EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Failure to Sunshine Proposals

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Public notice complaints may not be adjudicated in the context of unfair practice proceedings, but compliance with public notice requirements is a factor that may be considered in evaluating bargaining conduct; here, even if employer failed to comply with requirements, there was no evidence that it was intended to have, or in fact had, any impact on negotiations; pp. 32-35, proposed dec.