In Department of General Services v. Fraternal Order of Police, Lodge No. 85, 903 A.2d 84 (Pa. Cmwlth. 2006) (en banc), the Commonwealth assigned capitol security officers, rather than capitol police officers, to operate scanners in the state office buildings in Harrisburg. The FOP filed a grievance, which proceeded to arbitration. The arbitrator held that the operation of scanners requires the exercise of police powers, and, thus, it is bargaining unit work that must be performed by capitol police officers. In so holding, the arbitrator rejected the Commonwealth's argument that Article 44, Section 2 allowed the Commonwealth to assign capitol security officers to operate the scanners because it was a new assignment that would not reduce the complement of capitol police officers. The Court upheld the arbitrator's award.