Upper Makefield Township (Employer) petitions for review of a final order of the Pennsylvania Labor Relations Board (Board) entered July 8, 1997 in which the Board found that Employer committed an unfair labor practice when it refused to proceed to arbitration of a grievance filed by the Upper Makefield Township Police Association (Association). The grievance arose out of the parties’ 1990-1992 collective bargaining agreement (Agreement). The question presented to this Court is whether an employer must arbitrate a grievance where the griev-anee procedure set forth in the parties’ collective bargaining agreement does not require arbitration as the last stage in a four-step grievance procedure.
The facts of this matter are not in dispute. On July 21, 1992, the Association filed a grievance on behalf of Matthew Shrum, who was terminated as a police officer prior to the end of his probationary period for insubordination and conduct unbecoming an officer. Employer refused to process the grievance through the grievance procedure set forth in the Agreement because Shrum was a probationary employee and according to Employer was no longer classified as a police officer as defined in the Agreement. This began a somewhat lengthy procedural history that is largely not relevant here, except that it resulted in the grievance being processed through the four steps of the grievance procedure and ultimately denied in December 1995 by Employer’s Board of Supervisors at the last step in the grievance process.1 Next, the Association notified Employer that it intended to proceed to binding arbitration. Employer refused because the Agreement included no step for grievance arbitration, and, therefore, Employer believed that it was not required to submit the grievance to arbitration.
On January 3, 1996, the Association filed the unfair labor practice charge alleging that Employer violated the Act of June 24, 1968, P.L. 237, as amended, 43 P.S. §§ 217.1-217.10, commonly known as “Act 111,” and Sections 6(l)(a) and (e) of the Pennsylvania Labor Relations Act (PLRA), Act of June 1, 1937, P.L. 1168, as amended, 43 P.S. §§ 211.6(1)(a) and (e),2 by refusing to pro*600ceed to arbitration. The Board concluded that both this Court and the Supreme Court have recognized that Act 111 mandates binding arbitration of all grievances arising under collective bargaining agreements negotiated thereunder, and as a result Employer’s refusal to arbitrate constituted an unfair labor practice.3
I
Employer asserts that it was not required under the Agreement to submit to grievance arbitration where it negotiated with the Association in good faith and reached the Agreement and processed the grievance through all steps of the grievance procedure and abided by the outcome. Employer argues that the Board’s decision was unreasonable, arbitrary and illegal and that it erred in concluding that this Court’s decision in West Lampeter Township v. Police Officers of West Lampeter Township, 143 Pa.Cmwlth. 226, 598 A.2d 1049 (1991), appeal denied, 531 Pa. 658, 613 A.2d 562 (1992), is no longer good law in light of Pottstown Police Officers’ Association v. Pennsylvania Labor Relations Board, 160 Pa.Cmwlth. 87, 634 A.2d 711 (1993) (en banc), and it further argues that the Board erred in concluding that a statutory duty to arbitrate grievances has been recognized by the Courts.
A brief review of the history of the existing public sector labor statutes is instructive. In 1967, Article III, § 31 of the Pennsylvania Constitution was amended to permit enactment of statutes that incorporate the use of binding arbitration and collective bargaining in the public sector because previously the constitutional scheme did not permit public employers to delegate responsibilities through collective bargaining agreements or binding arbitration awards. Harney v. Russo, 435 Pa. 183, 255 A.2d 560 (1969). Shortly thereafter Act 111 was enacted, which eon-ferred the right to collective bargaining upon police and firefighters but withheld the right to strike because of the crucial services they performed. Township of Moon v. Police Officers of the Township of Moon, 508 Pa. 495, 498 A.2d 1305 (1985). To resolve bargaining impasses in the absence of the employees’ ability to strike as an economic weapon, Act 111 included a mandate to employers to engage in binding interest arbitration pursuant to the procedures specified therein. Id.
