In closed-door arbitration sessions this month, the president of the United Federation of Teachers, Randi Weingarten, accused the city of adopting a “factory model” of education and demanded three annual 6% across-the-board raises as well as more decision-making power for teachers.

“The UFT’s contract proposals envision a very different climate than the top-down, over-regulated, assembly line style that the BOE/City seeks to codify with its contract proposals,” the teachers union stated in its brief. The union says that the Department of Education gives principals all of the decision-making power in schools and that teachers are forced to conform to a uniform teaching model “as if they were on an assembly line producing widgets.” BOE stands for Board of Education, the anachronistic designation in state law of the city’s education administration.

Late last summer, Mayor Bloomberg indicated the teachers union could have a new contract before the start of the 2004-05 school year. In October, when the mayor and Ms. Weingarten attended a Yankees game together, city government was buzzing with talk of an imminent contract. But now, as the end of the school year approaches, the city’s 80,000 public-school teachers are still working under a contract that expired more than two years ago.

On Friday and Monday, Ms. Weingarten with the UFT general counsel, Carol Gerstl, and the union’s outside lawyer, Basil Paterson, presented the union’s case at a fact-finding session called by the state’s Public Employment Relations Board. Historically, the board’s recommendations become the foundation for a new contract, but its findings are not binding. Mr. Paterson, who is a member in the Long Island-based law firm of Meyer, Suozzi, English & Klein, P.C., is a former New York secretary of state and New York City deputy mayor for labor relations and personnel, as well as the father of the minority leader of the state Senate, David Paterson, a Democrat of Manhattan.

The teachers union is demanding a 6% increase in salary for each of the three years of the contract, which would cover the period from June 2003 through next May. The union told the state board that the raises – which it describes as an “18% compounded increase” but works out to a cumulative 19.1% – would make salaries for the city’s public-school teachers comparable to salaries in other school districts in the region. Teachers in Nassau, Suffolk, Westchester, and Rockland counties earn between 14% and 26% more than city teachers.

“Since the teachers in surrounding districts have received salary increases of upwards of 4% for each of the past two years, this 18% compounded increase will still not bring New York City teachers’ salaries on par with those in surrounding districts; the 18% increase would simply allow progress to be made in that pursuit,” the brief states.

The union demanded more pay for teachers who undergo additional training, and more pay for teachers who volunteer to work in the most difficult schools in the system.

The union also demanded that there be “no layoff for all titles through the term of this agreement.” The union said the no-layoff proposal would ensure job security for educators and bar the city from getting rid of groups of competent teachers, such as typing teachers or paraprofessionals.

In the brief, the union does, however, back the idea of the immediate firing of teachers who have been found guilty through a due-process proceeding of sexually abusing students. The schools chancellor, Joel Klein, has called repeatedly for the flexibility to fire teachers involved in inappropriate sexual relationships with students.

The union also endorses the expansion of a “peer intervention program” to help teachers who are at risk of being fired for incompetence. According to union data, 487 of the 687 teachers who went through the training between 1993 and 2003 improved so much that they were rated “satisfactory” by principals who had previously targeted them for possible dismissal.

The union also wants to reduce class sizes. It says it wants to work together with the Department of Education to decide how to use money from the huge settlement of the lawsuit by the Campaign for Fiscal Equity to reduce class sizes in all grades.

“Solid research connects class size reduction with improved student outcomes,” the brief states. The Bloomberg administration would allocate some of the Campaign for Fiscal Equity funds to reducing class sizes, and the City Council and its speaker, Gifford Miller, have called for adoption of a formula to require that classes in the lower grades have no more than 17 students. Decreasing the number of students in each classroom is not, however, a top priority of Bloomberg education officials.

Overall, the union stated: “Despite public lip service paid by the BOE and the City to the value of teachers and other educators who toil in the City’s public school system to educate the City’s 1.1 million school children, many of whom are among the most disadvantaged in the State, their actions belie their words. By their deeds, they trash teachers on the one hand and on the other bemoan the lack of retention of experienced and qualified teachers.” Referring to the union’s decision to publish the contents of the closed-door arbitration session on its Web site, a spokesman for the mayor, Robert Lawson, said: “If they want to negotiate a new contract as the mayor has done for more than half of our 250,000 employees, they need to come to the table, not cyberspace.”

Needless to say, the city opposes most of the union’s demands.

According to the preliminary statement of the city’s brief, which was printed in the most recent issue of the union periodical New York Teacher and was posted online, the city and the Department of Education argue that billions of dollars have been poured into the school system and teachers have received large wage increases, but results have not improved.

The city makes the case that: “… it is abundantly clear that formulaic across-the-board wage increases are not the remedy for the school system’s sub-par performance, particularly with high needs students.”

The city advances five key recommendations to overhaul the teachers’ contract:

* Performance-based bonuses as an incentive for teachers to improve their performance and to reward teachers who improve student achievement.

* Signing bonuses for educators equipped to teach hard-to-staff subject areas such as math and special education.

* More flexibility for principals to assign teachers to non-classroom duties, such as conducting homeroom or monitoring the cafeteria during lunchtime.

* Elimination of the system of seniority, under which veteran teachers flock to the best schools in the city. Instead, management wants to establish a system under which the most experienced teachers can be deployed to the schools with the highest needs.

* Establishment of new rules that would make it easier to fire inept teachers and teachers who have engaged in serious misconduct.

The city adds that any raises for teachers included in the new contract must follow the pattern set by contracts already negotiated with unions representing about 46% of the city’s workforce. The contract that set the pattern was for District Council 37, the city’s largest union. DC-37 workers received a $1,000 bonus for the first year of the contract, followed by a 3% raise in the second year and a 2% raise in the third year.

Representatives of the city will testify before the Public Employment Relations Board later this month.