policy (UTEP),^[13] which the agency is required to establish under state law. Broadly, the UTEP specifies factors which IDA must consider before approving a project (job creation, clawback provisions, public support, etc.); establishes procedures for payments in lieu of taxes; describes processes for benefit forfeiture and recapture; and allows IDA to amend any of these policies on its own so long as it gets input from the City and holds a public hearing.

Program cost

A total of 27 grocery stores have benefited from FRESH tax subsidies since the program’s inception.[14]

While FRESH has grown rapidly since the mid-2010s, it remains a small program. Chart 2 shows the annual level of tax expenditures (foregone tax revenue) attributed to the program since FY 2011. Thus far, annual FRESH tax expenditures reached a maximum of $4.0 million in FY 2021.^[15]

Chart 2

Source: EDC data
Note: Total tax expenditures sums property tax exemptions (less payments-in-lieu-of-taxes, or “PILOTs”), mortgage recording tax savings, and sales tax savings on materials used for construction.

The vast majority of FRESH tax benefits come in the form of property tax reductions. These account for $25.3 million (or 87 percent) of the total $29.2 million in tax expenditures through FY 2023. This breakdown is relatively consistent across individual projects.

V. Job quality

New York City’s grocery store industry has undergone significant changes over the past several decades. Once considered a reliable pathway to middle-class stability, a decline in unionization, real wages, and access to affordable health insurance has greatly reduced the desirability of retail grocery work both within New York City and nationwide. This section reviews job quality in New York City’s retail grocery sector and compares how FRESH-subsidized stores fare against non-subsidized stores.

Job quality in NYC’s grocery store industry

Data from the Census Bureau’s American Community Survey (ACS) suggests New York City had 40,100 grocery store floor workers in 2022, 63 percent of whom worked full time. The city had another 8,866 first-line grocery store supervisors, 88 percent of whom worked full time.^[16]

The estimated median wage for grocery store floor workers was $15.25 per hour—just above the City’s $15.00 per hour minimum wage in 2022.^[17] The estimated median wage of first-line supervisors of floor workers was $22.73 per hour. Among non-grocery workers in New York City, the median wage was $28.85 per hour.

Only 46 percent of full-time grocery store workers (both floor and first-line supervisors) in New York City reported receiving health insurance through an employer, compared with 74 percent of other full-time New York City workers.^[18]

Research from CUNY’s School of Labor and Urban Studies (SLU) highlights that in past decades, retail grocery work provided a solid middle-class income along with “excellent benefits,” including affordable health insurance and defined benefit pension plans. This was in large part a result of widespread unionization in the industry. In the 1960s, about 40 percent of all U.S. food store workers were unionized. In New York City, that figure was “by all accounts far greater.”

Unions play a critical role in promoting job quality for New York City’s food store workers. A director from the Retail, Wholesale, and Department Store Union (RWDSU), one of the city’s unions representing grocery store workers, outlined the extensive advantages of union representation: affordable health insurance, retirement benefits, guaranteed wage increases, scheduling protections, and grievance procedures, among others—all of which are absent or significantly weaker in non-unionized grocery stores.

Beginning in the 1990s, however, a wave of corporate consolidation and financialization has characterized the U.S. supermarket industry, dealing a major blow to its union density. According to SLU, by 2019 less than 20 percent of retail grocery store workers in the New York metropolitan area were unionized.

Job quality and FRESH

As a tax incentive program, we believe FRESH should support businesses which commit to providing well-paid, high-quality jobs in their community. In the retail grocery industry, this generally means supporting unionized shops. At the very least, the program should avoid granting tax subsidies which would provide non-union grocery stores an unfair competitive advantage over pre-existing unionized stores.

When evaluating a FRESH application, IDA does not consider whether the store will operate under a collective bargaining agreement. Chart 3 shows the union status as well as total FRESH tax benefits received to date among the program’s large chain recipients. To the program’s credit, two of its largest beneficiary brands—ShopRite and Food Bazaar—are unionized across the board.

On the other hand, as a representative from RWDSU informed us, Western Beef has a reputation for being strongly anti-union. “We actually had an organizer be physically intimidated by management at a shop on Long Island,” they said.

At Key Food, C-Town, and FoodTown stores—all of which operate under franchise models—union status depends on the individual owner. An additional eight brands, consisting of small chains and independent stores, are not depicted on the chart, as their union status is not publicly available.

Of the 1,869 full-time-equivalent jobs that FRESH tax benefit recipients reported at their stores in Fiscal Year 2023, 63 percent were at unionized ShopRite or Food Bazaar.[19] 13 percent were at Western Beef, a known anti-union employer. The remaining 24 percent—representing 11 brands—were in shops of mixed or unknown union status. In their own review of the FRESH program, RWDSU found that to date, “a majority of FRESH recipients have been non-union operators”—a finding that makes sense considering most small or independent grocery businesses tend to be non-union.