The legislature next enacted the Public Employee Relations Act, Act of July 23, 1970, P.L. 563, as amended, 43 P.S. §§ 1101.101-1101.2301, commonly known as “Act 195”, which conferred the right to bargain collectively on the remaining public employees. Because their services were not as critical to public safety and welfare, the legislature conferred a limited right to strike and an interest arbitration procedure that is voluntary rather than mandatory. Moon. However, Act 195 withheld the right to strike from guards at prisons and mental hospitals and court employees, and it mandated binding interest arbitration because these employees’ services are more critical to public safety and welfare. Sections 805 and 1001 of Act 195, 43 P.S. §§ 1101.805 and 1101.1001; Moon. Also in Act 195, the legislature included an express mandate in Section 903, 43 P.S. § 1101.903, that parties must include binding arbitration as a final step in any contractual grievance procedure.4
The Board reasoned that the legislature incorporated a similar mandate in Act 111, and relied in part on the following language set forth in Section 4:
(a) If in any case of a dispute between a public employer and its policemen or firemen employes the collective bargaining process reaches an impasse and stalemate, or if the appropriate lawmaking body does *601not approve the agreement reached by collective bargaining, with the result that said employers and employes are unable to effect a settlement, then either party to the dispute, after written notice to the other party containing specifications of the issue or issues in dispute, may request the appointment of a board of arbitration....
43 P.S. § 217.4(a). Section 4 specifically addresses the subject of interest arbitration and contains no directions concerning grievance arbitration or its procedures. Pennsylvania State Police v. Pennsylvania State Troopers Association (Betancourt), 540 Pa. 66, 656 A.2d 83 (1995); Moon.
The Board concluded that various Supreme Court decisions, including Chirico v. Board of Supervisors for Newton Township, 504 Pa. 71, 470 A.2d 470 (1983), Moon and Betancourt, and this Court’s decisions particularly in Pottstown and in Upper Providence Township v. Buggy, 100 Pa.Cmwlth. 389, 514 A.2d 991 (1986), demonstrate judicial recognition of the existence of an Act 111 mandate for grievance arbitration. However, review of these decisions demonstrates that the question of whether Act 111 contains a statutory mandate for grievance arbitration was not addressed by either the Supreme Court or this Court. Indeed, in Pottstown the issue involved the question of the Board’s jurisdiction to determine whether an employer’s alleged refusal to comply with the dispute resolution provisions of an Act 111 agreement constitutes an unfair labor practice. The issue presented here concerns the nature of the grievance procedure itself and whether it contains a process not established by terms of the Agreement.
The Supreme Court has held simply that Act 111 authorizes grievance arbitration. Chirico; Moon; Betancourt. The Board and the Association further argue that the Supreme Court interpreted Section 1 of Act 111 as “providing] the right to an adjustment or settlement of grievances and disputes under the terms of an existing collective bargaining agreement.” Moon, 508 Pa. at 505, 498 A.2d at 1310. Section 1 provides as follows:
Policemen or firemen employed by a political subdivision of the Commonwealth or by the Commonwealth shall, through labor organizations or other representatives designated by fifty percent or more of such policemen or firemen, have the right to bargain collectively with their public employers concerning the terms and conditions, including compensation, hours, working conditions, retirement, pensions and other benefits, and shall have the right to an adjustment or settlement of their grievances or disputes in accordance with the terms of this act.
43 P.S. § 217.1 (emphasis added). The Board relied as well on the language emphasized above in Section 1 to support its conclusion that Act 111 contained an express mandate for grievance arbitration since its inception. However, it is apparent that Section 1 does not express the same clear mandate for grievance arbitration expressed in Act 195.
In Chirico the Supreme Court stated that the “only method for settling grievance disputes allowable within the framework of Act 111 is arbitration.” 504 Pa. at 79, 470 A.2d at 475. The Board and the Association argue that this statement amounts to the court’s recognition of a statutory mandate. However, this reading ignores the context in which the statement was made, and it is overbroad. The Supreme Court noted that the dispute there concerned the interpretation and legality of provisions of an Act 111 interest arbitration award, and it noted at the outset of its discussion of this issue that “[a] dispute over the interpretation of a provision in an existing award falls within the ambit of grievance arbitration.” 504 Pa. at 77, 470 A.2d at 474. The court stated that Act 111 specifically avoids resort to the courts for collective bargaining impasse resolution and that labor arbitrators are in the best position to resolve disputes that arise out of an existing interest award. For these reasons the court held that the proper forum for resolution of the dispute was grievance arbitration since the right to be enforced was not clear where an ambiguity existed. The Board and the Association assert that the Supreme Court’s reasoning in Chirico supports the conclusion that arbitration is the only appropriate forum for all grievance disputes even where the parties agreed otherwise. This Court, how*602ever, does not read Chirico so broadly, especially where the language of Act 111 itself sets forth no such mandate.
