Veterans Administration Medical Center, Tampa, Florida v. Federal Labor Relations Authority

THORNBERRY, Circuit Judge:

In this collective bargaining dispute, we are asked to decide whether a rational basis supports the Federal Labor Relations Authority’s determination that a federal agency1 has a duty to bargain over a union2 proposal concerning the procedures to be followed in personnel actions, when those procedures would not prevent the agency from “acting at all” on such personnel actions. The agency argues that it should not have a duty to bargain when the proposed procedures would “unreasonably delay” its ability to make personnel decisions. Although the choice between these…