Perb

Petitioner California Faculty Association (the association),

which is the exclusive bargaining representative for certain employees of the California State University (the university), complained to the Public Employment Relations Board (the board) that the university committed an unfair labor practice when it excluded members of the association’s bargaining unit from parking in newly built parking structures on the Northridge and Sacramento campuses of the university without first giving the association an opportunity to bargain over the issue. Rejecting a proposed decision by an administrative law judge (ALJ) to the contrary, the board concluded the university had not committed an unfair labor practice because the university had no “duty to bargain a change of parking location.” The board based this conclusion on the determination that “parking location does not involve the ‘employment relationship.’ ”

On writ review of the board’s decision, we conclude that the terms and conditions on which the university provides parking to its employees— including where the employees are allowed to park—do involve the employment relationship between the university and its…