Substantial evidence that pension contribution scehme was integrated into the CBA, the Board decision affirmed the ALJ, who drew a rate from an earlier form of the agreement, but the ALJ's determination was arguably not dispositive of the holding, and substantial evidence exists to the contrary.
Accepted appendix to CBA and a reference in the CBA incorporating an attachment were sufficient writings to permit the pension contributions under a stsatute requiring written agreements for such payements.
Employer practice consistent with the writings at the end of the CBA meant that those terms remained in force after the period of the CBA, so the diminution of contributions was an unfair labor practice.
Disssent:
Unsigned, undated standalone writing insufficient. ALJ implicitly made this determination in accepting the earlier rate.