STATE OF WASHINGTON BEFORE THE PUBLIC EMPLOYMENT RELATIONS COMMISSION
In the matter of the petition of:
SPOKANE EDUCATION ASSOCIATION	CASE NO. 2344-C-79-105
For clarification of an existing bargaining unit of employees of:	DECISION NO. 1095-EDUC
SPOKANE SCHOOL DISTRICT NO. 81	ORDER CLARIFYING BARGAINING UNIT

Symone Scales, Attorney at Law, appeared on behalf of the petitioner.

Robert W. Winston, Jr., Attorney at Law, appeared on behalf of the employer.

On September 25, 1979, Spokane Education Association (SEA) filed a petition with the Public Employment Relations Commission seeking clarification of an existing bargaining unit with respect to "substitutes and coordinators". On April 14, 1978, the Spokane School District had filed a petition, docketed as Case No. 1458-C-78-64 for clarification of the bargaining unit concerning "substitute teachers". Decision No. 874 (EDUC, 1980) resolved the issue concerning substitutes. Therefore, testimony in the instant proceeding was limited to that concerning "coordinators" only. The hearing on the matter was held November 8 and 9, 1979 in Spokane, Washington before Hearing Officer Katrina I. Boedecker.

POSITION OF THE PARTIES:

The union argues that RCW 41.59.020(d) uses stricter language than the National Labor Relations Act in defining "supervisor".[1] Thus, the union urges the Public Employment Relations Commission (PERC) to require a greater showing of responsibility on the part of one claiming exclusion based on supervisory status than has been required by the National Labor Relations Board (NLRB). Relying on the reference in RCW 41.58.020(4) to "preponderance", the union urges that no one indicator standing alone is sufficient to justify segregating a person from the employee bargaining unit. Each duty and the circumstances in which each duty is performed must be analyzed to determine if that person functions in a manner that sets him or her apart from other employees and aligns that individual with management. Citing PERC precedent,[2] the union argues that the alleged supervisors in this present case are properly categorized as program coordinators rather than supervisors, and therefore should remain in the unit of non-supervisory certificated employees.

The district argues that all of the individuals holding the disputed positions consistently exercise independent judgment in matters relating to budgeting, program administration and the hiring and evaluating of staff assigned to those programs; that these coordinators have a community of interest as supervisors different from that of other certificated employees of the school district and that they should be excluded from the bargaining unit. Additionally, the district argues that the Coordinator of Student Activities is a confidential employee as defined by statute.[3]

FACTS:

The clarification petition covers 19 "program coordinators" presently included in a bargaining unit of approximately 1,366 certificated staff. All of the coordinators hold teaching certificates from the State of Washington as educators. The coordinators are all supervised by persons excluded from the bargaining unit. They are all paid in accordance with a "Coordinator Salary Schedule", which offers a higher rate of pay than that for a classroom teacher with the same amount of seniority. The coordinators are required to work either 190 days or 200 days per year, while classroom teachers have a 182-day contract work year. Many programs operated by the Spokane School District have "itinerant" certificated staffs who work in more than one building. The coordinator for each program is responsible for assigning and evaluating all itinerant certificated staff. If an itinerant teacher is to be absent, the teacher contacts the coordinator, who is then responsible for providing a substitute. Coordinators must also approve payroll records of itinerant teachers. While the procedural steps of the evaluation of certificated staff is covered by RCW 28A.58 and by the collective bargaining agreement between the parties, the coordinators are responsible for the substance of the evaluations of itinerant staff. Some coordinators may seek input from the principals in the buildings in which those itinerant staff work, but the coordinator remains the evaluator of record.

During the time of the hearing, the superintendent of the Spokane School District had what was called the "Superintendent's Council" made up of the Superintendent, the Deputy Superintendent, the Assistant Superintendent and seven directors of various departments within the district. The departments were Personnel, Business Services, Building Project, Special Programs, Basic Education and two district regional areas. The present petition concerns six positions in the Basic Education Department and thirteen positions in the Special Programs Department.

DISCUSSION:

Unit clarification petitions require the examination of each disputed position against standards clearly defined in a series of PERC cases. A basic test established for clarification of rank and file certificated bargaining units is: supervisors are excluded from rank and file certificated bargaining units where they primarily work in support of the administrative function of the school district; employees whose duties are routine or ministerial in nature or who serve as resource personnel in support of the educational program remain in non-supervisory educational employee bargaining units[4].

