Shoreline School District, Decision 12914 (PECB, 2018)

STATE OF WASHINGTON

BEFORE THE PUBLIC EMPLOYMENT RELATIONS COMMISSION

In the matter of the petition of: Public school employees of washington   Involving certain employees of: shoreline School District

CASE 130466-E-18 DECISION 12914 - PECB   DIRECTION OF ELECTION

Jason K. MacKay, Assistant General Counsel, for the Public School Employees of Washington.

Parker A. Howell, Attorney at Law, and Jay W. Schulkin, Attorney at Law, Porter Foster Rorick LLP, for Shoreline School District.

On March 6, 2018, the Public School Employees of Washington (union) filed a petition seeking to represent all full-time and regular part-time classified Head Start employees at the Shoreline School District (employer or district).  The employer contends that the petitioned-for unit is not appropriate because the Head Start employees do not share a sufficiently distinct community of interest from other employees who perform early childhood services.  The employer also argues that the Head Start coordinator position is supervisory and should not be included in any unit with nonsupervisory staff.  Hearing Officer Michael Snyder conducted a hearing in the matter on May 30, 2018.  The parties filed post-hearing briefs on June 27, 2018, to complete the record.

The petitioned-for unit of Head Start employees is an appropriate unit based on the employees’ current duties, skills, and working conditions and the employer’s organizational structure.  The duties of the Head Start employees demonstrate that no work jurisdiction issues would be created if those employees were allowed to be in a bargaining unit separate from other early childhood service employees.  The proposed bargaining unit would not fragment the employer’s workforce.  Finally, the Head Start coordinator position is not a supervisory position and is appropriately included in the proposed bargaining unit.

BACKGROUND

The employer offers a range of pre-kindergarten (pre-k) care and educational programs for children aged three to five.  The district’s early learning department contains three components, all of which are overseen by Director of Early Learning Hillery Clark.  The department’s organizational structure is set forth below.

 

Special Education

The district provides special education services to pre-k students with disabilities through the district’s Early Childhood Education program.  The program’s content and direction is mandated by the federal Individuals with Disabilities Education Act.  The program is currently staffed by eight certificated teachers and thirteen paraeducators.  The special education certificated teachers are represented by the Shoreline Education Association (SEA).  The paraeducators are represented by the Shoreline Educational Support Professionals Association (SESPA).

Shoreline Children’s Center

The district offers standard daycare and pre-k classes through the Shoreline Children’s Center (Children’s Center) program.  The Children’s Center represents the largest component of the early learning department.  The Children’s Center is funded through tuition.  Shoreline Children’s Center Director Kelly Davidson oversees the program and reports directly to Clark.  The program is divided into the Extended Care component and the pre-k daycare and pre-k class component.

Extended Care provides daycare for children from kindergarten to sixth grade and is offered from 6:00–8:30 a.m. and from 2:30–6:30 p.m. at the district’s nine elementary schools. It is staffed by 11 childcare leads and 20 childcare assistants.

The pre-k daycare is provided at the Children’s Center during the same approximate hours as the Extended Care program.  Traditional pre-k classes are offered during the middle of the day.  These classes are governed by lesson plans developed by the district and childcare leads.  In contrast, the pre-k daycare does not have a formal curriculum and instead focuses on less structured, age-appropriate activities.

The pre-k daycare and pre-k classes at the Children’s Center are staffed by 12 childcare leads and 21 childcare assistants.  The leads are responsible for teaching classes.  The childcare lead positions require an associate’s degree in early childhood education or an equivalent degree.  The childcare assistants support the work of the leads.  The childcare assistants require a high school diploma plus either experience with or course work in early childhood education.  The pre-k daycare and pre-k classes offered by the Children’s Center staff are available during the regular school year and on a limited basis during the summer months.

The Children’s Center also employs family advocates who serve as primary information resources and liaisons, connecting families with the district, other appropriate community agencies, and social services.  The family advocates provide support for students in both the tuition-based program as well as the federally funded pre-k special education program.  The role of the family advocate is duplicated elsewhere in the district, with individuals working in similar capacities in a number of elementary schools as well in as the high schools.

The childcare leads and childcare assistants are represented by the Shoreline Children’s Center Association (SCCA).  See Shoreline School District, Decision 4701 (PECB, 1994).  The family advocates in the Children’s Center, as well as those working in the district’s elementary and high schools, are represented by SESPA.  The Extended Care coordinator and Children’s Center coordinator are represented by the Shoreline Professional-Technical Association.

