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B. Counter Proposal Two: "Parity and Flat-Amount Increase" <br /> The second counter proposal offered by the Union would also mirror the Sheriff's proposal <br /> with only one difference: <br /> 1. Instead of a 5% across the board raise, all bargaining unit members would receive an <br /> across the board raise of$3,550.00. <br /> See Union Ex. 4. <br /> The Union offered this proposal to accomplish parity within the bargaining unit and <br /> achieve the Sheriff's desired goal of increasing starting pay to $42,000.00. Tr. 15. See also Tr. <br /> 73. As noted previously, the Sheriff's proposal does not provide an "across the board" raise. <br /> Instead, new employees can earn as much as a 9.1% raise, while the rest of the bargaining unit <br /> receives only 5%. Those employees who would receive a 9.1% raise would receive $3,550 as a <br /> total salary increase. See Union Ex. 5 (42,500 - $38,950 = $3,550). Therefore, in order to have <br /> complete parity in the bargaining unit the Union offered its Counter Proposal Two which would <br /> provide every employee with at least one-years' experience the exact same dollar amount raise <br /> ($3,550). See Union Ex. 4. Union Counter Proposal Two did not request to increase all twenty- <br /> plus(20+)year employees to topped pay. This was because the Union recognized that this counter <br /> proposal would top-out most of the twenty-plus (20+) Deputies and get the rest within <br /> approximately$1,400 of top-out pay. Tr. 16 <br /> It is of particular note,the Sheriff's bargaining representatives never stated that their refusal <br /> to agree to the Union's counter proposal was due to the cost of the proposal. See Tr. 12, 72. In <br /> fact, the Sheriff's Office has never stated to the Union that this proposal is in excess of the total <br /> budgeted amount for salaries for Fiscal Year 2018-2019. See Tr. 13, 72-73 (Harpring: "I didn't <br /> 5 <br /> 22 <br />