EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Time Limit on Negotiations

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PERB addressed open questions regarding how to apply provisions of facially valid San Francisco City Charter when the parties approach Charter-mandated submission deadline but have not had enough time to complete good faith negotiations. PERB upheld union’s as-applied challenge to provisions of the San Francisco City Charter where union demonstrated that there was insufficient time for good faith negotiations and/or to reach a legitimate impasse prior to Charter-imposed submission deadline.