Head Start

The employer provides a second pre-k program known as Head Start.  Funding for the Head Start program is provided by the United States Department of Health and Human Services (DHHS) to the Puget Sound Educational Service District (PSESD).  The Shoreline School District, in turn, contracts with PSESD to operate the Head Start program.  Funding for the program is tied to the district’s compliance with a range of regulations established by DHHS and PSESD.

Children are accepted into the program based upon their family’s income or if a child is otherwise considered “at risk,” such as being an unaccompanied minor, in foster care, or homeless.  Head Start classes are offered from 8:30 or 9:00 a.m. through 2:30 or 3:00 p.m. exclusively during the course of the school year.  The district has offered a Head Start program since approximately 1990.

The program is staffed by Head Start Coordinator Holly Ogden, 10 Head Start lead teachers,  4 Head Start assistants, and 3 Head Start family support personnel.  All employees in the Head Start program are currently unrepresented and are the subject of this petition.  Like the staff of the special education program, the Head Start employees report directly to Clark.

As coordinator, Ogden is responsible for ensuring the smooth operation of the program’s daily activities.  Ogden does not have the authority to grant leave requests or assign overtime.  She does not assign employees to a given shift or classroom and is not responsible for assigning employees their duties.  Ogden does not transfer employees between job classifications or perform evaluations.  Instead, these responsibilities fall within Clark’s purview.

Ogden is not responsible for disciplining or firing employees.  Her role in hiring is limited to one occasion when she was a member of an interview panel for a Head Start assistant position.  In addition to Ogden, the panel included various other stakeholders, including members of the public.  All final hiring decisions are made by the employer’s human resources office.

Ogden may serve as acting director when Clark is absent.  Ogden estimates this occurs twice a month.  While serving as acting director, she may call in a substitute in order to maintain the requisite student-to-teacher ratio.

The Head Start lead teachers design and implement daily lesson plans that comply with the curriculum mandated by PSESD.  The Head Start assistants work closely with the lead teachers to maintain an orderly and developmentally appropriate learning environment.  The Head Start lead teachers are required to have an associate’s degree with some early childhood education courses, as well as access to a vehicle and a valid driver’s license.  The Head Start assistants must have an early childhood education certificate or degree.  With one limited exception, all Head Start employees currently only work with Head Start students.

The Head Start family support employees serve as the bridge between the program and the families of children enrolled in the program.  The family support employees’ duties include enrolling children in the program, monitoring student attendance, and providing families with support.  Overall, they facilitate positive parent, school, and student relationships.  The lead teachers interact daily with the family support employees.

Prior to beginning work in the program, all Head Start employees must complete an extensive training program offered by PSESD at its Renton facility.  This training is not provided to other district employees.  Completion of annual training specific to Head Start also is required.

The Head Start program requires staff to perform certain duties not required of the employer’s other pre-k employees. These duties include home visits; recurring vision, hearing, and health screenings of students; and daily charting to track child development along a range of metrics.  Completing the requisite documentation occupies a substantial portion of the leads’ planning time before and after class. 

There is limited evidence of permanent or temporary employee transfers into or out of the Head Start program.  In one case, an employee from the Head Start program was hired to fill the Children’s Center coordinator position.  One part-time Head Start assistant also works part-time as a childcare assistant.  SCCA-represented employees, in contrast, often move between the Extended Care and Children’s Center programs.  One reason for the frequency of transfers stems from the internal posting provisions of the SCCA collective bargaining agreement.  These internal posting requirements also apply to summer work positions in the Children’s Center.  In contrast, there is no internal posting requirement for any Head Start position.

2018­–2019 School Year Changes

Prior to the 2017–2018 school year, the Shoreline Children’s Center was located in a stand-alone facility while the pre-k special education and Head Start programs were housed in Meridian Park Elementary School.  After an internal review process, the district passed a bond measure in February 2017, providing funding for the construction of a new Early Learning Center that will house all three pre-k programs.

In preparation for that move, the Children’s Center, special education, and Head Start programs moved into the North City Elementary School for the 2017–2018 school year.  While currently co-located at North City, the Children’s Center and Head Start programs operate out of separate classrooms.  The Children’s Center staff works with the students in the tuition-based program while the Head Start staff works with the Head Start students.  There is, however, a shared playground area for children and a break room for staff.  Deputy Superintendent Marla Miller testified that the district expects the programs to move to a newly constructed Early Learning Center in January 2019.

