City of Holyoke, 35 MLC 153, 156, MUP-05-4503 (January 9, 2009) (citing 21 Town of Dracut, 25 MLC 131, 133, MUP-1397 (February 17, 1999)). The Union contends 22 that the Citys decision to end the rolling blackouts and to decommission Engine 11 23 without bargaining with the Union constituted an adverse action because it impacted unit 39 H.O.

City of Boston, 35 MLC 289, 291 (2009); Town of Dracut, 25 MLC 131, 133 (1999), and when objective aspects of the work environment are affected, City of Holyoke, 35 MLC 253, 156 (2008). Although Fay received his base salary while he was on administrative leave, he was materially disadvantaged because he no longer had the opportunity to earn pay for working details and overtime.

City of Holyoke, 35 MLC 153, 156, MUP-05-4503 (Jan. 9, 2009) (citing Town of Dracut, 25 MLC 131, 133, MUP-1397 (Feb. 17, 1999)). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. City of Boston, 35 MLC 289, 291, MUP-04-4077 (May 20, 2009) (citing MacCormack v. Boston Edison Co., 423 Mass. 652, 662 (1996)).

City of Holyoke, 35 MLC 153, 156 (2009) (citing Town of Dracut, 25 MLC 131, 133 (1999)). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291 (2009) (citing MacCormack v.

Many management 153, 156 (2009) (citing Town of Dracut, 25 MLC 1371, decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291 (2009) (citing MacCormack v.

City of 5 Holyoke, 35 MLC 153, 156, MUP-05-4503 (Jan. 9, 2009) (citing Town of Dracut, 25 MLC 131, 6 133, MUP-1397 (Feb. 17, 1999)). Here, the City issued Jacques a written reprimand on 7 December 11, 2020. It is well-established that an employee reprimand constitutes an adverse 8 employment action. See Athol-Royalston School Committee, 28 MLC 204, 214-15, MUP-2279 9 (January, 14, 2002).

City of Lawrence, MUP-14-3666 (CERB Sept. 21, 2016), citing Sheriff of Worcester County 27 MLC 103, 106 (2001); Town of Dracut, 7 MLC 1342 (1980)(noting unequivocally that dress codes are mandatory subjects of bargaining.) The central issue in both unilateral change claims is whether the City either changed an existing practice or implemented a new one. In a nutshell, the Citys defense to these claims is no change and nothing new.

City of Holyoke, 35 MLC 153, 156 (2009)(citing Town of Dracut, 25 MLC 131, 133 (1999)). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291 (2009)(citing MacCormack v.

Cityof Holyoke, 35 MLC 153, 156 (2009) (citing Town of Dracut, 25 MLC 131, 133 (1999). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291 (2009) (citing MacCormack v.

Cityof Holyoke, 35 MLC 153, 156 (2009) (citing Town of Dracut, 25 MLC 131, 133 (1999). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291 (2009) (citing MacCormack v.

City of Boston, 35 MLC 289, 291, MUP-04-4077 (May 20, 2009); Town of Dracut, 25 MLC 131, 133, MUP-1397 5 Complaint and Partial Dismissal (Contd) MUP-22-9261 (February 17, 1999). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way.