REPRESENTATION ISSUES; UNIT MODIFICATION – In General

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County local rules tracked settled precedent by repeatedly referencing the need to determine the broadest feasible group based on community of interest, and to avoid fragmentation of units. (See, e.g., County of Santa Clara (2019) PERB Decision No. 2670-M, p. 19 [“[P]ublic sector bargaining units may require modification to avoid fragmentation and ensure operational efficiency”].) Because “[t]he foundation of public sector labor relations is to protect employees’ right to representation and to balance those rights with public employers’ interest in maintaining operational efficiency . . . [PERB] generally seek[s] to avoid the fragmentation of employee groups and proliferation of bargaining units.” (Id. at p. 27 & fn. 25; Regents of the University of California (2017) PERB Order No. Ad-453-H, pp. 23-24.) (p. 11.)