Department of Central Management Services -vs- American Federation of State, County, and Municipal Employees, Council 31: The Board found that the individuals represented by petitioner, a collection of employees from the Pollution Control Board, were subject to removal from their collective bargaining units upon being designed by the Governor as exempt from collective bargaining under a 2013 statute. We find that the individuals' collective bargaining rights were beyond the reach of the Governor and that the Board should have dismissed the Governor's petitions.