Chart 3

Source: EDC, UFCW-RWDSU Local 338
Note: “Parent organization” refers to both single business entities as well as retailer cooperatives and store brands operating under a franchise model. We define “large chains” as parent organizations with at least 10 locations in New York City (including non-FRESH stores).^[20]

IDA does not set a specific wage threshold for stores to receive tax benefits. One of the challenges, the agency indicated, is that wages of grocery store workers are generally low. However, if the store will not offer employee health insurance, IDA looks for some kind of “wage bump” to make up for this, though they did not offer a specific figure on how large a bump is needed.

An RWDSU director expressed concern that the FRESH program lacks sufficient transparency and accountability on job quality. They noted that the City’s Economic Development Corporation (EDC), which houses IDA, does not collect wage breakdowns by job title at proposed FRESH stores. Additionally, they stated, “to our knowledge EDC has never done a follow-up/audit to review the quality of employment once FRESH recipients are open and operational.”

VI. Recommendations

To maximize its impact as a community and economic development program, FRESH should promote access to both healthy food and good jobs within underserved communities. To achieve this, we propose two key strategies: first, prioritizing applicants that meet specific criteria for job quality and community impact; second, conducting more thorough post-project reviews to ensure stores deliver on their commitments around wages, job quality, and net job creation.

Project prioritization and eligibility

Below are key factors which IDA and its Board should consider when deciding whether to move forward with a FRESH tax incentive applicant, in rough order of importance:

1. Labor practices
   1. Collective bargaining agreements: Prioritize stores which commit that workers will be covered by a collective bargaining agreement. This will help ensure that the program does not inadvertently subsidize non-union stores at the expense of union labor, and that FRESH stores bring good jobs to their communities.[21]
   2. Wage commitments: Give preference to applicants who pay competitive wages relative to the industry average. Establish a minimum wage and benefit standard which is in line with what comparable employees could expect at a unionized grocery store.
   3. Health insurance affordability commitments: Favor applicants who plan to offer health insurance to all hires, including part-time hires, at affordable premiums.
2. Local hiring: Give preference to businesses that actively contribute to local employment opportunities, reinforcing their role in community development.
3. M/WBE ownership: Prioritize minority- and women-owned business enterprises, especially if owners are local to the community.
4. Sustainability and transit access: Promote businesses that actively contribute to environmental and sustainability goals. In addition, favor locations that are more easily accessible by public transit to reduce environmental impact and increase access for non-car-owning households.

In addition, the following criteria should be added to baseline eligibility requirements:

1. Participation in SNAP, WIC, and other food assistance programs: Considering FRESH tax benefits are meant to benefit food-insecure communities, and SNAP and WIC recipients tend to be among the most food-insecure, participation in these programs should be non-negotiable. IDA notes that most FRESH projects currently participate in these programs.
2. Concentration of nearby grocery stores: Adopt a grocery store “saturation threshold” beyond which FRESH tax benefits will not be approved. For example, the DCP zoning benefits program stipulates that no more than 40,000 square feet of FRESH-benefitting grocery space can exist in a given half-mile radius. New Jersey allows no more than two Food Desert Relief Program projects per “food desert community.”

Enhanced post-project reviews

As required by local law, the New York City Economic Development Corporation (EDC), which oversees IDA, produces an Annual Investment Projects Report which provides a set of baseline information on projects receiving City financial assistance. The report includes detail on the scale and form of financial assistance for each project, as well as company-reported data on jobs created and retained.

However, as a representative from RWDSU noted, these reporting requirements lack the level of detail necessary to understand true employment quality at FRESH-subsidized stores.

One key concern is wages. Companies benefitting from EDC tax subsidies must report the number of employees earning below New York City’s living wage rate. But the legal living wage currently sits below the city’s $16.00 minimum wage, at only $15.85 per hour including supplemental benefits. Using such data to suggest that 100 percent of retail jobs at FRESH projects “earn a living wage or more” is therefore unhelpful and potentially misleading. EDC should instead request information on stores’ actual wages broken down by job title.

As a best practice, City tax subsidy recipients, including FRESH projects, should be required to report on certain indicators of job quality. They should note their union status, as well as if any violations of workplace protection laws have been reported.

While companies already report whether they offer employee health insurance, they should also disclose the affordability of these plans—a frequent concern in the retail grocery industry, especially among non-unionized shops.

Ultimately, EDC should implement a standardized review process to evaluate employment quality after FRESH recipients become operational. The process should specify criteria for suspension or even repayment of tax benefits if basic job quality standards are not met. Such reviews would be critical to understanding the true impact of these subsidies, particularly on workforce outcomes.

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Endnotes 

[1] Floor area requirements for FRESH eligibility include at least 6,000 square feet dedicated to a general line of food and other grocery products; at least 50 percent of that selling area used for the sale of a “general line of food products;” and at least 30 percent of the area set aside for perishable goods specifically, of which 500 square feet must be used for fresh meat, fruit, and vegetable

[2] The full value of the land tax is abated if a FRESH project is located within a New York City Empire Zone or Empowerment Zone. Otherwise, the land tax abatement equals $500 multiplied by each full-time equivalent employee at the time of application. Land tax benefits are phased out at 20 percent per year, beginning in year 21.

