OPINION

McCONNELL, P. J.—

INTRODUCTION

This appeal requires us to decide whether the provisions in the Meyers-Milias-Brown Act (Act) (Gov. Code, § 3500 et seq.)1 for impasse resolution through advisory factfinding (factfinding provisions) apply to impasses arising during the negotiation of any bargainable matter or only to impasses arising during the negotiation of a comprehensive memorandum of understanding (MOU).2 We conclude the factfinding provisions apply to impasses arising during the negotiation of any bargainable matter. As the trial court determined otherwise, we reverse the court's judgment and remand the matter for further proceedings consistent with our decision.

BACKGROUND

The San Diego Housing Commission (Commission) is a local public agency subject to the Act. (§ 3501, subd. (c).) Service Employees International Union, Local 221 (Union), is an employee organization and the exclusive representative of certain Commission employees. The Public Employment Relations Board (Board) is a quasi-judicial administrative agency modeled after the National Labor Relations Board and administers the Act. (County of Los Angeles v. Los Angeles County Employee Relations Com. (2013) 56 Cal.4th 905, 916 [157 Cal.Rptr.3d 481, 301 P.3d 1102] (County of Los Angeles); §§ 3501, subd. (f), 3509, subd. (a), 3541, subd. (g).)

After the Commission and the Union reached an impasse in their negotiations over the effects of the Commission's decision to lay off two employees represented by the Union, the Union made a written request to the Board for the parties' dispute to be submitted to a factfinding panel under section 3505.4, subdivision (a).3 When the Board granted the request over the Commission's objection, the Commission filed this action seeking a declaratory judgment and a writ of mandate prohibiting the Board from ordering the use of factfinding procedures in this case, determining the use of factfinding procedures is not permitted under the circumstances of this case, and restraining the parties from using factfinding procedures on matters unrelated to the negotiation of an MOU.4

The Commission subsequently filed a motion for summary judgment, arguing the Commission was entitled to a declaratory judgment and writ of mandate as a matter of law because the Act's factfinding provisions applied only to an impasse arising during the negotiation of a comprehensive MOU, not to an impasse arising during the negotiation of a discrete, bargainable issue. The court agreed with the Commission's interpretation of the Act and granted the Commission's motion. The court then issued a judgment declaring the Act's factfinding provisions only apply to an impasse arising from the negotiation of a new or successor MOU and do not apply to an impasse arising from any other negotiations. The court also issued a writ of mandate commanding the Board to dismiss the factfinding proceedings requested by the Union, to rescind any requirement for the Commission to participate in factfinding proceedings for impasses not involving the negotiation of a new or successor MOU, and to reject any requests for the Commission to participate in factfinding proceedings for impasses not involving the negotiation of a new or successor MOU. The court later denied the Commission's motion for attorney fees under Code of Civil Procedure section 1021.5.

DISCUSSION

I

The resolution of this appeal turns on the proper interpretation of the Act's factfinding provisions. The interpretation of a statute presents a question of law, which we review independently. (B.H. v. County of San Bernardino (2015) 62 Cal.4th 168, 189 [195 Cal.Rptr.3d 220, 361 P.3d 319]; Santa Clara County Correctional Peace Officers' Assn., Inc. v. County of Santa Clara (2014) 224 Cal.App.4th 1016, 1026 [169 Cal.Rptr.3d 228] (Santa Clara).)

(1) "`Under settled canons of statutory construction, in construing a statute we ascertain the Legislature's intent in order to effectuate the law's purpose. [Citation.] We must look to the statute's words and give them their usual and ordinary meaning. [Citation.] The statute's plain meaning controls the court's interpretation unless its words are ambiguous.' [Citations.] If the words in the statute do not, by themselves, provide a reliable indicator of legislative intent, `[s]tatutory ambiguities often may be resolved by examining the context in which the language appears and adopting the construction which best serves to harmonize the statute internally and with related statutes. [Citation.]' [Citation.] `"Literal construction should not prevail if it is contrary to the legislative intent apparent in the statute ...; and if a statute is amenable to two alternative interpretations, the one that leads to the more reasonable result will be followed [citation]." [Citations.]' [Citation.] If the statute is ambiguous, we may consider a variety of extrinsic aids, including legislative history, the statute's purpose, and public policy." (People v. Arias (2008) 45 Cal.4th 169, 177 [85 Cal.Rptr.3d 1, 195 P.3d 103].)

