EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Lack of Sufficient Authority

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When ground rules make the parties’ chief spokespersons responsible for coordinating communications between the parties, the chief spokespersons may delegate their responsibilities to others. The union’s chief spokesperson directed another union representative to ask the county when it would implement its LBFO. The county replied, providing an agenda which indicated the county believed the parties were at impasse. The union did not deny receipt of the agenda or dispute the county’s belief that the parties were at impasse. The county reasonably concluded that the union had no further proposals, movement, or a desire to continue negotiations, and properly determined the parties were at impasse.