Community College District 3 (Olympic)(Washington Public Employees
Association), Decision 9486 (PSRA, 2006)
STATE OF WASHINGTON
BEFORE THE PUBLIC EMPLOYMENT RELATIONS COMMISSION
COMMUNITY COLLEGE DISTRICT 3 )
(OLYMPIC), )
) CASE DECISION
Employer. ) 19128-U-05-4862 9486 - PSRA
------------------------------) 19136-U-05-4863 8899-A - PSRA
JAMES STUART, DAVID ) 19157-U-05-4869 8900-A - PSRA
BARTELHEIM, JEANNE GARDNER, ) 19158-U-05-4870 8901-A - PSRA
CATHRYN GRAY, WILLIAM OLDMAN, ) 19159-U-05-4871 8902-A - PSRA
SHIRLEE WILFORD AND ) 19204-U-05-4880 9487 - PSRA
JACQUELINE BAKER ) 19214-U-05-4883 9488 - PSRA
)
Complainants, )
)
vs. )
)
WASHINGTON PUBLIC EMPLOYEES ) CONSOLIDATED
ASSOCIATION, UFCW LOCAL 365 ) FINDINGS OF FACT,
) CONCLUSIONS OF LAW,
Respondent. ) AND ORDER
______________________________)
The employer did not appear.
Schwerin Campbell Barnard LLP, by Lawrence Schwerin, Attorney,
for the union.
James Stuart, David Bartelheim, Jeanne Gardner, Cathryn Gray,
William Holdman, Shirlee Wilford, and Jacqueline Baker,
appeared on their own behalf.
Between January 18 and February 18, 2005, James Stuart, David
Bartelheim, Jeanne Gardner, Cathryn Gray, William Holdman, Shirlee
Wilford, and Jacqueline Baker (complainants) filed separate
complaints charging unfair labor practices, naming Washington Public
Employees Association, UFCW Local 365 (union) as respondent.
Complainants Bartelheim and Wilford occupy positions in a
supervisory classified bargaining unit at Community College District
3, also known as Olympic Community College (employer), which
operates an institution of higher education; the remaining
complainants occupy positions in a non-supervisory bargaining unit
therein. The complaints concern an alleged failure to notify
bargaining unit members adequately of their right to vote on a
proposed collective bargaining agreement.
On March 29, 2005, agency staff consolidated these cases and found
that the complaints stated causes of action based on allegations
that the union had failed to provide adequate notice to allow all
bargaining unit employees to participate in a contract ratification
vote; misrepresented that employees had to join the union to be
eligible to vote, and had failed to include the union security
clause in a summary of the new contract. Examiner Carlos R.
Carrion-Crespo held a hearing on October 5 and 6, 2005. The parties
submitted post-hearing briefs.
ISSUES PRESENTED
1. Does the Commission have jurisdiction over these complaints
concerning notice and opportunity to vote on the ratification
of these particular collective bargaining agreements?
2. If the Commission has jurisdiction, did the WPEA fail to
fulfill its duty of fair representation by failing to provide
adequate notice and opportunity to vote in the ratification
election?
3. If the Commission has jurisdiction, did the WPEA fail to
fulfill its duty of fair representation by failing to include
the union security clause in a summary of the new contract?
The Examiner rules that the Commission has jurisdiction to
adjudicate claims asserting breach of the duty of fair
representation owed by unions to all bargaining unit employees, with
respect to situations where a union agrees to allow all bargaining
unit employees to vote on ratification of a collective bargaining
agreement. The Examiner finds that the union breached its duty of
fair representation by its conduct during the ratification of the
2005-2007 collective bargaining agreement at Olympic Community
College, but did not fail to include the union security clause in a
summary of the new contract.
ANALYSIS
Issue 1: Does the Commission have jurisdiction over these complaints?
On September 17, 2004, the union and the employer concluded
negotiations for a collective bargaining agreement which covering
the period from July 1, 2005, to June 30, 2007. It included a
memorandum of agreement which specified that "the Union agrees that
ratification votes will be taken by institution, and that all
bargaining unit employees will be allowed the opportunity to vote."
The agreement did not specify the voting process or procedures
(including notification) that the union would follow. Other than
agreeing that the union would allow all bargaining unit members the
opportunity to vote, there were no other discussions on the matter.