II

A

(2) The Act imposes a duty on a public agency to "meet and confer in good faith" with a recognized union, "regarding wages, hours, and other terms and conditions of employment ... prior to arriving at a determination of policy or course of action." (§ 3505.) The duty to bargain applies to a decision "directly defining the employment relationship, such as wages, workplace rules, and the order of succession of layoffs and recalls." (International Assn. of Fire Fighters, Local 188, AFL-CIO v. Public Employment Relations Bd. (2011) 51 Cal.4th 259, 272 [120 Cal.Rptr.3d 117, 245 P.3d 845] (Fire Fighters 188).) The duty to bargain also applies to a fundamental management or policy decision if the decision directly affects employment and "`the employer's need for unencumbered decisionmaking in managing its operations is outweighed by the benefit to employer-employee relations of bargaining about'" the decision. (Id. at pp. 273, 274; Claremont Police Officers Assn. v. City of Claremont (2006) 39 Cal.4th 623, 638 [47 Cal.Rptr.3d 69, 139 P.3d 532].) Thus, the duty to bargain extends to matters beyond what might typically be incorporated into a comprehensive MOU, including, as here, the implementation and effects of a decision to lay off employees. (Fire Fighters 188, supra, at p. 277.)

B

Before the passage of Assembly Bill 646, if a public agency and a union reached an impasse in their negotiations, the Act permitted the parties to mutually agree to engage in mediation (§ 3505.2), but did not require the parties to engage in factfinding or any other impasse procedure. (Bagley v. City of Manhattan Beach (1976) 18 Cal.3d 22, 25-26 [132 Cal.Rptr. 668, 553 P.2d 1140]; Fire Fighters Union v. City of Vallejo (1974) 12 Cal.3d 608, 614, fn. 4 [116 Cal.Rptr. 507, 526 P.2d 971].) If there was no impasse procedure applicable by local law or by the parties' agreement, the public agency could unilaterally impose its last, best and final offer. (Santa Clara, supra, 224 Cal.App.4th at p. 1034.)

C

(3) The absence of mandatory impasse procedures in the Act prompted the introduction of Assembly Bill 646. (Santa Clara, supra, 224 Cal.App.4th at p. 1035, fn. 5.) With Assembly Bill 646's passage, if a public agency and a union reach an impasse in their negotiations, the union may now require the public agency to participate in one type of impasse procedure — submission of the parties' differences to a factfinding panel for advisory findings and recommendations — before the public agency may unilaterally impose its last, best, and final offer. (§§ 3505.4, subd. (a), 3505.5, subd. (a), 3505.7.)5

Upon submission of the parties' differences to a factfinding panel, the panel must meet with the parties "and may make inquiries and investigations, hold hearings, and take any other steps it deems appropriate." (§ 3505.4, subd. (c).) In arriving at its findings and recommendations, the panel must consider, weigh, and be guided by several criteria, including "[t]he interests and welfare of the public and the financial ability of the agency"; a "[c]omparison of the wages, hours, and conditions of employment of the employees involved in the factfinding proceeding with the wages, hours, and conditions of employment of other employees performing similar services in comparable public agencies"; "[t]he consumer price index for goods and services, commonly known as the cost of living"; and "[t]he overall compensation presently received by the employees, including direct wage compensation, vacations, holidays, and other excused time, insurance and pensions, medical and hospitalization benefits, the continuity and stability of employment, and all other benefits received." (§ 3505.4, subd. (d)(4)-(7).)6

