CPSU Submits Our Evidence.  ON PAY - para 58 onwards.  CPSU proposes that the determination order include the following wages increases; 3.7% from 1 October 2011, 3.25% from 1 October 2012, 3% from 1 February 2013, 3% from 1 October 2013, 3% from 1 February 2014, and 3% from 1 October 2014.  The first two increases reflect a maintenance of real wages since the period of the last wages increase in October 2010, and are consistent with Victoria’s wages policy objective.  The length of time that has elapsed while the bargaining has taken place, the substantial erosion of real wages that has occurred, and Victoria’s expressed policy, provide appropriate circumstances justifying these increases.

ON THE ECONOMICS - para 39 onwards.  CPSU has submitted expert evidence from BIS Shrapnel’s leading economists that the headline inflation rate is the more the appropriate figure to use when seeking to assess an appropriate amount to ensure employees keep up with the effects of inflation in counter to DTF and Deloitte Access Economics (DAE) evidence which uses the underlying rate to justify the 2.5% wages policy position.  BIS Shrapnel argue that the headline rate has averaged well above 2.5% in recent years, and is projected to average above 2.5% during the life of any workplace determination that FWA would make.  BIS Shrapnel note that even the underlying inflation rate, that Govt has relied upon, has been allowed by the RBA to run at an average of 2.9 over the ten years to June 2011.  BIS Shrapnel explains that even the headline CPI does not reflect the actual cost of living effects of inflation and that a Living Cost index is the most appropriate measure to be used in wage fixing exercises.

ON PRODUCTIVITY – para 49 onwards.  CPSU submits that the 10% reduction in the size of the public service proposed by Govt, when one excludes the areas that have been quarantined from the reduction, the actual diminution of the affected workforces will by between 13.63 % and 15.12%.  CPSU argues that this will have a dramatic effect on the workloads expected to be carried by the remaining employees, and will result in a significant increase in the productivity of the remaining public service.  CPSU refers to the evidence in the statements of the following members; Maureen Bakker from VicPol, Gary Banks from DEECD, Jules Blewer from Justice, Sue Clark from DEECD, Chris Coutts from Justice, Andrew Crabtree from DEECD, Louise Dressing from DEECD, Augusta Giannini from Justice, John Halls from VicPol, Robert Holmes from DPI, Eilis Hughes from DHS, Anita Kain from DEECD, Simone Lethaus from DEECD, Brennan O’Brien from DHS, Peter Panoutsos from EPA, Catherine Quinn from VicPol, Rosemary Ruddell from DEECD, Mary Sullivan from Health, Ralph Tulloch from Justice, and Jeanette Webb from DHS and we extend our thanks to them.  

ON PROGRESSION - para 24 onwards.  Victoria’s objections are directed to the terms of the previous arbitrated outcome by Commissioner Smith, and the effects that are complained of are contradicted by its own materials in attachment PE-4 to the first statement of Mr Peter Ewers and CPSU submits the objections to the proposed clauses are without merit and should be rejected.

Govt must lodge their response now by Friday 25 May before the formal hearings commence in June. 

Fair Work has issued an Order after CPSU sought document discovery and Fair Work will hear argument on 24/6 about the Govt objections.