The complainants are bargaining unit members who have not joined the
union, but pay the union a representation fee under RCW
41.80.100(1). The complainants allege that the union did not notify
them adequately of their right to vote in the election that the
union conducted on September 25, 2004, to ratify the two-year
collective bargaining agreement.
An agreement to allow all bargaining unit members the opportunity to
vote exposes the union that signs it to scrutiny regarding any
allegation that it restrained employees from the right to vote
granted to them by the agreement. Community College 19 (Columbia
Basin) (Washington Public Employees Association), Decision 9210-A
(PSRA, June 20, 2006). The aforementioned "memorandum of agreement"
created voting rights for employees who have not joined the union
and obligated the union to provide fair representation to them in
the ratification process. Therefore, the Commission has
jurisdiction in this case to determine whether the union restrained
employees in the exercise of rights protected by RCW 41.80.050 and
RCW 41.80.080(3), in violation of RCW 41.80.110(2)(a). Community
College 19 (Columbia Basin) (Washington Public Employees
Association), Decision 9210-A.
Issue 2: Did the WPEA fail to provide adequate notice and
opportunity to vote in the ratification election?
If the terms of a contract require that all affected employees
ratify it, a union breaches its duty of fair representation if it
fails to submit the contract to a meaningful vote of those
employees. Once the union agrees in collective bargaining to allow
all bargaining unit employees the opportunity to vote, it had an
obligation to unambiguously notify all employees of their rights.
Community College 7 (Shoreline) (Washington Federation of State
Employees), Decision 9094-A (PSRA, June 20, 2006). A union must
treat all factions and segments of the bargaining unit without
hostility or discrimination, exercise its discretion to assert the
rights of individual members in good faith and honesty, and avoid
arbitrary conduct. The legislative mandate to submit collective
bargaining agreements to the legislature for funding by October 1,
2004, does not allow parties to circumvent the other
responsibilities that Chapter 41.80 RCW imposes. The complainant
who alleges that the union failed to meet its duty of fair
representation must show:
[T]hat the union behaved irrationally, invidiously,
fraudulently, deceitfully, dishonestly, or indifferently as to
the rights of bargaining unit employees, or that the union's
conduct was so grossly deficient as to be properly equated with
arbitrary action. The complainant must also demonstrate a
causal nexus between the breach of the union's duty of fair
representation and the harm suffered by the employee.
Community College 19 (Columbia Basin) (Washington Public Employees
Association), Decision 9210-A. Thus, the complainants in this case
will succeed if they prove indifference on the part of the union,
that is, "no interest, concern, or feeling." Webster's New World
Dictionary 716 (2d College ed. 1976). The results of such a
ratification vote will be annulled if they demonstrate that they
could have affected the outcome of the ratification election.
Community College 19 (Columbia Basin) (Washington Public Employees
Association), Decision 9210-A.
The complainants maintain that the union did not notify them
adequately of the vote. They testified that they did not receive
notice of the vote and that they do not routinely search for union
information in bulletin boards, that they did not receive the
electronic message that the union sent, and that the message
incorrectly stated that bargaining unit members had to pay union
dues if they wished to vote. The complainants expressed frustration
that the union did not identify its bulletin boards clearly and did
not use the postal service and flyers to inform them about the
process, like the union had done when it held a vote to approve a
union security clause 10 or 15 years ago. They also state that many
employees did not have access to a personal computer with which to
search for the union's internet website and that the voting place
and date was not published on the website until four days before the
vote. Lastly, they point out that holding the vote on a Saturday
afternoon excluded most employees. Their claim rests mainly on the
lack of adequate information on the ratification process, not on the
union's insistence on membership before voting.
The record demonstrates the union's actions and inactions concerning
the ratification of the 2005-2007 contract at Columbia Basin
Community College precluded the complainants from having a
meaningful opportunity to vote on ratification of the contract. The
following summarizes the efforts that the union made to notify
bargaining unit members of the ratification vote.
On September 18, 2005, the union sent an electronic message to some
bargaining unit members which announced that the parties had reached
a tentative agreement, summarized some economic provisions, and
directed readers to the union's website. The message also announced
that an information meeting would take place on September 21, 2005,
a ratification vote would occur the following weekend, and both
would take place in undetermined locations. It also advised readers
that the contract would establish a "closed shop," and that
"[c]lassified staff not a member [sic] of the union who wish to vote
may do so by submitting a green card (membership application) with 1
month membership dues ($32) at the voting location." The union was
aware that the employer's electronic mail system did not deliver
messages to all of the bargaining unit employees. As a result, the
system did not transmit the message to all of the employees of the
bargaining unit.