(4) If the parties do not settle their dispute within a specified or agreed-upon period, the factfinding panel must make advisory findings and recommendations, which the public agency must make publicly available within a specified time after their receipt. (§ 3505.5, subd. (a).) Provided the public agency is not subject to interest arbitration,7 the public agency may proceed to implement its last, best, and final offer, but not an MOU, after the public agency exhausts any applicable mediation and factfinding procedures and conducts a public hearing regarding the impasse. (§ 3505.7.) The public agency's unilateral implementation of its last, best, and final offer "shall not deprive a recognized employee organization of the right each year to meet and confer on matters within the scope of representation, whether or not those matters are included in the unilateral implementation, prior to the adoption by the public agency of its annual budget, or as otherwise required by law." (Ibid.)

III

A

Around the time the court entered its judgment, the Board issued a decision addressing the statutory interpretation question at issue in this appeal. (County of Contra Costa (2014) PERB Order No. Ad-410-M [2014 Cal.PERB LEXIS 14].) The Board held the Legislature intended the Act's factfinding procedures to apply "to any bargaining impasse over negotiable terms and conditions of employment, and not only to impasses over new or successor [MOUs]." (Id. at pp. 2-3.) The Board reaffirmed this holding in a subsequent decision. (City and County of San Francisco (2014) PERB Order No. Ad-419-M [2014 Cal.PERB LEXIS 48].)

The Board based its holding on several factors. First, the Act does not contain any language expressly limiting its factfinding provisions to impasses occurring during the negotiation of a comprehensive MOU. (County of Contra Costa, supra, PERB Order No. Ad-410-M at p. 32.) Second, the Board had consistently applied the analogous factfinding provisions in the Educational Employment Relations Act (EERA) (§§ 3548.1-3548.3) and Higher Education Employer-Employee Relations Act (HEERA) (§§ 3591-3593) to all types of bargaining disputes, not just disputes arising in the context of a negotiation for a comprehensive MOU. (County of Contra Costa, at pp. 10, 24-28, 42-43.) Third, interpreting the Act's factfinding provisions to apply to any bargaining disputes is consistent with the legislative history of Assembly Bill 646. (County of Contra Costa, at pp. 34-37.) Finally, interpreting the Act's factfinding provisions to apply to any bargaining dispute is consistent with the parties' continuous duty to bargain on any bargainable issue and prepare an MOU after reaching an agreement. (County of Contra Costa, at pp. 40-42.)

B

(5) Although statutory interpretation is ultimately a judicial function, the Board is vested with the authority to interpret the Act. (Santa Clara, supra, 224 Cal.App.4th at p. 1026; Burke v. Ipsen (2010) 189 Cal.App.4th 801, 809 [117 Cal.Rptr.3d 91].) "`[The Board] is "one of those agencies presumably equipped or informed by experience to deal with a specialized field of knowledge, whose findings within that field carry the authority of an expertness which courts do not possess and therefore must respect."'" (County of Los Angeles, supra, 56 Cal.4th at p. 922.) Consequently, we must defer to the Board's interpretation of the Act unless the Board's interpretation is clearly erroneous. (County of Los Angeles, at p. 922; Santa Clara, at p. 1026.)

Amici curiae League of California Cities and California State Association of Counties (Amici Curiae) contend the Board's decisions interpreting the Act are entitled to no deference because they were created for the purpose of assisting the Board in this litigation. However, the timing of the Board's decision does not affect the deference we must accord to the decision. (South Bay Union School Dist. v. Public Employment Relations Bd. (1991) 228 Cal.App.3d 502, 506-507 [279 Cal.Rptr. 135] ["[O]ur construction of legal principles can be influenced by other, even later, pronouncements of the administrative agency."].) Further, judicial comity and restraint preclude us from speculating about any ulterior motives the Board may have had in reaching its decision. (See In re Shaputis (2011) 53 Cal.4th 192, 217-218 [134 Cal.Rptr.3d 86, 265 P.3d 253].)

