We continued with our busy arbitration schedule by completing 8 days of hearings in the last three weeks. We have now completed 32 days of hearings. We presented our entire case in 20 days, which included hearing evidence and the cross-examination of 28 witnesses. So far Canada Post has used 12 days of hearings and we have heard evidence from 3 witnesses. They still have their fourth witness on the stand and have at least 3 more witnesses to go after that.
We began the week with our cross examination of Canada Post’s witness Jean-Laurent Rousset, General Manager of Customer Experience. We challenged Mr. Rousset’s evidence regarding the need for “flexibility” in Group 1 staffing, by indicating just how much flexibility Canada Post currently has for Group 1 staffing.
We also challenged Mr. Rousset’s representation that Canada Post was struggling in the parcel business and that maybe 2019 wouldn’t be a good year for parcel growth. We presented documents showing that Canada Post is forecasting to have a very good “Peak Season” this year. No one can say what the final results for 2019 will be, but it is clear that Canada Post is optimistic with its forecasts. This goes against much of the theme presented by Canada Post’s first two witnesses.
Canada Post then began with the testimony of Mr. Sanjay Paliwal, General Manager of Delivery Transformation. His testimony continued the same gloom and doom theme as Canada Post’s first three witnesses. He then talked about some of the changes that Canada Post has made to address these challenges, such as Postal Transformation, the 5 Point Action Plan and Separate Sort and Delivery (SSD). Yes, much of this was addressed by previous Canada Post witnesses.
Mr. Paliwal continued his lengthy testimony, going into great detail about the Letter Carrier Route Measurement System (LCRMS) and letter carrier restructures. He then went on to discuss letter carrier workload and overtime and the clauses in the collective agreement used to manage workload and overtime.
The next hearing dates are October 23 and 30. Canada Post has scheduled visits to three different smaller post offices on these dates. The cross examination of Mr. Paliwal will begin when Canada Post completes his evidence in chief, whenever that is.
It is not clear if CPC’s strategy to have their witnesses read passages after passages of the collective agreement, or spend hours on issues that are not in front of the arbitrator, is designed to ensure that the arbitration is extended past the federal election. Perhaps they are hoping for a Conservative majority?
Be assured we are doing everything we can to move the arbitration forward without compromising our case.