Although the membership requirement to vote was contrary to the
"memorandum of agreement," the union attributes the incorrect
information to a union secretary who had apparently presumed that
only members would vote to ratify the contract, as had occurred in
several contracts signed under the preceding statute. The union was
not responsible for the distribution deficiency and sent the message
the day after the parties reached a tentative agreement, which
distinguishes this set of facts from those in Community College 7
(Shoreline)(Washington Federation of State Employees), Decision
9094-A (PSRA, June 20, 2006).(fn:1) However, the union relied
erroneously on the employer's communications method, which the union
did not control, and communicated mistaken information which the
union had to correct through affirmative action.
____________________
fn:1 In Shoreline, employees had to register on a mailing list
affirmatively and voluntarily in order to receive updates sent
through that method of communication; also, the union "wasted" a
week, in the Commission's words, waiting to get employer
authorization before sending an electronic message to employees.
On September 20, 2004, the union placed the draft agreement and the
"memorandum of agreement" on its website. It included a notice
announcing the schedule of the ratification vote, which stated that
"All WPEA bargaining unit members have an opportunity to vote on
ratifying the contract that pertains to your work group at one of
the following polling sites . . . " All voting would take place on
Saturday, September 25, 2004, and Sunday, September 26, 2004. The
voting in Olympic College would take place on September 25, 2004,
from 3:00 P.M. to 6:00 P.M. at the Bremer Student Center. However,
every bargaining unit member could vote in any polling site. The
locations and times were subject to change, and the document
directed bargaining unit members to check for changes on Friday,
September 24, 2004.
On September 21, the union held a meeting with bargaining unit
members in which union officials discussed the tentative agreement,
including the union security clause and pointed out that all
bargaining unit members would have an opportunity to vote on the
contract. Between 15 and 20 persons attended the meeting, out of
more than 140 members of the bargaining units.
On September 23, 2004, the union restated an earlier announcement
that it would hold the ratification vote on September 25, through
notices posted in bulletin boards on the first floor of the College
Service Center building, in the Bremer Student Service Center
building, and in the mail center located in the Facilities Service
Center Building. The union assumed that all employees would be
aware of the effects of the PSRA, that all employees would look at
the bulletin boards, and that bargaining unit members would know
about the date and place of the vote through word of mouth. Also on
September 23, the union sent an electronic message to union members
with the same content, plus an introductory paragraph which
announced the opportunity to vote and encouraged employees to join
the union.
On Saturday, September 25, 2004, from 3:00 P.M. until 6:00 P.M., the
union conducted an election for all bargaining unit employees to
vote on whether they accepted or rejected the tentative agreement in
the Bremer Student Center in Olympic College. The record does not
show whether the members of the supervisory and non-supervisory
bargaining units voted separately. Only 24 bargaining unit
employees voted. The complainants did not vote.
Contrary to the complainants' allegations, the Examiner will not
infer that the union was negligent by holding the election on a
Saturday, because such a date avoided restrictions based on work
schedule. Neither will the Examiner evaluate what the union could
have done, but only whether its efforts showed that it was not
indifferent to the rights of the complainants.
It is evident that the union was unable to meet the goal of
mobilizing a large number of bargaining unit members to vote. The
union's efforts were more extensive than what the Commission
described in Community College 19 (Columbia Basin) (Washington
Public Employees Association), Decision 9210-A and Community College
7 (Shoreline)(Washington Federation of State Employees), Decision
9094-A, but they could not reach enough bargaining unit members to
include the complainants. The one electronic message that could
have reached many bargaining unit members did not reach the
complainants and contained misleading information on eligibility to
vote, which the union did not correct in another electronic message.
The union used two other methods of communication and stated
unambiguously that all bargaining unit employees regardless of union
membership were eligible to vote on ratification of the contract.
However, the union could not reasonably expect that any of these
methods would reach bargaining unit employees who received the
incorrect information contained in the September 18 electronic
message, or who otherwise were accustomed to the previous practice
of allowing only members of the union to vote. The union assumed at
its own peril that "word of mouth" would reach the targeted
audience, and its assumption did not prove true. In conclusion, the
union's means were so deficient as to signal that the union had no
real interest in promoting the rights of the complainants. This
finding meets the "indifference" standard set by the Commission.