IV

A

1

The Commission does not directly contest any of the Board's reasons for broadly interpreting the Act's factfinding provisions, including the most compelling reason — there is no language in the Act expressly limiting the factfinding provisions to particular types of impasses. Instead, the Commission asserts four reasons why, notwithstanding the lack of limiting language in the Act, we should interpret the factfinding provisions to apply only to impasses occurring in the context of negotiations for comprehensive MOUs. First, the Commission points to the list of criteria in section 3505.4, subdivision (d), that a factfinding panel "shall" consider and weigh before reaching its findings and recommendations. (See fn. 6, ante.) In the Commission's view, these criteria — particularly the criteria requiring the consideration of the comparable wages, hours, and working conditions of other public agencies; the consumer price index for goods and services; and the overall compensation employees currently receive (§ 3505.4, subd. (d)(5)-(7)) — only make sense for impasses occurring in the context of negotiations for comprehensive MOUs. To conclude otherwise, the Commission contends, would render much of the language in this subdivision surplusage.

2

However, as the Board points out, the criteria listed in section 3505.4, subdivision (d), are virtually identical to the criteria contained in analogous provisions of the EERA. (See § 3548.2, subd. (b).) The only difference between the statutes is that the Act includes a requirement for the factfinding panel to consider local rules, regulations, or ordinances (§ 3505.4, subd. (d)(2)), a criterion not expected to be included in the EERA because the criterion is not generally relevant to public school employment relations. Since at least 2008, the Board has applied the factfinding provisions of the EERA to all types of impasses, not just impasses arising during negotiations of comprehensive MOUs.8 (See, e.g., Chico Unified School Dist. (2008) PERB report No. FF-623 <http://www.perb.ca.gov//ffpdfs/FR0623.pdf> [as of Mar. 30, 2016].) The Legislature presumably knew of the Board's practice when it passed Assembly Bill 646 in 2011.9 (Moore v. California State Bd. of Accountancy (1992) 2 Cal.4th 999, 1017-1018 [9 Cal.Rptr.2d 358, 831 P.2d 798].) Therefore, we cannot reasonably infer from the language of section 3505.4, subdivision (d), a legislative intent to limit the application of the factfinding provisions in the manner the Commission asserts.

(6) Moreover, if we were to limit the application of the Act's factfinding provisions to only those impasses in which all eight of the listed criteria are relevant, which is the logical extension of the Commission's position, there would be few, if any, circumstances in which the factfinding provisions could ever be utilized. As the Board explained in its decision in City and County of San Francisco, supra, PERB Order No. Ad-419-M: "Even in a factfinding proceeding concerning a new or successor MOU, not every one of the eight criteria is necessarily applicable to the issues that divide the parties. When parties reach an impasse in negotiations over a comprehensive MOU, they have usually agreed to at least some terms prior to reaching impasse on more intractable proposals. Issues that impede final agreement can be economic, or non-economic.... Where the issues are non-economic, it is unlikely the factfinding panel would spend time comparing wages and hours of comparable public agencies or assessing the consumer price index in arriving at its recommendations. Thus, the listing of eight criteria that factfinders are to consider does not demonstrate that factfinding applies only to comprehensive MOUs.... [M]id-term bargaining disputes, or disputes over the effects of layoffs or some other proposed economic reduction, can involve issues that are just as complex as disputes over comprehensive MOUs. The eight listed criteria can be equally applicable or equally not applicable to any bargaining dispute, whether it be a mid-term re-opener, a single issue, effects bargaining, or a comprehensive MOU." (Id. at p. 14.)

