Is a public agency required to consult with an employee representative before making changes to a bargaining unit?

"[A] public agency must meet and consult with any recognized employee representative prior to adopting (or modifying) rules and regulations themselves, but it need not do so when determining whether an individual proposed bargaining unit is appropriate under rules previously adopted." (Service Employees Internat. Union v. City of Santa Barbara (1981) 125 Cal.App.3d 459, 469, 178 Cal.Rptr. 89.) Under section 1 of the existing memorandum of understanding between the City and County of San Francisco and appellant, for fiscal year 1980-1981, the city was specifically not precluded from transferring a particular classification to another "more appropriate unit," and there was no meet and confer requirement for such action. ¹ We find that under those existing rules, the city was also not required to meet and confer with appellant before reorganizing and reclassifying one and one-half positions within a particular classification simply because such action affected the size of appellant's bargaining unit.

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