The crucial element in this conclusion is that the union had an
obligation to let each bargaining unit member, including the eight
complainants, know that the terms of the agreement with the employer
provided them an opportunity to vote on the contract. This was
particularly true in this case because this right represented an
abrupt change in past practice. The complainants showed that the
union was indifferent to this obligation, and thus discharged their
burden of proof. The union committed the unfair labor practice
alleged in the complaint.
Issue 3: Did the union fail to include the union security clause in
a summary of the new contract?
The tentative agreement signed on September 17 contained a "union
security" provision, which required employees to pay an agency shop
fee to the exclusive bargaining representative, as RCW 41.80.100
allows. The union had the duty to inform bargaining unit members of
this fact because it represented a new element in collective
bargaining.(fn:2) The complainants allege that the overview of the
contract that was published on the union's website on September 20
did not include the union security clause. However, it was
discussed at the top of the fourth page of the document. Therefore,
the evidence does not sustain the allegation.
____________________
fn:2 The union had attempted to organize a separate vote for union
security under case number 18580-R-04-0225. However, the petition
was filed too late for the Commission to comply with legal
requirements before the statutory deadline.
Remedies
The fashioning of remedies is a discretionary action of the
Commission, based on a liberal construction of the statute to
accomplish its purpose. The Commission has the remedial powers
which may be necessary to effectuate the purposes of the collective
bargaining statute to make the Commission's lawful orders effective.
The Commission will not relieve complainants of their union
security obligation nor order a second ratification election unless
the complainants show that they could have affected the outcome of
the election, because such a remedy "would allow numerous other
individuals who did not file complaints to benefit from the efforts
of these two complainants." Community College 19 (Columbia Basin)
(Washington Public Employees Association), Decision 9210-A.
This Examiner directs the union to cease and desist from failing to
properly notify the complainants and all bargaining unit employees
of their contract ratification rights. The Examiner also directs
the union to read into the record at its next state-wide convention
the attached notice and to permanently append such notice to the
official minutes of that meeting. Additionally, the union shall
publish a copy of the notice in its next issue of the "WPEA Sentinel."
However, the complainants did not present evidence regarding the
results of the ratification election, and thus the record does not
show that they could have affected its outcome. Given this fact and
that they continue to benefit from the negotiated contract, this
Examiner declines the complainants' requests to vacate the result of
the ratification vote and to relieve them of their union security
obligation.
FINDINGS OF FACT
1. Community College District 3, also known as Olympic College, is
an institution of higher education of the state of Washington
within the meaning of RCW 41.80.005(10).
2. The Washington Public Employees Association, an employee
organization within the meaning of RCW 41.80.005(7), is the
exclusive bargaining representative for all supervisory and
non-supervisory classified employees and is the exclusive
bargaining representative for two classified bargaining units
certified by the Public Employment Relations Commission at
Olympic Community College, which at all pertinent times
included more than 140 members.
3. James Stuart, Jeanne Gardner, Cathryn Gray, William Holdman,
and Jacqueline Baker occupy positions in a non-supervisory
bargaining unit at Olympic Community College, have not joined
the Washington Public Employees Association, and are
complainants in five of the present cases.
4. David Bartelheim and Shirlee Wilford occupy positions in the
supervisory bargaining unit at Olympic Community College, have
not joined the Washington Public Employees Association, and are
complainants in two of the present cases.
5. Olympic Community College and the Washington Public Employees
Association are parties to a collective bargaining agreement
covering all bargaining units certified by the Public
Employment Relations Commission at Olympic Community College,
with an effective date of July 1, 2005, through June 30, 2007.
6. On September 17, 2004, the Washington Public Employees
Association and the State of Washington reached a tentative
agreement on the collective bargaining agreement described in
paragraph 5 of these findings of fact, under the Personnel
System Reform Act, Chapter 41.80 RCW. The agreement included a
"memorandum of understanding" that would allow all bargaining
unit employees to vote to accept or reject the tentative
agreement, regardless of affiliation with the Washington Public
Employees Association.
7. The memorandum of understanding described in paragraph 6 of
these findings of fact did not specify the voting process or
procedures (including notification) that the Washington Public
Employees Association would follow.
