EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION) – Change in Past Practice

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MOU did not establish a written agreement to pay the same amount for retiree health insurance benefits as employer pays for current bargaining unit employees. Where evidence failed to establish that employer had an unequivocal, clearly enunciated and acted upon, and readily ascertainable past practice, accepted by both parties, of linking retiree health insurance benefits to the benefits received by current bargaining unit employees, charging party did not met its burden of proving a unilateral change in an established past practice, and prima facie case of unlawful unilateral change was not established.