The record establishes that the coordinators in dispute here act as supervisors, within the meaning of the statute, to any itinerant teachers in their area. The coordinators effectively recommend hiring, disciplining or discharging; they are the main, if not the sole, evaluators of the itinerants and they act as the agent of management at the first step of the grievance process for any grievance filed by the itinerants. Basically, the coordinators function as a building principal to the itinerant staff.

Basic Education Division

The Basic Education Division is headed by director Gay Selby. The Coordinator of Student Activities and the Coordinator of Instructional Media report directly to Selby. The other four positions in contention report to a supervisor of Basic Education who, in turn reports to Selby.

Coordinator Student Activities -- Paul Henley

Paul Henley is responsible for developing and maintaining the student activities program in the K-12 grade levels of the district and the physical education program for the 7-12 grades. He selects and screens the head coaches. There are 537 coaches in the district, approximately 80 of which are head coaches. He evaluates the head coaches and has been involved in settling grievances. Thirty percent of his time is spent as the District's representative to the Greater Spokane League and the Washington Interscholastic Activities Association. He is responsible for a "couple hundred thousand dollars" per year of receipts from league activities. Besides effectively recommending hiring of the head coaches, Henley also effectively recommends hiring of certificated employees for the camp and activity programs the district runs during the summer. Henley's functions further the administration of the district more than the teaching functions of the district.

The record does not support the district's claim that Henley is also a confidential employee. It was established that he provided information to the district's bargaining team, but he did not formulate their labor policy.

Coordinator Instructional Media -- Robert Pryor

Robert Pryor works a 200 day contract year. He is responsible for the media center, which is a "warehouse" operated by the school district in one of its own buildings. Pryor is responsible for the district film library, dispensing and maintaining audio-visual equipment, the district textbook depository, and the science equipment for all the elementary science programs. He has one assistant coordinator, who is a certificated employee and 17 classified employees working under him. Each school provides Pryor with their projected needs as to classroom materials, and Pryor then develops the district's budget in the area of media. Pryor effectively recommends the hiring and he evaluates all 17 classified personnel working in his department. Pryor's supervisory duties vis-a-vis the employer in his department dictate a conclusion that he is a supervisor to be excluded from the unit.

Assistant Coordinator Professional Library -- Marilyn Matulich

Although the testimony regarding Marilyn Matulich's responsibility varied slightly, the record supports a finding that she works directly under Pryor less than 30% of her time. The rest of her time she reports to a supervisor of basic education, Cynthia Lambarth, who is excluded from the SEA unit. The part of her working time when she is supervised by Pryor, she is working on the physical part of instructional media. The rest of her working time would be spent on the programming aspect of instructional media. She is the immediate supervisor of 16 itinerant librarians and the coordinator of a total of 24 elementary librarians.

Program Specialist -- Shirley Tupper

Shirley Tupper is in charge of a visiting artist program for the sixth grade, a cultural enrichment program district-wide and an artist-in-residence program. In addition, she is involved in art development in grades 7-12 and is the immediate supervisor of seven itinerant art teachers. The SEA did not address her position in its post-hearing brief. Except for her supervision of the itinerant teachers, Tupper's responsibilities are geared more toward enriching the educational program of the district than helping it function at the administrative level. However, her responsibilities toward the seven itinerant art teachers clearly make her a supervisor.

Coordinator of Music K-6 -- Maxine Jennings

At the time of the hearing, Maxine Jennings was employed 6/10ths time as a coordinator and 4/10ths time as a band teacher. Jennings is responsible for the development of the elementary music program for the district and for coordinating the vocal, band and string programs and the all-city music groups. The program supports 26 full-time equivalent (FTE) music positions with 30 certificated individuals filling the slots. Twenty-nine are itinerant teachers supervised by Jennings.

Coordinator of Physical Education K-6 -- Donna Plato

Donna Plato's position is similar to that of Jennings. She has a 190-day work year contract, 6/10ths time as teacher and 4/10ths time as a coordinator. She supervises eight itinerant physical education instructors, therefore having the same scope of responsibility as do other itinerants supervisors. Plato is not responsible for the physical education directors that remain within a building on permanant assignment.