8. On September 18, 2004, the union notified members of the
bargaining unit through the Olympic Community College's
electronic mail system that they would have the opportunity to
vote and directed them to the union website for more
information.
9. The Olympic Community College's electronic mail system that the
Washington Public Employees Association used on September 18,
2004, did not transmit messages to all of the members of the
bargaining unit. For that reason, the message described in
paragraph 8 of these findings of fact did not reach any of the
complainants.
10. On September 20, 2004, the Washington Public Employees
Association placed a copy of the tentative agreement described
in paragraph 6 of these findings of fact on its internet
website along with a bulletin that a computer user had to view
before accessing the website. The bulletin contained an
overview of the higher education master agreement, including
union security, and information concerning the dates, times and
places of a vote to accept or reject the tentative agreement
described in paragraph 5 of these findings of fact. It also
noted that the locations and times were tentative so interested
parties should check for changes on Friday, September 24, 2004.
The bulletin also stated that "all WPEA bargaining unit
members have an opportunity to vote on ratifying the contract."
11. On September 21, 2004, the Washington Public Employees
Association held a meeting which between 15 and 20 employees
attended, where its officials discussed the tentative agreement
described in paragraph 6 of these findings of fact. They
pointed out the union security clause and that all bargaining
unit members were eligible to vote on the contract.
12. The Washington Public Employees Association conducted an
election for all bargaining unit employees to vote on whether
they accepted or rejected the tentative agreement described in
paragraph 6 of these findings of fact on Saturday September 25,
2004, from 3:00 P.M. until 6:00 P.M. at the Bremer Student
Center in Olympic Community College. However, every bargaining
unit member could vote in any polling site at any community
college whose employees were represented by the Washington
Public Employees Association. Only 24 bargaining unit
employees voted. None of the complainants voted.
13. Considering the totality of the circumstances, the Washington
Public Employees Association should have foreseen that its
efforts to notify bargaining unit members were not likely to
reach an audience of employees that included the complainants.
The four days' advance notice did not mobilize a substantial
number of bargaining unit members to vote in the ratification
election described in paragraph 12 of these findings of fact.
These efforts were so deficient as to signal that the
Washington Public Employees Association was indifferent to the
right of the complainants to vote in the ratification election.
CONCLUSIONS OF LAW
1. The Public Employment Relations Commission has jurisdiction and
statutory authority to hear this matter under Chapter 41.80 RCW
and Chapter 391-45 WAC.
2. James Stuart, David Bartelheim, Jeanne Gardner, Cathryn Gray,
William Holdman, Shirlee Wilford, and Jacqueline Baker have
legal standing to file a complaint charging unfair labor
practices, and the Commission has jurisdiction under RCW
41.80.110 to determine and remedy complaints that the employee
organization described in paragraph 2 of the above findings of
fact has interfered with or restrained such employees in the
exercise of their statutory rights under RCW 41.80.050 by its
breach of its duty of fair representation that entailed an
agreement reached with the State of Washington in collective
bargaining as described in paragraph 5 of the foregoing
findings of fact.
3. By not fairly and adequately notifying all bargaining unit
employees who pay representation fees to the Washington Public
Employees Association in the bargaining units it represents at
Olympic Community College, as described in paragraph 2 of the
above findings of fact, of the opportunity to vote on whether
the bargaining unit would accept or reject the tentative
collective bargaining agreement, as described in paragraph 12
of the above findings of fact, and thereby breaching its duty
of fair representation, the Washington Public Employees
Association interfered with and restrained those employees in
the exercise of their rights under RCW 41.80.050, and has
committed an unfair labor practice in violation of RCW
41.80.110(2)(a).
4. The Washington Public Employees Association did not fail to
include the union security clause in a summary of the new
contract, and thus did not interfere with or restrain those
employees in the exercise of their rights under RCW 41.80.050,
nor did it commit such an unfair labor practice in violation of
RCW 41.80.110(2)(a).
ORDER
The Washington Public Employees Association, it officers and agents,
shall immediately take the following actions to remedy its unfair
labor practices:
1. CEASE AND DESIST from:
a. Failing to adequately inform James Stuart, David
Bartelheim, Jeanne Gardner, Cathryn Gray, William Holdman,
Shirlee Wilford, Jacqueline Baker and all members of the
supervisory and non-supervisory classified employee
bargaining units of their voting rights conferred by
agreement of the Washington Public Employees Association
with the State of Washington in collective bargaining.
b. In any other manner, restraining or coercing employees in
the exercise of their rights under Chapter 41.80 RCW.