B

1

Next, the Commission points to the language in section 3505.7 allowing a public agency to implement its last, best, and final offer after exhausting any applicable mediation and factfinding procedures, but precluding the public agency from implementing an MOU. (See fn. 5, ante.) The Commission asserts the Legislature would not have used the "any applicable" language in the statute if it had intended the factfinding procedures to apply to any bargainable dispute. The Commission further asserts the language precluding the implementation of an MOU logically reflects the intent only to apply the factfinding procedures to resolve an impasse arising from the negotiation of an MOU.

2

One key difficulty with the Commission's position is that the language upon which it relies was part of the Act before the Legislature added the factfinding provisions. The language was derived from the original section 3505.4 with minimal revisions to accommodate the addition of the factfinding provisions.10 (Dailey v. City of San Diego (2013) 223 Cal.App.4th 237, 254, fn. 4 [167 Cal.Rptr.3d 123]; see fn. 3, ante, for a history of § 3505.4.) Consequently, the language offers no particular insight into the intended scope of the factfinding provisions.

(7) In addition, the "any applicable" language is more logically and reasonably construed as a recognition that neither mediation nor factfinding will necessarily occur after an impasse. Mediation will only occur if the parties mutually agree to it. (§ 3505.2.) Factfinding will only occur if the union requests it. (§ 3505.4, subd. (a).) If the parties choose not to mediate their dispute or the union chooses not to request a factfinding, then there would not be "any applicable" mediation or factfinding procedures to exhaust before the public agency could implement its last, best, and final offer.

Likewise, the language precluding the implementation of an MOU is more logically and reasonably construed as a recognition that, at the point a public agency implements its last, best, and final offer, there has not been an understanding or an agreement between the parties to implement. This construction is consistent with section 3505.1, which indicates a binding MOU is the result of a tentative agreement between the public agency's and the union's negotiators that has been adopted by the public agency's governing body.11

C

The Commission also relies on references in Assembly Bill 646's legislative history the Commission believes indicate the Act's factfinding provisions were directed solely at addressing failed efforts to negotiate collective bargaining agreements. (See, e.g., Assem. Conc. Sen. Amends. to Assem. Bill No. 646 (2011-2012 Reg. Sess.) as amended June 22, 2011, p. 2 ["According to the author, `Currently, there is no requirement that public agency employers and employee organizations engage in impasse procedures where efforts to negotiate a collective bargaining agreement have failed" (italics added)]; id. at p. 3 ["AB 646 undermines a local agency's authority to establish local rules for resolving impasse and the requirement that a local agency engage in factfinding may delay rather than speed the conclusion of contract negotiations" (italics added)].)

(8) However, these references are to arguments made by the supporters and opponents of Assembly Bill 646. While the Legislature knew of these arguments because they were noted in committee reports and analyses, we generally do not consider references showing the motive or understanding of the bill's author or other interested persons in determining legislative intent. (Joannou v. City of Rancho Palos Verdes (2013) 219 Cal.App.4th 746, 759 [162 Cal.Rptr.3d 158].) Such references are entitled to no weight "unless they reiterate legislative discussion and events leading up to the bill's passage." (Kleffman v. Vonage Holdings Corp. (2010) 49 Cal.4th 334, 348 [110 Cal.Rptr.3d 628, 232 P.3d 625].) Even if we could consider the Commission's proffered references, the references are not illuminating because they focus on the mandatory nature of the factfinding provisions, not the scope of their application.

D

Finally, the Commission contends the Board's reliance on decisions interpreting the EERA and the HEERA is misplaced because these statutory schemes differ fundamentally from the Act in their treatment of impasse and factfinding. Specifically, the Commission points out that under the Act, the parties must mutually agree to mediation, and under the other statutory schemes, either party may compel mediation. (§§ 3505.2, 3548, 3590.) In addition, under the Act, only a union may initiate factfinding, and under the other two statutory schemes, either party may initiate factfinding after a mediator declares factfinding to be appropriate. (§§ 3505.4, 3548.1, subd. (a), 3591.) Further, under the Act, the parties must pay the cost of mediation and factfinding, and under the other statutory schemes, the Board may be required to absorb some of the costs. (§§ 3505.5, subds. (b) & (c), 3548.3, subds. (b) & (c), 3593, subd. (b).)