When the programs move to the new center, the employer anticipates changing the structure of its early learning programs.  The school board approved a plan to begin “blending” students from the three separate programs into single classrooms starting in the 2018–2019 school year.  Miller testified that the timeline for blending is not yet determined.  Some may occur prior to the move to the new Early Learning Center in January 2019.

The district began integrating the special education students into both the Children’s Center and Head Start classrooms in preparation for the 2018–2019 school year.  Under the pilot program, certificated staff represented by the SEA and childcare leads represented by the SCCA volunteered to work together to teach the blended classes.  Similarly, the special education teachers started working with the Head Start lead teachers to incorporate special education students into classes formerly composed of only Head Start students.  There is no evidence that either practice resulted in disputes over work jurisdiction.

Miller testified that the district’s goals are to align the operating hours of the three childcare programs, create a unified curriculum, and adopt a standardized training program.  However, the SCCA objected to the process of working with Head Start staff to blend the classrooms and filed a grievance on May 15, 2018, alleging that the district’s plan to blend classrooms violates the subcontracting clause of its collective bargaining agreement.

ANALYSIS

Applicable Legal Standards

Determining appropriate bargaining units is a function delegated to this agency by the Legislature.  City of Richland, Decision 279-A (PECB, 1978), aff’d, International Association of Fire Fighters, Local 1052 v. Public Employment Relations Commission, 29 Wn. App. 599 (1981), rev. denied, 96 Wn.2d 1004 (1981).  The decision is made on a case-by-case basis.  King County, Decision 5910-A (PECB, 1997).  The goal is to group together employees who have sufficient similarities (a community of interest) that indicate they will be able to bargain effectively with their employer.  Quincy School District, Decision 3962-A (PECB, 1993).

In making bargaining unit determinations, the agency considers “the duties, skills, and working conditions of the public employees; the history of collective bargaining by the public employees and their bargaining representatives; the extent of organization among the public employees; and the desire of the public employees.” RCW 41.56.060(1).  For the classified staff of school districts, the agency also seeks to avoid excessive fragmentation.  RCW 41.56.060(2)(b).  These criteria are not applied on a strictly mathematical basis.  King County, Decision 5910-A.  Not all of the factors will arise in every case and where they do exist, any one factor could be more important than another, depending on the facts.  Renton School District, Decision 379-A (EDUC, 1978), aff’d, Renton Education Association v. Public Employment Relations Commission, 101 Wn.2d 435 (1984).

When crafting bargaining units, this agency is not required to determine the “most” appropriate bargaining unit.  Rather, it is only necessary that the petitioned-for unit be an appropriate unit.  The fact that there may be other appropriate employee groups, and perhaps even more appropriate ones, does not require setting aside a unit determination.  University of Washington, Decision 8392 (PSRA, 2004); City of Winslow, Decision 3520-A (PECB, 1990).

The agency examines the factual situation as it exists when a petition is filed.  State – Attorney General, Decision 9951-A (PSRA, 2009).  The Commission has rejected attempts to speculate as to future duties and working conditions of employees.  City of Yakima, Decision 9983-A (PECB, 2008); Lake Washington School District, Decision 1550 (EDUC, 1982).  Where future changes are mandated by law and well-defined, however, the Commission may take those factors into account.  See State – Health Care Authority, Decision 11254 (PSRA, 2011), aff’d, Decision 11254-A (PSRA, 2012) (dismissing the petition as premature when changes to the workforce mandated by legislation had a strong likelihood of rendering the unit inappropriate).

Supervisory Status

Generally, supervisors are not included in the same bargaining units as the employees they supervise.  WAC 391-35-340.  Separating supervisors from the rank-and-file bargaining unit avoids the potential for conflicts of interest that would otherwise exist in a combined bargaining unit.  Id.

A supervisory employee is any employee whose preponderance of duties include the independent authority “to hire, assign, promote, transfer, layoff, recall, suspend, discipline, or discharge other employees, or to adjust their grievances, or to recommend effectively such action.”  Granite Falls School District, Decision 7719-A (PECB, 2003) (citing RCW 41.59.020(4)(d)).  “Preponderance” can be met in two different ways.  An employee may be a supervisor if he or she spends a preponderance of his or her time performing one or more of the statutory supervisory activities.  City of East Wenatchee, Decision 11371 (PECB, 2012); Inchelium School District, Decision 11178 (PECB, 2011).  An employee may also be a supervisor if he or she spends less than a preponderance of his or her time performing supervisory activities but performs a preponderance of the types of supervisory activities.  City of East Wenatchee, Decision 11371; King County, Decision 12079 (PECB, 2014).

