The City of Corvallis seeks review of an Employment Relations Board order which determined that the city committed an unfair labor practice when it communicated directly with an employe regarding employment relations during the “period of negotiations.” ORS 243.672(1)(i).1 We affirm.

The facts that ERB found are not in dispute. The city and AFSCME Local 2975/Council 75 (union) negotiated a collective bargaining agreement in September, 1984, effective through June 30, 1987. Under the agreement, the city must give a 14-day written notice of layoff to affected employes.2 It must also give the union notice of a decision to “contract out” services that bargaining unit employes had provided at least 14 days before the intended implementation date.3 If, within *37514 days, the union makes a written demand to bargain the impact of that decision, the city must delay implementation pending bargaining.

On March 7,1986, the City decided to subcontract, or contract out, some custodial services. Arnot, a bargaining unit member, was the only custodial employe affected. On March 10, 1986, his supervisor, Mitchell, met with him and a union representative and delivered a written notice of layoff. The notice listed the reasons for the layoff. It also described Arnot’s options, including transfer to a temporary position as a seasonal maintenance worker. Arnot expressed interest in the transfer and said that he wanted to talk with his wife. Later that day, a city representative met with the union and notified it of the city’s decision to contract out custodial services and of its plan to address the impact of that decision.

On March 11, Mitchell asked Arnot whether he had talked with his wife. Arnot indicated that she was concerned about eligibility for unemployment benefits. Mitchell said that he would look into it. On March 13, he told Arnot that the temporary job would not affect his eligibility. Arnot said that he would accept the transfer.

By letter dated March 17,1986, the union demanded impact bargaining on the decision to contract out custodial services. The city received the letter on the morning of March 18. Arnot was unhappy with the union’s demand. On March 18, Mitchell told him that he could use a city car to meet with a union representative. After Arnot returned on that day, he *376wrote a letter to the union, at Mitchell’s suggestion, expressing his dissatisfaction.

On March 18, the parties began impact bargaining. Arnot’s layoff was rescinded pending its completion. In May, 1986, the city and the union reached an agreement concerning the city’s plan to address the impact of its decision to contract out.

In July, the union filed an unfair labor practice complaint, charging that the city had violated ORS 243.672(1) (i) when Mitchell discussed the transfer with Arnot on March 10, 11, 13 and 18. Under ORS 243.671(1)(i), a public employer commits an unfair labor practice if it, or its designated representative, communicates directly with an employe during a period of negotiations regarding employment relations on a matter not related to the performance of the work involved.4 ERB concluded that the period of negotiations began March 10. It held that the city had committed an unfair labor practice when it communicated directly with Arnot.5 ERB also rejected the city’s argument that ORS 243.672(1)(i) violates Article I, sections 8 and 20, of the Oregon Constitution.

The city assigns as error that ERB concluded that the period of negotiations began on March 10. Neither the statute nor the agreement defines the term “period of negotiations.” The city argues, however, that Section 29.2 and 29.3 of the agreement indicate that the parties intended that the period of negotiations begins when the union makes a formal written demand of its “intent to bargain.” The union responds that ERB correctly concluded that the period of negotiations begins when the city gives notice of its decision to contract *377out. It asserts that, otherwise, the city could “end-run” its obligation to bargain about impact by negotiating directly with employes during the time when the union is considering whether to demand bargaining.

“Period of negotiations” is an inexact term. When there is no factual dispute, its meaning is a question of law. When an agency interprets an inexact term, we defer to that interpretation if it is consistent with legislative policy. Springfield Education Assn. v. School Dist., 290 Or 217, 224, 621 P2d 547 (1980); see ORS 183.482(8)(a). ERB concluded that the period of negotiations began when the city gave the union notice on March 10 of its decision to contract out. That conclusion is consistent with the legislative policy and is correct.6 The purpose of the statute is to prevent the public employer from undermining the union’s status as exlusive bargaining representative by engaging in direct negotiations or other contact with its employe “that substantially impairs the relationship between the [member] and its representative.” See Oregon City School District No. 62 v. Oregon City Education Association, 5 PECBR 4246, 4251-52 (1981).

The city next assigns as error ERB’s ruling that the agreement did not authorize the communications that Mitchell made to Arnot. It argues that Article 26.1 required it to notify him of his layoff. ERB, however, correctly ruled that Mitchell’s communication regarding the options available to him, including transfer, went beyond the notice requirement of Section 26.1. See Rogue Community College Classified Employees Association, Chapter 152 v. Rogue Community College, 9 PECBR 8484 (1986).

The city also assigns as error that ERB ruled that *378ORS 243.672(1)(i) does not violate Article I, section 8.7 It argues that, contrary to the guarantee of Article I, section 8, the law restricts the city’s right to speak “on any subject whatever.” ERB rejected the argument, reasoning that unfair labor practice liability lies with the public employer, not its “designated representatives,” see ORS 243.650(18),8 and that public employers do not enjoy Article I, section 8, rights. We agree. Article I, section 8, protects persons against “laws” that restrict speech rights. It does not protect the city as a public employer, as defined by ORS 243.650(18).9 See State ex rel Emerald PUD v. Joseph, 292 Or 357, 362, 640 P2d 1011 (1982). ORS 243.671(1) (i) does not violate Article I, section 8.10

Affirmed.