Special Programs Division

The Special Programs Division is headed by James Hordemann. At the time of the hearing, the Special Programs department contained at least four divisions: Vocational Education and Traffic Safety; Handicapped Programs; Student Services; and Grants Management. Of the remaining 13 disputed positions, two are in Vocational Programs; five are in Handicapped Programs; four are in Student Services; and two are in Grants Management. Many of the programs in these divisions are operated with categorical funding from either the federal or state government. Each such program must meet guidelines and restrictions spelled out by the funding source. The discretion that might exist in a program is generally in the personnel area, e.g., the number of people to be employed and the amount of salary the person is to receive. Because of the outside funding source for these programs, the personnel employed fluctuates year to year. The coordinators, with some input from teachers in their programs, formulate budgets to meet the district's needs in their areas and the funding sources guidelines.

Vocational Programs: Coordinator of Vocational Education and Traffic Safety--Mark Miller

In the vocational education branch of Mark Miller's duties, he is responsible for the trade and industrial programs in the four senior high schools. Miller works a 200-day year contract and reports to the supervisor of Vocational Education and Traffic Safety. Miller assesses the needs of the vocational program for budgetary purposes, and monitors the operation of the program to assure performance within the limits set by the state. In the Traffic Safety branch of his responsibility, Miller effectively recommends the hiring for 4.2 FTE positions as traffic instructors during the regular school year and 16 to 18 persons as traffic safety instructors during the summer. To fill the summer school slots, Miller screens candidates who are qualified and interested and then submits the list to the Personnel Director of the district who acts on Miller's recommendations. Miller evaluates the instructors and is the first official step for their grievances. He transfers and assigns the traffic department employees among the schools. Miller must approve all requisitions for supplies and equipment in his area.

Vocational Programs: Coordinator of Vocational Education -- Georgialee Smithpeters

Georgialee Smithpeters is on a 200-day contract year. She reports directly to the supervisor of Vocational Education and Traffic Safety and coordinates three departments: Business and Office Education; Distributive Education; and Home and Family Life Education. There are approximately 20 certificated staff in each area. Smithpeters effectively recommends hiring, assigning and transferring of staff at the beginning of each year. All the staff is permanantly assigned to either one of the seven high schools or seven junior high schools. Each vocational program (Business Education, Distributive Education, Home and Family Life Education) must have an advisory committee. In addition, there is an advisory council which oversees the entire District vocational education program. A major portion of Ms. Smithpeters' responsibility is to work with various advisory committees. Ms. Smithpeters makes contact with the community to recruit members, sets up the committees, sets guidelines, calls meetings, and insures compliance with federal and state law. The committees suggest curriculum, equipment purchases, and make staff recommendations.

Handicapped Programs: Coordinator Deaf Education; Hearing Conservation; Home Tutor and Guilds' School Programs -- Richard Reames

Richard Reames works a 200-day contract year and is paid half on the coordinator's salary schedule and half on the principal's salary schedule. He reports to the supervisor of the Handicapped Programs Department. Reames evaluates one certificated employee and two classified employees in the Deaf Education Program. The certificated employee is an itinerant Hearing Therapist who travels among all the schools in the school district.

Handicapped Programs: Coordinator CDS, Shrine Hospital, Booth Care Center Visually Impaired, Deinstitutionalized Handicapped Program -- Merlin Omans

Merlin Omans is responsible for the evaluations and effective recommendations regarding hiring, disciplining and discharging of all the communication disorder specialists for the district. At the time of the hearing there were 13.5 FTE communication disorder specialists; 3.5 of which were permanantly assigned to schools, the other 10 being itinerant. Omans assigns the communication disorder specialists to particular schools based on his analysis of the needs of the speech handicapped children in the enrollment. There are no state guidelines as to the ratio between speech specialist and number of students, and assignments vary year to year. Also under his supervision are two certificated teachers and a non-certificated aide in the Visually Impaired Program. Both these teachers are itinerant. Spokane School District runs a program at the Shrine Hospital for children who are in long-term treatment processes or surgery. There is one certificated teacher at the Shrine Hospital. The Booth Care Center is a center for single mothers of high school age. There is one certificated teacher in that program. Omans is similar to a principal in both the Shrine and Booth programs.