The determination of an employee’s supervisory status is made by examining the employee’s actual duties, not solely on the basis of the job title or job description.  Rosalia School District, Decision 11523 (PECB, 2012); Morton General Hospital, Decision 3521-B (PECB, 1991).  This agency places emphasis on whether a disputed position has independent authority to act in the interest of the employer and make meaningful changes in the employment relationship.  City of Lakewood, Decision 12453 (PECB, 2015); State – Office of Administrative Hearings, Decision 11503 (PSRA, 2012).  If an employee merely executes the instructions of a higher ranking employee when making meaningful changes to the workplace, that employee has not exercised independent judgment.  Id., citing City of Lynnwood, Decision 8080-A (PECB, 2005), aff’d, Decision 8080-B (PECB, 2006).

The distinguishing characteristic is that the authority does not rise to the level of conflict expressed in the statute that would require separating the employee out of the bargaining unit.  Rosalia School District, Decision 11523.  In determining supervisory status, the agency considers the extent of authority of first-line supervisors to hire, terminate, suspend without pay, or to effectively recommend such actions as being the paramount criteria.  Okanogan County, Decision 6142-A (PECB, 1998).  An employee’s exercise of authority to assign and direct work, grant time off, authorize overtime, issue oral or written reprimands, and evaluate and train subordinate employees may be insufficient when that individual does not have authority to hire, terminate, suspend without pay, or effectively recommend such actions.  Id.

Application of Standards

The duties, skills, and working conditions, as well as the extent of the employer’s organization, demonstrate that the Head Start staff shares a sufficiently distinct community of interest to constitute an appropriate unit.  The Head Start employees interact with one another on a daily basis.  The lead teachers are paired with an assistant for the duration of a school day.  Similarly, the lead teachers also frequently come into contact with the family support employees as well as the Head Start coordinator.  This type of frequent and sustained contact does not currently occur between the Head Start staff and employees of the other programs within the early learning department.

The Head Start staff performs unique job duties based upon the state and federal rules that are not applicable to the special education or Children’s Center programs.  The Head Start family support employees and lead teachers perform home visits on a regular basis.  The Head Start employees track the developmental progress of the children in a system currently only utilized by that program, and they perform various student health screenings that are not performed by employees in the other programs.  The tracking process requires a significant amount of time.  While Children’s Center childcare leads also perform home visits, they are neither required by the district as a condition of employment nor do they occur with the same frequency as the Head Start home visits.

All Head Start program employees, however, have additional skills by virtue of the training provided by the PSESD.  In addition to the annual training required of all employees by the district, Head Start employees also attend a weeklong training conducted by PSESD and they take subsequent annual refresher courses.  The hiring qualifications for lead teachers and assistants in the Head Start program are also more stringent than those required for the comparable positions in the Children’s Center.

The Head Start staff also has certain unique working conditions.  Unlike employees in the Children’s Center, for instance, Head Start employees do not work during the summer.  Although they may apply for summer positions with the Children’s Center, they are treated the same as external applicants.  Also, the Head Start staff works during normal school hours while the Children’s Center employees provide daycare both before and after normal school hours.

There is limited contact and interchange between the Children’s Center and Head Start staff.  Currently, the Head Start employees interact primarily with one another in support of the district’s stand-alone Head Start program.  Rarely do employees permanently transfer between the programs and there is no evidence of temporary interchange of employees between the programs.

The extent of organization also supports a distinct community of interest for the Head Start employees.  The employer’s workforce is currently organized into both horizontal and vertical bargaining unit configurations.  Importantly, the SCCA bargaining unit is vertical in nature and comprised of all employees below the classification of coordinator.  Creating a Head Start unit would simply replicate that existing structure. 

In evaluating the extent of the employer’s organization and making unit determinations, the agency also endeavors to avoid stranding groups of employees to the extent that they are unable to exercise their collective bargaining rights.  City of Blaine, Decision 6619 (PECB, 1999).  Finding the petitioned-for unit inappropriate here creates such a risk.  The Children’s Center and Head Start programs have existed side by side for decades.  During this time, the SCCA has not sought to represent the group via any petition before this agency.  When presented with the opportunity to intervene in the instant proceeding, the SCCA declined.