While these procedural distinctions indeed exist, the Commission has not explained nor is it apparent how they are relevant to the intended application of the Act's factfinding provisions, much less how they compel a conclusion the factfinding provisions only apply to impasses during negotiations of comprehensive MOUs. This omission in the Commission's analysis notably weakens the Commission's position, particularly since there is no material distinction in the three statutory schemes' descriptions of what may be submitted to a factfinding panel. (§§ 3505.4, subd. (a) [parties' "differences" may be submitted to a factfinding panel], 3548.1, subd. (a) [parties' "differences" may be submitted to a factfinding panel], 3591 [parties' "differences" may be submitted to a factfinding panel].)12

(9) Amici Curiae attempt to fill the analytical gap by arguing the word "differences" does not have the same contextual meaning in the Act as it does in the other two statutory schemes. Citing to section 3548 and section 3590, Amici Curiae contend the contextual meaning of "differences" in the other two statutory schemes is an impasse "over matters within the scope of representation."13 Since the Act does not contain the "within the scope of representation" language, Amici Curiae posit the Legislature must have intended for the word "differences" in the Act to mean something other than an impasse over matters within the scope of representation. We are unpersuaded by this argument because it ignores the fact the Act is a public sector labor relations statute and, as such, "matters within the scope of representation" is the implicit context for all of its provisions. For the reasons stated in part IV.B, ante, we are also unpersuaded by Amici Curiae's reliance on the MOU language in section 3505.7 to divine the contextual meaning of "differences."

E

(10) In addition to being unconvincing, the Commission's position is inconsistent with the Act's general purpose. (Mays v. City of Los Angeles (2008) 43 Cal.4th 313, 321 [74 Cal.Rptr.3d 891, 180 P.3d 935] [when construing a statute, courts ultimately must choose the construction most closely fitting the Legislature's apparent intent, with a view to promoting, not defeating the statute's general purpose].)

(11) The Act is intended "to promote full communication between public employers and their employees by providing a reasonable method of resolving disputes regarding wages, hours, and other terms and conditions of employment between public employers and public employee organizations." (§ 3500, subd. (a).) The Act is also intended "to strengthen merit, civil service and other methods of administering employer-employee relations through the establishment of uniform and orderly methods of communication between employees and the public agencies by which they are employed." (§ 3500, subd. (a).)

(12) Applying the factfinding provisions only to impasses arising from MOU negotiations would hinder this purpose by depriving the parties of an orderly method for resolving disputes arising during the negotiation of supplemental matters. Such a result would also be anomalous since the Act makes no other procedural or substantive distinction between the negotiation of comprehensive MOUs and the negotiation of supplemental matters. Indeed, we cannot fathom why the need for an orderly method of resolving disputes would be less acute during the negotiation of supplemental matters than during the negotiation of comprehensive MOUs. The negotiation of supplemental matters is not necessarily less complex nor is the outcome necessarily less important than the negotiation of comprehensive MOUs. For this and the other reasons stated in this opinion, we conclude the Board correctly interpreted the Act's factfinding provisions to apply to all impasses and not just impasses arising during negotiations of comprehensive MOUs. As the trial court determined otherwise, we reverse the judgment and remand the matter for further proceedings consistent with this decision.

V

Given our resolution of the Board's appeal, we need not decide the Commission's cross-appeal of the court's orders on the Commission's motion for attorney fees and the Board's motion to tax costs. Therefore, we dismiss the Commission's cross-appeal as moot.

DISPOSITION

The judgment is reversed. The Commission's cross-appeal is dismissed as moot. The matter is remanded to the trial court for further proceedings consistent with this decision. The Board is awarded its costs on appeal.

McIntyre, J., and Aaron, J., concurred.