In Pottstown this Court considered the sole question of whether the Board possessed the jurisdiction to decide if an employer’s alleged refusal to comply with a decision under the dispute resolution provisions of an Act 111 agreement constitutes an unfair labor practice. The Court stated that Act 111 had been previously interpreted as mandating interest and grievance arbitration. Moon. Contrary to assertions by the Board and the Association, the above statement does not amount to the recognition of a statutory mandate for arbitration of all grievances. It appears that the Board and the Association have ignored the citations that immediately followed the statement, which reveal that the Court was simply summarizing established legal principles, including the holding in Moon.5 The Court concluded that the Board possessed jurisdiction to decide if Pottstown’s alleged refusal to arbitrate the grievance filed by the officer constituted an unfair labor practice. The Court went one step further and held that Pottstown’s alleged refusal to comply with the result of the dispute resolution process must be treated just as an employer’s refusal to participate in that process.
II
The question resolved in Pottstoum is clearly distinct from the question presented by Employer in the case presently before the Court. See also Moon and Buggy (questions presented involved whether specific terms of an interest arbitration award were lawful and whether a dispute over ambiguous and vague terms of an agreement required an arbitrator’s interpretation in order to resolve a dispute between the employer and employees, respectively). The Board concluded, nonetheless, that West Lampeter is inconsistent with the holding in Pottstown; it erred in doing so and in refusing to apply West Lampeter.
In West Lampeter a contractual grievance procedure existed that included no step for binding arbitration but expressly provided that the decision of the employer’s board of supervisors was final. After the grievance involving an officer’s ten-day suspension was processed through step one of the two-step grievance procedure and denied, the employee waived step two and notified the township that he wanted to proceed to binding arbitration. The employer refused. The union then filed an action in mandamus, seeking to compel the employer to arbitrate under the agreement. The trial court ordered that the question be resolved by a binding arbitration panel. This Court reversed, reasoning that the agreement between the parties did not require the employer to arbitrate the grievance, and it therefore denied the petition for mandamus.
The question in West Lampeter was whether the parties’ agreement required the employer to submit the grievance there to arbitration. The Court stated in pertinent part:
The Township argues, and we agree, that Chirico, Moon, and Buggy are distinguishable from the present matter, because in each case the courts ‘filled a void left by the absence of legislation or agreement of the parties.’ In the present matter, however, according to the Township, the parties engaged in collective bargaining culminating in the Agreement, which included Section 20 describing a grievance procedure. The Agreement also contained a section indicating that the Agreement superseded all previous agreements and/or arbitration awards and contained all covenants between the parties.
... By not providing, on the face of the agreement, for arbitration of grievances, the parties, according to the Township, *603have made ‘a conscious decision to exclude arbitration from the dispute resolution process.’ According to the Township, the Agreement has provided a mechanism for resolving grievances and that fact distinguishes the present matter from Chineo, Moon, and Buggy, where ‘either the collective bargaining process or the interest arbitration award system had failed to provide the grievant with a vehicle or forum to resolve his grievance.’ We agree.
The Agreement is devoid of any requirement for grievance arbitration. This matter does not involve the situation where a term of a collective bargaining agreement is ambiguous or in need of interpretation. The Agreement clearly provides for a two step grievance procedure, of which McCord availed himself of step one but chose to waive step two. Having freely bargained for the grievance procedure, the parties are bound by it, and, therefore, the officers are mistaken in their belief that they may, at their pleasure, substitute binding arbitration for step two of the grievance procedure.
Id., 598 A.2d at 1051. The Court concludes that just as in West Lampeter, Employer here had no duty to submit the grievance at issue to arbitration. Further, the Court reaffirms the reasoning and holding in West Lampeter and declines to accept the Board’s position that West Lampeter is no longer good law.