The employer asserts that it would be inappropriate to certify the Head Start employees at this time because it intends to combine students from the three separate programs into single classrooms once the Early Learning Center is completed in January 2019.  The appropriate time to evaluate the duties, skills, and working conditions of the petition-for employees is the time at which the petition was filed.  Absent compelling evidence of concrete changes to the petitioned-for employees’ wages, hours, and working conditions, this agency relies on the factual situation as it exists when a petition is filed.  City of Yakima, Decision 9983-A.  Although the evidence establishes the decision to combine the students of its three pre-k programs into blended classrooms at an unidentified point in the 2018–2019 school year has been made, many of the practical effects as to how that decision will be implemented have not been determined.  Furthermore, there is no evidence demonstrating that the work of any employees in the three different programs will be substantially altered as a result of the decision.

Permitting the Head Start employees to organize as a stand-alone unit will not create a work jurisdiction issue.  Co-teaching in blended classrooms already occurs on a regular basis.  SEA‑represented certificated staff integrate the special education students into the Children’s Center and Head Start classrooms on a regular basis.  There is no evidence that the current practice has created any work jurisdiction issues.  The creation of a separate Head Start unit would thus not create any potential issues that do not already exist as a result of the district’s own actions.  Having determined that the petitioned-for bargaining unit is an appropriate bargaining unit configuration, the final step is to determine Ogden’s status to be included in that unit.

Supervisory Status

Ogden is not a supervisory employee because she does not perform a preponderance of the statutory supervisory duties and she spends less than a preponderance of time performing supervisory duties.  Ogden does not have the authority to hire, promote, transfer, layoff, recall, suspend, discipline, or discharge other employees.  She testified that she does not have the authority to assign employees to a given work location, shift, or significant overall duties.  Rather, these responsibilities are vested solely with the early learning director.  Thus, she does not perform a preponderance of the supervisory duties.

Ogden also does not spend a preponderance of her time performing supervisory duties.  Although Ogden periodically fills in for Clark, the evidence demonstrates that this occurs twice a month.  These instances of limited supervision fail to meet the preponderance of time standard.

CONCLUSION

The Head Start coordinator is not a supervisor within the meaning of Chapter 41.56 RCW or WAC 391-35-340.  The petitioned-for group of classified Head Start employees share a sufficient community of interest to constitute a unit appropriate for the purposes of collective bargaining.  The matter is remanded to the Representation Case Administrator for further processing consistent with this decision.

FINDINGS OF FACT

1.                  The Shoreline School District (employer) is a public employer within the meaning of RCW 41.56.030(12).

2.                  The Public School Employees of Washington (union) is a bargaining representative within the meaning of RCW 41.56.030(2).

3.                  The employer offers a range of pre-kindergarten (pre-k) care and educational programs for children aged three to five.  The district’s early learning department contains three components, all of which are overseen by Director of Early Learning Hillery Clark.

4.                  Pre-k students with disabilities are provided special education services through the district’s Early Childhood Education program.  The program’s content and direction is mandated by the federal Individuals with Disabilities Education Act.  The program is currently staffed by eight certificated teachers and thirteen paraeducators.  The special education certificated teachers are represented by the Shoreline Education Association (SEA).  The paraeducators are represented by the Shoreline Educational Support Professionals Association (SESPA).

5.                  Standard daycare and pre-k classes are offered through the Shoreline Children’s Center (Children’s Center) program.  The Children’s Center represents the largest component of the early learning department.  The Children’s Center is funded through tuition.  Shoreline Children’s Center Director Kelly Davidson oversees the program and reports directly to Clark.  The program is divided into the Extended Care component and the pre‑k daycare and pre-k class component.

6.                  The pre-k daycare and pre-k classes at the Children’s Center are staffed by 12 childcare leads and 21 childcare assistants.  The leads are responsible for teaching classes.  The childcare lead positions require an associate’s degree in early childhood education or an equivalent degree.  The childcare assistants support the work of the leads.  The childcare assistants require a high school diploma plus either experience with or course work in early childhood education.  The childcare leads and childcare assistants are represented by the Shoreline Children’s Center Association (SCCA).