Handicapped Programs: Coordinator Self-Contained Programs -- Joy Kerr

Joy Kerr is the coordinator for the self-contained behavioral and handicapped program and the educable mentally handicapped program. Her position was a newly created one at the start of the 79-80 school year, and she had filled her position for one month, at the time of the hearing, so much of the testimony was speculative. Self-contained programs are learning situations where a handicapped student is in one classroom for at least three hours, if not the full day. Kerr coordinates the individual education plans that must be developed for each individual student to make sure teachers are meeting goals and objectives required in the handicapped area according to federal and state law. There were 62 certificated teachers in the program and there was speculation that six itinerant teachers would be hired before the end of the school year. Kerr was not directly responsible for the evaluation of any of the 62 certificated staff in her programs. She does an evaluation of each staff member with the principal, who is the evaluator of record. Kerr goes into the classroom to help the teachers coordinate curriculum. Without itinerant teachers under her, Kerr's work in support of the classroom situation, and the educational program of the district would not qualify her for exclusion as a supervisor. There has been no motion to reopen the record and no evidence of actual supervisory authority exercised by Kerr, but it is observed that the addition of itinerant staff and supervisory responsibilities similar to those of other coordinators would consititute a significant change of circumstances, and likely a changed result, from that found here.

Handicapped Programs: Coordinator Learning Support Centers -- Jean Keil

Jean Keil coordinates and supervises resource rooms in the Learning Support Family program for the district. There are 45 rooms involved with 38 teachers. Keil is responsible for seven itinerant staff within the 38 certificated teachers assigned to the resource rooms. Keil submits a budget for the resource room programs, conducts monthly meetings among the certificated staff to go over state and federal requirements, trouble shoots, arranges for in-service training, and monitors compliance with the rules and regulations of the programs. She coordinates with the Basic Education Department to facilitate the transfer of the learning disability student from her program to the regular classroom. She is called in as a consultant by teachers to work with students and help the teachers determine what disability is interferring with the specific child's learning. Keil clearly has responsibilities in support of the educational program of the district, but her supervisory responsibilities toward the seven itinerant teachers require her exclusion from the unit as a supervisor.

Handicapped Programs: Coordinator Enrollments Budgets, Marian Heights and Youth Learning Center -- Harold Hurmence

Harold Hurmence works a 200-day contract year. Half of his time is spent in activities similar to a principal at the Youth Learning Center, a half-way house for students coming back from either probation or parole from state institutions, and the Marian Heights Center, a program for deliquent or "predeliquent" girls. The Youth Learning Center has two certificated staff and Marian Heights has four certificated staff. The other half of his time is spent coordinating transportation and placement of handicapped students among the various programs offered by the district.

Student Services: Coordinator School Psychologist Services -- Michael Jarvis

Michael Jarvis works a 190-day contract year and reports to the Supervisor of Student Services. There are five regional guidance centers in the Spokane School District, each staffed by a manager and psychologists and counselor/social workers. Jarvis is responsible for the psychologists within the center but not for those running the center itself. He recruits and effectively recommends hiring, disciplining and discharging of the school psychologists. He assigns and evaluates them at the various areas. He is the first step of their grievance process. He has effectively recommended the hiring of four school psychologists since he started working for the district. Five percent of his time is spent in contact with students; the rest of the time is spent in program evaluation for the district.

Student Services: Acting Coordinator Health Services -- Carol Kerkering

Carol Kerkering is on a 200-day contract year. Kerkering has five itinerant nurses under her direct supervision and coordinates six other nurses in 3.5 FTE positions in permanent building assignments. Some of the nurses are also supervised by coordinators of other programs; for example, the Title 1 Program requires a nurse for screening and making physical assessments. Kerkering is responsible for evaluating all of the nurses for their nursing performance in their employment with the district. Kerkering's responsibilities make her the main supervisor for the nurses of the district and therefore exclude her from the bargaining unit.

Student Services: Coordinator Group Testing and Research -- Gordon Erickson

Gordon Erickson is responsible for predicting the enrollments of each school in the district for use by the school board. Erickson is also the chairman of a committee that devises a testing plan for the district, selects the instruments that will be used in the program and implements the state-wide assessement that is mandated by the Superintendent of Public Instruction. He is also the chairman of the Research Council which reviews any research proposal that comes into the district before passing it along for approval or disapproval by the Superintendent's Council. He coordinates the Special Program evaluators to see that all the special programs are evaluated in accordance with the state law by proper test design, that the data is collected, analyzed and receives the correct conclusions, and that the final reports are submitted to the proper agencies. The special program evaluators are not certificated employees, but they are full time employees of the district. Erickson is clearly aligned with the administration in the district.