2. TAKE THE FOLLOWING AFFIRMATIVE ACTIONS to effectuate the
purposes and policies of Chapter 41.80 RCW.
a. Post, in conspicuous places on Olympic Community College
premises where Washington Public Employees Association
notices to all employees are usually posted, copies of
the notice attached to this order. Such notices shall be
duly signed by an authorized representative of the
Washington Public Employees Association. Such notices
shall remain posted for 60 days. Reasonable steps shall
be taken by the respondent, Washington Public Employees
Association, to ensure that such notices are not removed,
altered, defaced, or covered by other material.
b. Read the notice attached to this order at a meeting of all
employees in the bargaining units represented by the
Washington Public Employees Association at Olympic
Community College and at the next state-wide convention
held by the Washington Public Employees Association.
c. Publish in the next monthly issue of the "WPEA Sentinel" a
true-sized copy of the notice attached to this order.
d. Notify each of the above-named complainants, in writing,
within 20 days following the date of this order, as to what
steps have been taken to comply with this order, and at the
same time provide each named complainant with a signed
copy of the notice attached to this order.
e. Notify the Compliance Officer of the Public Employment
Relations Commission, in writing, within 20 days following
the date of this order, as to what steps have been taken to
comply with this order, and at the same time provide the
Compliance Officer with a signed copy of the notice
attached to this order.
Issued at Olympia, Washington, the 22nd day of November, 2006.
PUBLIC EMPLOYMENT RELATIONS COMMISSION
CARLOS R. CARRION-CRESPO, Examiner
This order will be the final order of the
agency unless a notice of appeal is filed
with the Commission under WAC 391-45-350.
PUBLIC EMPLOYMENT RELATIONS COMMISSION
NOTICE
THE WASHINGTON PUBLIC EMPLOYMENT RELATIONS COMMISSION CONDUCTED A LEGAL
PROCEEDING IN WHICH ALL PARTIES HAD THE OPPORTUNITY TO PRESENT EVIDENCE AND
ARGUMENT. THE COMMISSION RULED THAT WE COMMITTED UNFAIR LABOR PRACTICES IN
VIOLATION OF STATE COLLECTIVE BARGAINING LAWS, AND ORDERED US TO POST THIS
NOTICE TO EMPLOYEES:
WE UNLAWFULLY failed to fairly and adequately notify all bargaining unit
employees in the supervisory and non-supervisory classified units we
represent of the opportunity to vote on the acceptance or rejection of the
tentative collective bargaining agreement reached between the State of
Washington and ourselves, the Washington Public Employees Association.
WE UNLAWFULLY interfered with and restrained all bargaining unit employees
in the exercise of their statutory rights by breaching our duty of fair
representation.
TO REMEDY OUR UNFAIR LABOR PRACTICES:
WE WILL cease and desist from failing to fairly and adequately inform all
bargaining unit employees of the opportunity to vote on the acceptance or
rejection of the tentative collective bargaining agreement reached between
the Washington Public Employees Association and the State of Washington on
September 17, 2004, in negotiations for a successor contract.
WE WILL cease and desist from failing to fairly and adequately inform all
bargaining unit employees of the opportunity to vote on the acceptance or
rejection of any other tentative collective bargaining agreement reached
between the Washington Public Employees Association and the State of
Washington in negotiations, when the negotiated agreement calls for such
opportunity (and notice).
WE WILL NOT, in any other manner, interfere with or restrain bargaining unit
employees in the exercise of their collective bargaining rights under the
laws of the state of Washington.
DATED: ___________ WASHINGTON PUBLIC EMPLOYEES ASSOCIATION
BY: ____________________________
Authorized Representative
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE.
This notice must remain posted for 60 consecutive days, and must not be
altered or covered by any other material. Questions about this notice or
compliance with the Commission's order may be directed to the Public
Employment Relations Commission (PERC), 112 Henry Street NE, Suite 300, PO
Box 40919, Olympia, Washington 98504-0919. Telephone: (360) 570-7300.
The full decision will be published on PERC's website, www.perc.wa.gov.