Alaska Public Employees Ass'n v. State, Department of Administration, Division of Labor Relations

RABINOWITZ, Justice,

concurring.

I agree with the various holdings in this opinion. However, I disagree with the court’s exclusive reliance on the NLRA for purposes of determining when the state may unilaterally change the terms of class II employee contracts under PERA.1

In part the NLRA is designed so that upon a good faith impasse, parties can break off negotiations to pursue their respective interests through “economic warfare.” In particular, a union may respond to what it deems to be an unfair unilateral change in working conditions by striking.2 The NLRA provides a statutory scheme in which both the requirement of good faith negotiations, “and the availability of economic pressure devices to each to make the other party incline to agree on one’s terms, exist side by side.... Doubtless one factor influences the other....”3

PERA, as it pertains to class II employees, embodies a scheme which compromises the parties’ right to use economic force in exchange for certain dispute resolution provisions. Under PERA, class II employees are granted a qualified right to strike. However, strikes are not permitted until after mediation procedures have been exhausted. Furthermore, the state can seek an injunction to force the union to submit to arbitration. AS 23.40.200(c). Thus, unlike the NLRA, PERA provides for mandatory dispute resolution devices. The difference in these statutory schemes comes into play when negotiations are deadlocked.

A union governed by the NLRA may forcefully respond to an employer’s imposition of unilateral changes at impasse.4 On the other hand, if the state were permitted under PERA to impose unilateral changes during a compulsory mediation or arbitration period, the union would be restrained by statute from responding. Employees under PERA are unable during these periods to resort to “economic warfare.”

In my view the policy basis for holding that unilateral changes may not be imposed during statutory mediation periods are as follows: First, since employees are precluded by statute from striking during mediation periods, it would be unfair to allow an employer, shielded from employee economic force, to impose unilateral changes in working conditions. Second, if an employer were permitted to impose unilateral changes during mediation, it would have less incentive to bargain over the issues subject to the change. This latter conclusion was reached by a California appellate court in applying a public sector labor act with mediation provisions similar to PERA’s.5 In considering the issue of em*1035ployer unilateral changes during mandatory “no-strike” mediation periods, the court explained that their allowance would serve to undermine mediation efforts, as the employer would “lose[] incentive to participate in the dispute resolution process.”6

In order to resolve the problems unique to PERA by analogy to federal labor law, the court holds that “impasse” does not occur at the time negotiations become deadlocked. Rather, the majority holds that “impasse” occurs only after the statutory mediation period which follows deadlock. See AS 23.40.190 (mediation to begin after negotiation deadlock). Though I agree with the conclusion that impasse occurs not at deadlock, but only after the statutory mediation period which follows deadlock, I am of the view that this result flows more logically from the principles set forth above than from the provisions of the NLRA.

. "No provision in Alaska’s labor statutes mandates that ... the NLRA be employed as [an] interpretive aid[ ] ... [where the statutes have] different purposes and policies....” United Food and Commercial Workers Union v. D & A Supermarkets, Inc., 688 P.2d 165, 168 (Alaska 1984).

. This is permitted even before the parties have reached an impasse. NLRB v. Insurance Agents’ Int'l Union, AFL-CIO, 361 U.S. 477, 493-95, 80 S.Ct. 419, 429-30, 4 L.Ed.2d 454, 467 (1960).

. Id. at 489, 80 S.Ct. at 427, 4 L.Ed.2d at 464.

. Id.

. Moreno Valley Unified School Dist. v. Public Employment Relations Bd., 142 Cal.App.3d 191, 191 Cal.Rptr. 60, 65 & n. 4 (Cal.App.1983). The *1035California Educational Employment Relations Act provides for non-binding mediation upon impasse, during which strikes are forbidden. Cal. Gov't Code §§ 3548-3548.8; San Diego Teachers' Ass'n v. Superior Court, 24 Cal.3d 1, 154 Cal.Rptr. 893, 593 P.2d 838, 843 (1979) (prohibition against strikes during mediation “assumed" to be part of statutory scheme, though not expressly stated in act).

. Moreno, 191 Cal.Rptr. at 65 & n. 4. Public sector labor laws such as PERA and the California act discussed in Moreno generally involve some dispute resolution process to be "substituted for direct economic action.” B. Justice, Unions, Workers and the Law 248 (1983). Accordingly, decisions under such laws can serve to provide guidance in resolving questions of the type presented here.