The Canadian Union of Postal Workers finds that the Corporation has failed to abide by Appendix “P” of the collective agreement by not maintaining the ratio of regular full-time employees at 78 %, in violation of paragraph 1 (b) of this Appendix, and by not creating the required number of regular full-time employees, as set out in paragraph 2 (d).

On July 14, 2005, the Corporation informed CUPW that it had decided to "review its national network" and that "the matter of the Quebec mechanized plant would be the first." This notice was allegedly submitted under clause 29.03 (a).

On August 3, 2005, the Corporation submitted a new notice allegedly under clause 29.03 (b) providing some information regarding the closure of the Quebec sortation centre, the transfer of the work to Montreal and the elimination of positions.

The information contained in the August 3, 2005 letter and other information obtained afterwards by CUPW show that the Corporation began reviewing this project long before July 14. Accordingly, the notice submitted on that date is late and is not consistent with the letter and spirit of clause 29.03 (a), particularly with regard to the other installations that might be involved in the review of the national network announced by the Corporation.

The Corporation's failure to meet its obligations under clause 29.03 (a) prevents CUPW from intervening in a timely manner and stating its position before the Corporation makes a final decision.

In addition, the August 3, 2005 notice is also not consistent with the letter and spirit of clause 29.03 (b) and clause 29.04 because it was submitted late and does not contain the information required under the collective agreement, particularly with regard to what will happen to the employees adversely affected by the changes that were announced.

The Canadian Union of Postal Worker grieves that the closures of Station B Saint-John, Cap de la Madeleine, Québec, St-Hubert, Delorimier, Hamilton CSC LCD4 and Kamloops Station A are in violation of Appendices "I", "T" and other applicable provisions of the collective agreement

The Canadian Union of Postal Workers grieves that the employer has violated articles 14, 47, 48, 50, Appendix "V" and other provisions of the collective agreement in that it is failing to include over-assessed routes in restructuring exercises when minor or major restructures are occurring.

The Canadian Union of Postal Workers grieves that the employer's decision to discontinue the monotainer repair operations in Winnipeg, Montreal and Toronto, as stipulated in a letter dated December 30, 2004 is in violation of Appendix "T" and other applicable provisions of the Urban Operations collective agreement.

The Canadian Union of Postal Workers grieves that the employer has violated Appendix "FF" and other applicable provisions of the Collective Agreement in that it has failed to allow the working committees in Montreal and other locations to develop alternative schedules for the night shift and forward these schedules to the Steering Committee. It has also prevented the Steering Committee from reviewing and testing these proposed schedules. Finally, it has prevented the working committees from performing the activities specified in point 4 of Appendix "FF".

The Canadian Union of Postal Workers grieves that the employer has violated the

The Canadian Union of Postal Workers grieves that the Corporation is in violation of Article 28 and other applicable articles of the Collective Agreement in that it is calculating severance pay entitlements for periods of part-time and temporary service based on scheduled hours.

The Canadian Union of Postal Workers grieves that the Corporation has violated Article 17, Appendix "V" and other articles and appendices of the Collective Agreement in that it has implemented a policy, which provides that the payment identified in Appendix "V-3" will not be paid when an uncovered route is covered pursuant to the provisions of clauses 17.04 and 17.05.

CUPW and the Corporation have an agreement for assessing the workload of letter carriers who do door-to-door delivery to points of call normally serviced by community mail boxes. Under this agreement, the equivalent of three quarters of the street distance must be allocated.

However, the Corporation refuses to comply with this agreement and the new provisions in the LCRMS Manual, and to make the required time assessment adjustments to several letter carrier routes. In so doing, the Corporation is violating the collective agreement, specifically Articles 47 and 50, as well Appendix "V" and Chapter 13 of the LCRMS Manual.