[3] Building tax benefits are phased out at 20 percent per year, beginning in year 21.

[4] FRESH zoning incentives allow one additional square foot of residential floor area in mixed-use buildings for every square foot of grocery store, up to a 20,000 square foot limit; no required parking for stores up to 40,000 square feet in commercial districts that permit residential buildings with ground floor retail; and the first 15,000 square feet of grocery retail space exempt from parking in other Commercial and Light Manufacturing districts.

[5] Unlike in the cited academic literature, neither the NYC Economic Development Corporation nor the Department of City Planning use the term “food desert” in relation to FRESH. Rather, FRESH aims to promote “accessible grocery stores in underserved neighborhoods.” Partly as a result of its density, virtually nowhere in New York City meets the U.S. Department of Agriculture’s criteria for classification as a food desert. In recent years, various public entities and nonprofits have advocated to move away from the term “food desert” altogether.

[6] Handbury, Rahkovsky, and Schnell: Is the Focus on Food Deserts Fruitless? Retail Access and Food Purchases Across the Socioeconomic Spectrum (2015). http://www.nber.org/papers/w21126

[7] The study’s treatment group consisted of students residing within 0.5 miles of a FRESH-subsidized supermarket, while the control group consisted of students residing beyond 0.5 miles of a FRESH store, but still in a FRESH-eligible area.

[8] Rummo, Sze, and Elbel: Association Between a Policy to Subsidize Supermarkets in Underserved Areas and Childhood Obesity Risk (2022). https://jamanetwork.com/journals/jamapediatrics/fullarticle/2792042

[9] Elbel et al.: Assessment of a government-subsidized supermarket in a high-need area on household food availability and children’s dietary intakes (2015). https://www.cambridge.org/core/journals/public-health-nutrition/article/assessment-of-a-governmentsubsidized-supermarket-in-a-highneed-area-on-household-food-availability-and-childrens-dietary-intakes/C998CF42FACEDADAE59D906CE63D04B7#figures

[10] DCP’s 2018 Supermarket Needs Index considered neighborhoods’ supermarket square footage per resident, along with local car ownership and child poverty levels. In addition, several eligible areas were selected based on input from local elected officials. Note the Supermarket Needs Index was a one-time analysis. For a map of the 2018 index, see the “Areas of Applicability” section on DCP’s FRESH landing page.

[11] DCP defines “supermarkets” as stores over 5,000 square feet whose primary purpose is the sale of food for consumption at home, thereby excluding bodegas, convenience stores, and small specialty or ethnic food stores.

[12] The U.S. Census Bureau determines the qualification criteria for severely distressed census tracts (SDCTs). IDA refreshes the list of eligible tracts annually based on the latest 5-year ACS survey. Outside of being located in, or adjacent to, an SDCT, projects can receive IDA benefits if they demonstrate that their project will bring a significant benefit to a community or a significant influx of tourist dollars—the latter of which is not relevant to FRESH.

[13] For more detail on UTEP, see IDA’s policy document.

[14] One more tax-subsidized project, a Western Beef located in the Bronx, had its agreement with NYCIDA terminated in FY 2022 and repaid the benefits it received.

[15] Total tax expenditures sums property tax exemptions (less PILOT payments), mortgage recording tax savings, and sales tax savings on materials used for construction.

[16] Analysis was conducted on workers employed in “supermarkets and other grocery (except convenience) stores” (NAICS code 44511) within New York City, regardless of place of residence. We define “floor workers” as workers within this industry employed under the following occupations (in order of most to least frequent): cashiers; food preparation workers; customer service representatives; butchers and other meat, poultry, and fish processing workers; janitors and building cleaners; fast food and counter workers; retail salespersons; cooks; bakers; dishwashers; non-restaurant food servers; and chefs and head cooks.

[17] To estimate workers’ hourly wages, we divided their annual wage income by their estimated total hours worked per year, both of which are self-reported in the American Community Survey.

[18] Per the American Community Survey’s questionnaire text, this figure includes those insured by another family member’s employer. Thus, for both grocery and non-grocery workers, it is an overestimate of the proportion who are insured via their own employer. Health insurance via one’s union or a family member’s union is also included in this figure, as is insurance through former employers.

[19] EDC defines full-time-equivalent jobs as the number of full-time jobs plus half the number of part-time jobs.

[20] Ideal Food Basket, which meets the criteria and has one FRESH-subsidized store, is excluded from the chart as its union status is not publicly available.

[21] City law currently requires that retail or food service establishments that receive over $500,000 in financial assistance from the City enter into a “labor peace agreement” (LPA) in the event of a unionization drive. An LPA stipulates that the employer will not interfere with unionization efforts, while the labor organization seeking to represent the employees will refrain from any kind of work stoppages.