EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Inflexible Position

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Employer's refusal to present counterproposal on subject of notice for layoffs does not constitute bad faith bargaining. Nothing in EERA requires parties to reach agreement or make concessions on every proposal. Adamant insistence on a bargaining position is not necessarily a refusal to negotiate in good faith. Employer's conduct is lawful hard bargaining.