EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES – Waiver by Union; Contract Waivers; Bargaining History Estoppel; Disclaimer; Supersession

Single Topic for Decision 0860E

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Board affirmed ALJ finding that contract wage rate provision did not apply to particular after-school program which had a distinct academic focus, in addition to a counseling and advising focus; thus, District made unlawful unilateral change when it selected a wage rate for the program; pp. 4-6; pp. 18-20, proposed dec.