For more than 30 years, the PERS has consistently maintained that employment is not part-time merely because it is seasonal or temporary. The interpretation of a statute by an administrative agency charged with its enforcement and construction is entitled to great weight unless clearly erroneous or unauthorized. Its first position is the more correct one. Therefore, the criterion of working 1,000 hours minimum does not apply. Under all of the circumstances herein, particularly the propriety of deferring to CalPERS in its interpretation of section 20305 and application of that interpretation to Ms. San Pedro, and that such application is not disallowed by the language of the statute, CalPERS is correct in its determination that Ms. San Pedro is entitled to membership.
All statutory references are to the Government Code.
In other ways, the Policy Manual does not appear to be helpful because it may not comport with the statute. The Policy Manual also requires the employer to fill in information, such as permanent or temporary, which is not required by the statute.