7.                  The Children’s Center also employs family advocates who serve as primary information resources and liaisons, connecting families with the district, other appropriate community agencies, and social services.  The family advocates provide support for students in both the tuition-based program as well as the federally funded pre-k special education program.  The role of the family advocate is duplicated elsewhere in the district, with individuals working in similar capacities in a number of elementary schools as well in as the high schools.  The family advocates in the Children’s Center, as well as those working in the district’s elementary and high schools, are represented by SESPA.

8.                  The employer provides a second pre-k program known as Head Start.  Children are accepted into the program based upon their family’s income or if a child is otherwise considered “at risk,” such as being an unaccompanied minor, in foster care, or homeless.

9.                  Funding for the Head Start program is provided by the United States Department of Health and Human Services (DHHS) to the Puget Sound Educational Service District (PSESD).  The Shoreline School District, in turn, contracts with PSESD to operate the Head Start program.  Funding for the program is tied to the district’s compliance with a range of regulations established by DHHS and PSESD.

10.              The program is staffed by Head Start Coordinator Holly Ogden, 10 Head Start lead teachers,  4 Head Start assistants, and 3 Head Start family support personnel.  All employees in the Head Start program are currently unrepresented and are the subject of this petition.  Like the staff of the special education program, the Head Start employees report directly to Clark.

11.              Ogden is responsible for ensuring the smooth operation of the program’s daily activities.  Ogden does not have the authority to grant leave requests or assign overtime.  She does not assign employees to a given shift or classroom and is not responsible for assigning employees their duties.  Ogden does not transfer employees between job classifications or perform evaluations.  Instead, these responsibilities fall within Clark’s purview.

12.              Ogden is not responsible for disciplining or firing employees.  Her role in hiring is limited to one occasion when she was a member of an interview panel for a Head Start assistant position.  In addition to Ogden, the panel included various other stakeholders, including members of the public.  All final hiring decisions are made by the employer’s human resources office. Ogden may serve as acting director when Clark is absent.  Ogden estimates this occurs twice a month.  While serving as acting director, she may call in a substitute in order to maintain the requisite student-to-teacher ratio.

13.              The Head Start lead teachers design and implement daily lesson plans that comply with the curriculum mandated by PSESD.  The Head Start assistants work closely with the lead teachers to maintain an orderly and developmentally appropriate learning environment.  The Head Start lead teachers are required to have an associate’s degree with some early childhood education courses, as well as access to a vehicle and a valid driver’s license.  The Head Start assistants must have an early childhood education certificate or degree.

14.              The Head Start family support employees serve as the bridge between the program and the families of children enrolled in the program.  The family support employees’ duties include enrolling children in the program, monitoring student attendance, and providing families with support.  Overall, they facilitate positive parent, school, and student relationships.  The lead teachers interact daily with the family support employees.

15.              Prior to beginning work in the program, all Head Start employees must complete an extensive training program offered by PSESD at its Renton facility.  This training is not provided to other district employees.  Completion of annual training specific to Head Start also is required.

16.              The Head Start program requires staff to perform certain duties not required of the employer’s other pre-k employees. These duties include home visits; recurring vision, hearing, and health screenings of students; and daily charting to track child development along a range of metrics.  Completing the requisite documentation occupies a substantial portion of the leads’ planning time before and after class.

17.              There is limited evidence of permanent or temporary employee transfers into or out of the Head Start program.  In one case, an employee from the Head Start program was hired to fill the position of the Children’s Center coordinator.  One part-time Head Start assistant also works part-time as a childcare assistant.

CONCLUSIONS OF LAW

1.                  The Public Employment Relations Commission has jurisdiction in this matter under Chapter 41.56 RCW and Chapter 391-25 WAC.

2.                  Based upon findings of fact 11 and 12, the Head Start coordinator is a public employee under RCW 41.56.030(11) and is not a supervisor under WAC 391-35-340 or as described in RCW 41.59.020(4)(d).

3.                  Based upon findings of fact 3 through 10 and 13 through 17, the petitioned-for employees share a community of interest sufficient to make the bargaining unit appropriate under RCW 41.56.060.

ORDER

The matter is remanded to the Representation Case Administrator for further processing consistent with this decision.

ISSUED at Olympia, Washington, this 24th day of September, 2018.

PUBLIC EMPLOYMENT RELATIONS COMMISSION

MICHAEL P. SELLARS, Executive Director

This order will be the final order of the
agency unless a notice of appeal is filed
with the Commission under WAC 391-25-590.