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

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This case is distinguishable from Los Angeles Community College District (1982) PERB Decision No. 252 where the contractual zipper clause did not allow the employer from unilaterally changing shifts without bargaining where the shifts were set forth in the contract. Under the zipper clause, the City is not obligated to negotiate a change in health benefit premiums.