Student Services: Coordinator Counseling, Student Discipline and Attendance -- Richard Jones

Richard Jones works a 200-work day contract year. Part of the time, Jones is a liaison-consultant to the administration, teachers, parents and students regarding the due process rights of students in disciplinary proceedings. Another part of his time is spent supervising the regional counseling center managers; he is partially responsible for their evaluation. Additionally, he determines the areas in which the counselors will be involved in providing services to students, and he monitors the caseload to see that the students are receiving the proper amount of time allotted for counseling among the approximately 50 counselors employed by the Spokane School District. Jones is solely responsible for the evaluation of the regional counselors assigned to the regional counseling centers. The remainder of his time is spent on attendance problems in the school district. He meets with parents, school administrators or community agencies to develop programs to keep a student attending school or to devise programs that will keep students in school (as opposed to dropping out). His responsibilities align him more with the administration than with the teaching staff.

Grants Management: Coordinator REAL, Bilingual Programs, English as a Second Language Program -- Theodore Runberg

Theodore Runberg acts as a principal for the REAL program, which is a reentry alternative learning situation for former high school drop-outs. He is responsible for three certificated employees in the program. The program is housed at the YMCA, apart from any school building. There are over 60 students in the REAL program. Runberg assists with their discipline, maintains the building, manages the budget for the program, approves purchases, approves and selects personnel, coordinates the curriculum of REAL with the on-going curriculum moves of the district, and makes sure REAL complies with the policies of the district. Runberg is also responsible for 15 non-certificated aides in the bilingual programs of the Spokane district and five non-certificated aides in the English as a Second Language program for the district. With respect to the bilingual program, Runberg recruits people, effectively recommends hiring them, assigns them and manages the budget of the program. He implements the budget with respect to materials and staff.

Grants Management: Coordinator Title I -- Barbara Wylder

Barbara Wylder reports directly to the supervisor of Grants Management. Title I is a federally funded program for under-achieving students in low income areas. In the Spokane district it involves 55 certificated staff, including two Title I managers, and 53 classified staff. The certificated staff are reading teachers, math teachers, counselors and nurses. Eighteen of the certificated staff are itinerant, with Wylder as their sole supervisor. The scope of Wylder's responsibilities is similar to that of other coordinators who are responsible for itinerant teachers.

FINDINGS OF FACT

1. Spokane School District No. 81, is and at all times material herein has been, a school district within the meaning of RCW 41.59.020(5).

2. The Spokane Education Association is, and at all times material herein has been, an employee organization within the meaning of RCW 41.59.020(1), which has been voluntarily recognized as the exclusive bargaining representative of all certificated personnel including substitutes and part-time employees employed by or to be employed by the district excluding the superintendent, the deputy superintendent, the assistant superintendent for support services, directors of basic education, special programs areas I and II, management services, personnel services, building and planning, principals and assistant principals and supervisors of program development, program operations, grants management, handicapped program, vocational education and traffic safety and pupil services.

3. A dispute has risen between the parties as to whether 19 "coordinator" positions are to be excluded from the bargaining unit described in paragraph 2 of these findings of fact, as supervisors. The Coordinator of Student Activities is additionally claimed by the employer to be a confidential employee.

4. The Coordinator of Student Activities reports to the Director of Basic Education, does no teaching, and is responsible for administration of functions within the district. The incumbent has provided information to district labor relations personnel but has not been directly involved in the formulation of district labor relations policy or negotiation of collective bargaining agreements.

5. The Coordinator of Instructional Media and the Assistant Coordinator of the Professional Library and Program Specialist exercise supervisory authority with respect to other district employees, do no classroom teaching, and have a reporting and evaluative relationship to the Director of Basic Education within the administration of the school district.

6. The K-6 Physical Education Coordinator and the K-6 Music Coordinator each teach or provide direct services to students for 40-60% of their working time, but the rest of their work time is devoted to administration of functions within the district. They each exercise supervisory authority with respect to other district employees, including evaluating and making effective recommendations on hiring, disciplining and discharging.

