By:  John Phillips and Vanessa Rogers

Seyfarth Synopsis:  The City of Houston is raising the minimum wage for employers with covered contracts, subcontracts, and concession agreements at George Bush Intercontinental Airport, William P. Hobby Airport, and Ellington Airport.  Under Mayor Sylvester Turner’s new executive order, the minimum wage will increase to $13.00/hour on April 1, 2022, $14.00/hour on October 1, 2022, and $15.00/hour on October 1, 2023.

On February 17, 2022, Houston Mayor Sylvester Turner signed an executive order to raise the wages for Houston airport workers to $15.00 per hour by October 1, 2023.  Mayor Turner previously signed a similar executive order in 2019 to raise the minimum wage to $12.00 per hour, and this new executive order replaces the prior one.

The new executive order applies to contractors, subcontractors, and concession agreements involving any city aviation facility, which includes George Bush Intercontinental Airport (IAH), William P. Hobby Airport (HOU), and Ellington Airport (EFD).  Unlike many minimum wage ordinances, the new executive order applies to employees of carriers and employees of concessionaires.  And although not specifically mentioned by name in the order, the executive order’s broad reach means that it also covers janitorial contractor employees and employees covered by collective bargaining agreements.  The executive order will not interfere with the right of an air carrier or a concessionaire, or one of their subcontractors to enter into or adhere to an agreement with a collective bargaining organization, but it will require covered contractors and subcontractors to incorporate the new minimum wage requirements into their city contracts.

As the executive order’s requirements are incorporated into city contracts, covered contractors and subcontractors will be required to pay their employees increased minimum wages, as follows:

  • Currently: $12.00 per hour
  • April 1, 2022: $13.00 per hour
  • October 1, 2022: $14.00 per hour
  • October 1, 2023: $15.00 per hour
  • 2024: As determined by applicable wage rate increase

For tipped employees, these new minimum wages must also be accounted for when applying the tip credit.

Accordingly, employers with city contracts or subcontracts at Houston area airports should review the new executive order and their pay practices, to ensure that they are planning for the new wage increases in the near future.