Well, we should look at the Employee Handbook. The Handbook says schedules for the breaks should "depend on the needs of each office."

Regardless, whether taken at the same time as the unpaid half hour lunch or not, the two paid breaks should have no impact on what OPA pays the employee. The GM says otherwise. I cannot obtain a clarification from OPA. Below is the wording from the Handbook. Can you explain to me where if the breaks are taken in the morning and afternoon, or all combined with the lunch break, how either approach impacts what OPA pays the employee or the hours worked?

The GM states it does. He wrote: "While there is no change to the existing break policy, we are addressing how it is implemented.  The change has been done partly to bring uniformity to our processes.  Furthermore, and specifically, the problem that we are solving is that a limited number of full-time hourly employees were taking their breaks in conjunction with their lunch break; thus, they were taking an hour off for lunch and the association was paying them for 40 hours when they were only working 37.5 hours.  By discontinuing that practice, the association will gain productivity and “recover” significant wages.  There is no change to the formal break policy; if an employee needs a break, they are certainly allowed to take it."  

From the Handbook:

Employees that work an 8 hour day are allowed an unpaid 30-minute lunch break. Lunch breaks are generally taken between the hours of 11:30 am and 2:00 pm. The schedule for meal periods should be established on the basis of work requirements in each office. Staggered meal periods may be necessary in customer service locations. Supervisors should be sure that each location is adequately staffed and that someone with authority to resolve minor problems is available at all times.
Two paid rest periods of 15 minutes each should be permitted each day. The schedule for these breaks should depend completely on the needs of each office. Rest periods are considered time worked, and employees will receive compensation for such periods. Employees that work less than a 7 hour day should check with their department about lunch breaks and rest periods.