7. The Coordinator of School Psychologist Services, the Acting Coordinator for Health Services, the Coordinator for Group Testing and Research, and the Coordinator for Counseling, Student Discipline and Attendance, all report to the Director of Student Services in the Special Programs department of the district. These four coordinators effectively recruit, hire, discipline and discharge other employees within the district. They are the first step of the grievance procedure for employees under them. They assign and transfer employees under them effectively within the confines of the contractual agreement between the SEA and the Spokane School District. They are responsible for substantial budgets of the district. They work in support of the administrative functions of the Spokane School District.

8. The Coordinator of Deaf Education, Hearing Conservation, Home Tutor and Guild School Programs; the Coordinator of Communication Disorder Specialists, Shrine Hospital, Booth Care Center and the Visually Impaired; and the Coordinator for Special Education Enrollments budgets, Marian Heights and Youth Learning Centers, all report to the Supervisor of Handicapped Programs in the Special Programs Department of the district. They all perform functions similar to principals as part of the work requirements in their special education programs. They support the administration functions of the district.

9. The Coordinator of Learning Support Centers, is hired for expertise in the area and serve as a resource person for teachers. However, the incumbent effectively recommends hiring, disciplining, discharging and is responsible for itinerants.

10. The Coordinator of Self-Contained Programs is hired for expertise in the area and serves as a resource person for teachers. At the time of the hearing herein, said individual did not possess or exercise supervisory authority over other employees of the employer.

11. The Coordinator of Vocational Education and Traffic Safety and the Coordinator of Vocational Education are responsible for substantial budgets within the district and exercise supervisory functions over other employees within the district.

12. The Coordinator of REAL, Bilingual and English as a Second Language, and the Coordinator for Title I, exercise supervisory functions over certificated and non-certificated employees of the district. Coupled with their other job duties they support the administrative functions of the district.

CONCLUSIONS OF LAW

1. No question concerning representation presently exists in the voluntarily recognized bargaining unit of non-supervisory employees of the Spokane School District, No. 81, and the Public Employment Relations Commission has jurisdiction of this matter to issue an order clarifying the existing bargaining unit under RCW 41.59 et. seq.

2. The Coordinator of Student Activities; the Coordinator of Instructional Media; the Assistant Coordinator of the Professional Library; Program Specialist (Tupper); the K-6 Physical Education Coordinator; the K-6 Music Coordinator; the Coordinator of School Psychologists Services; the Acting Coordinator of Health Services; the Coordinator of Group Testing and Research; the Coordinator of Counseling, Student Discipline and Attendance; the Coordinator of Deaf Education, Hearing Conservation, Home Tutor and Guild School Programs; the Coordinator of Communication Disorder Specialists, Shrine Hospital, Booth Care Center and Visually Impaired; the Coordinator of Special Education Enrollments, Budgets, Marian Heights and Youth Learning Center; the Coordinator of Learning Support Centers; the Coordinator of REAL, Bilingual, English as a Second Language; the Coordinator of Title I; the Coordinator of Vocational Education and Traffic Safety; and the Coordinator of Vocational Education, are supervisors within the meaning of RCW 41.59.020(4)(d).

3. On the record made herein the Coordinator of Self-Contained Programs is not a supervisor within the meaning of RCW 41.59.020(4)(d).

ORDER

The bargaining unit consisting of all non-supervisory certificated employees of Spokane School District No. 81 is clarified to exclude the positions of: Coordinator of Student Activities; the Coordinator of Instructional Media; the Assistant Coordinator of the Professional Library; Program Specialist (Tupper); the K-6 Physical Education Coordinator; the K-6 Music Coordinator; the Coordinator of School Psychologists Services; the Acting Coordinator of Health Services; the Coordinator of Group Testing and Research; the Coordinator of Counseling, Student Discipline and Attendance; the Coordinator of Deaf Education, Hearing Conservation, Home Tutor and Guild School Programs; the Coordinator of Communication Disorder Specialists, Shrine Hospital, Booth Care Center and Visually Impaired; the Coordinator of Special Education Enrollments, Budgets, Marian Heights and Youth Learning Center; the Coordinator of Learning Support Centers; the Coordinator of REAL, Bilingual, English as a Second Language; the Coordinator of Title I; the Coordinator of Vocational Education and Traffic Safety; and the Coordinator of Vocational Education.

DATED at Olympia, Washington this 20^th day of November, 1981.

PUBLIC EMPLOYMENT RELATIONS COMMISSION

[SIGNED]

MARVIN L. SCHURKE, Executive Director