Finally, the Board and the Association argue that without statutorily mandated grievance arbitration, Employer’s interpretation of the contract will control even where that interpretation is made in bad faith. However, the Court concludes that the absence of this procedure did not give rise to a bad faith interpretation by Employer but effectively left resolution of the grievance to Employer, and the Court finds no inconsistency in this result with the PLRA or the statutory language or policies of Act 111.6 In addition, the Court does not agree with the assertion that in the absence of a statutory mandate, pre-arbitral bouts of litigation wasteful of administrative and judicial resources will proliferate. It is the essence of collective bargaining that parties are free to bargain for advantages in exchange for concessions. Plainfield Township Policemen’s Association v. Pennsylvania Labor Relations Board, 695 A.2d 984 (Pa.CmwIth.), appeal denied, 549 Pa. 730, 702 A.2d 1062 (1997).
The Court’s holding today neither enlarges nor diminishes the rights of public employees under Act 111 to binding arbitration in circumstances where this right is established, such as when a collective bargaining impasse occurs, when an agreement or interest award expressly provides for a grievance procedure culminating in binding arbitration or when an ambiguity exists in an existing interest award. Section 4; Moon; Chirico. Accordingly, the Board’s determination that Employer committed an unfair labor practice is reversed.
ORDER
AND NOW, this 27th day of August, 1998, the final order of the Pennsylvania Labor Relations Board entered July 8, 1997 is hereby reversed.
. The grievance process provides for the following steps:
Article XIV — Grievance Procedure
Grievances arising between the Township and the Department or between the Township and an officer of the Department shall be taken up in accordance with the following procedure: Step 1. Request for complaint is made to the immediate ranking officer.
Step 2. In the event of an unsatisfactory result in Step 1, the request or complaint shall be made in the chain of command up to and including the Chief of Police.
Step 3. In the event of an unsatisfactory resolution through the chain of command, a meeting may be requested and held with the police liaison officer of the Board of Supervisors. Step 4. If the police liaison is unable to provide a specific resolution, a meeting may be requested and held with the Township’s Board of Supervisors.
. Sections 6(l)(a) and (e) provide as follows:
(1) It shall be an unfair labor practice for an employer-
fa) To interfere with, restrain or coerce employes in the exercise of the rights guaranteed in this act.
*600(e) To refuse to bargain collectively with the representatives of his employes, subject to the provisions of section seven (a) of this act.
. This Court's review of a Board final order is limited to determining whether the necessary findings of fact are supported by substantial evidence of record and whether a constitutional violation or error of law was committed. City of Harrisburg v. Pennsylvania Labor Relations Board, 146 Pa.Cmwlth. 242, 605 A.2d 440 (1992).
. See also Pennsylvania Labor Relations Board v. Bald Eagle Area School District, 499 Pa. 62, 451 A.2d 671 (1982); Chester Upland School District v. Pennsylvania Labor Relations Board, 655 A.2d 621 (Pa.Cmwlth.1995), aff'd per curiam, 544 Pa. 199, 675 A.2d 1211 (1996).
. The Court cited the following: "See 43 P.S. § 217.4; Article III, § 31 of the Pennsylvania Constitution; Township of Moon v. Police Officers of the Township of Moon, 508 Pa. 495, 498 A.2d 1305 (1985).” The Court reiterated the principles that interest arbitration involves an inability of the parties to agree upon terms for a collective bargaining agreement, whereas grievance arbitration involves a third-party resolution of a dispute between a public employer and a public employee over the interpretation of an existing agreement. Pottstown, 160 Pa.Cmwlth. at 90 n 4, 634 A.2d at 713 n 4.
. The Supreme Court has held that Act 111 must be read in pari materia with the PLRA, and it has declined to incorporate Act 195’s provisions for mandatory grievance arbitration into Act 111. Geriot v. Council of Borough of Darby, 491 Pa. 63, 417 A.2d 1144 (1980) (Nix, J. dissenting). The PLRA contains no guaranteed right to grievance arbitration, and a refusal to arbitrate grievances arising out of collective bargaining agreements under Act 111 is not a per se violation of unfair labor practice provisions of the PLRA. Warwick v. Pennsylvania Labor Relations Board, 671 A.2d 1199 (Pa.Cmwlth.), appeal denied, 545 Pa. 666, 681 A.2d 180 (1996).