EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Predictably Unacceptable Offer

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* * * OVERRULED IN PART ON OTHER GROUNDS by Contra Costa Community College District (2019) PERB Decision No. 2652. * * *

One indication of surface bargaining is the making of predictably unacceptable proposals; proposing to eliminate an organizational security clause with which the District had not had problems was predictably unacceptable. Proposing to delete 2 sections from the Hours article over which there had been disagreements was predictably unacceptable; p. 83, proposed decision.