An overview of the working and negotiating relationship between the parties is useful in understanding the issues presented in this case. On June 15, 1971, Denver voters passed an amendment to the Denver Charter of Internal Regulations (the 1971 amendment) that defines firefighters` right to negotiate terms of employment with the city and provides for a binding reconciliation of all unresolved issues in the event of a collapse in contract negotiations.  In accordance with this amendment, the union and the city have negotiated and entered into collective agreements every year since 1972.  See Fairchild v. West Rutland School District, 135 Vt 282, 284, 376 A.2d 28, 30 (1977): “If the award was based on a case that is not within the scope of the review agreement, it acted beyond the limits of its authority. Whether the arbitrator has exceeded the size of his authority is an issue that must be resolved in court. A review of our cases in applying the principle of non-delegation to tariff situations in the public service is useful in contextualization of this litigation. To Fellows v. LaTronica, 151 Colo. 300, 377 P.2d 547 (1962), a Firefighter from Pueblo asked for a claim arising from the terms of a collective agreement to be reconciled.
The court rejected the firefighter`s request for arbitration and stated that the principle of non-delegation prohibits public servants from entering into a mandatory collective agreement with municipal employees who do not have any special authority granted by the municipal code or the state code. A number of policy considerations support our conclusion that public sector complaint arbitration procedures are constitutionally and desirable. See How, Legality and Propriety of Agreements to Arbitrate Major and Minor Disputes in Public Employment, 54 Cornell L.Rev. 129, 135-36 (1968). First, Littleton Education Ass has found that collective bargaining between public servants and workers is constitutional and we believe that the impact of such participation could be significantly reduced in the absence of a practical and informal means of resolving interpretive disputes arising from an agreement. In the absence of a quick method of implementing the provisions of the treaty, each party may be tempted to violate its terms. Arbitration is an effective method of resolving disputes without the burden of tedious court proceedings. Secondly, the arbitration of complaints in the private sector has been recognized for years as a method of maintaining a peaceful and productive working relationship and, in the public sector, this benefit will benefit the citizens of the commune who are served by public employees. See United Steelworkers of America v. American Manufacturing Co., 363 U.S. 564, 80 P. Ct.
1343, 4 L. Ed. 2d 1403 (1960). Third, the availability of arbitration procedures for appeals can be used to compensate, to some extent, public sector employees for the denial of the right to strike.  See z.B. In addition, the legitimacy of representative government is enhanced when a procedure is available to ensure that public servants adhere to their own policies as defined in the collective agreement. Consistent with the distinction we make today between the claim and the decision of interest, the arbitration provision in a collective agreement must be limited to disputes arising from explicit provisions of the contract and must not include the transfer of discretion to the arbitrator in all matters reserved for the administration`s assessment under the agreement. Article XV, Section 5, of the 1977 agreement of the parties complies with these restrictions because it expressly excludes arbitration:  Following the decision of Greeley Police Union, Denver voters agreed to a further amendment to their municipal charter effective May 15, 1979, which provides for the presentation of all unresolved disputes that arise when negotiating an agreement on an advisory element.