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HomeMy WebLinkAbout1989-0782.MacLean.91-01-04I -Z ONTARIO EMPLO Y~'S DE LA COURONNE ~"' ~, CROWN EMPLOYE£S DE L 'ONTAR$O -, GRIEVANCE COMMISSION DE t SETTLEMENT R~=GLEMENT BOARD DES GRIEFS 180 DUNDAS STREET WEST, TORONTO, ONTARIO. MSG 1Z8- SUITE 2100 TELEPHONE/T~cL '~PHONE 180, RUE DUNDA3 0UEST. TORONTO, (ONTARIO) M5G 1Z8 - BUREAU2100 (475) 598-0688 782/89 IN TEE MATTER OF AN ARBITRATION Under TEE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before TEE GRIEVANCE SETTLEMENT BOA-RD BETWEEN: 0PSEU (MacLean) Grievor - and - The Crown in Right of Ontario (Ministry of Transportation) Employer - and - BEFORE: M.R. Gorsky ViCe-Chairperson G. Majesky Member D. Montrose Member FOR THE R. Wells GRIEVOR: Counsel Gowling, Strathy & Henderson Barristers & Solicitors FOR TEE M. Failes EMPLOYER: Counsel Winkler, Filion and Wakely Barristers & Solicitors ~'EARINGS: December 22, 1989 March 23, 1990 DECIS~0N _The Grievor filed a grievance on June !2, 1989, which stated: "'I grieve that I have been denied an interview for the position Highway Operator 2" The position in question was covered by Ottawa Distric't Competition ~9289-70, with a posting date of May 2, 1989, and a closing date of May I8, 1989. The competition was open to classified and unclassified staff of the Ontario Public ~er'?ice. Crown 5~ptoyees and the public. The position title is "Patrc, 1 · Operator AB (bilingual) and the classification is: "Highway Equipment Operator 2". The headquarters for the position is at the Vankleek Hill Patrol, The position specification and class allocation with respect to the position (Exhibit 3), provides as follows: "2, Purpose of position (why does this position exist?) To operate and maintain within a specified patrol area ,~ne or more units of M.T.C. type 'A' and 'B' equipment .for the purpose of maintaining roads and right-of-way. To perform the duties of night patrolman.when assigned. To perform general labouring duties when required. 3. Duties and related tasks ,(what is employee required to do. how and why? Indicate percentage of time spent on each duty) !. Under the supervision of a Patrol Supervisor, inc,'_?.bents perform duties and accept responsibilities involving v.ar~ous combinations o~ wo~ assignmer:~= relative to the operation of equipment known as Type A and B, performing ,as night patrolman ,and general labouring duties to provide good maintenance of Highways and right-o.f-way within a specified patrc, l area. Typical combinations of work activities are as follows: a) for at least 70~ of the year's working time is ass%'gned to operate a combination of Type 'A' and 'B' equipment with a minimum of 40% on Type 'b) acts as labourer in summer and performs duties .~f night patrolman for a minimum of 4 months during winter: c) operates type 'B' equipment in summer (40% of time) and acts as Wingman during winter for a total of at least 70% of year's working time. 2. While operating equipment performs such duties as: -transporting Patrol personnel, equipment or materials from Patrol Yard to job locations: - cutting grass on Highway right-of-way; - maintaining roadside shoulders with t?actor attachments: - loading materials onto vehicles or stockpiling salt and sand; - plowing snow from road surfaces - applying salt and sand. 3. Maintaining equipment to which assigned by performing such tasks as: - washing, cleaning and greasing as required: - inspecting equipment daily, reporting mechan~ca! defects to supervisor; - checking fuel, oil and lubricant levels and topping when required; - checking all safety equipment, flares, fuses, signs~ first aid kits,, fire equipment, etc., and ensure such equipment is in good operating condition; - completes equipment report forms daily, 'noting fuel and oil consumption, type of operation, etc. 4. Performs a variety of labouring tasks as assigned such as: -digging ditches; - replacing damaged guide rails: - cutting grass and weeds using hand mowers; - acting as flagman warning motorists of work in - cleaning and sharpening hand toc!s: - miscel'laneous janitorial duties in and around patrol headquarters; - re-erecting damaged Highway signs: - patching road surface: - removing beaver dams. 5. As Night Patrolman patrols specified Patrol area frequently, visually inspecting road conditions, lJsLnw mobile radio, directs snowplow or sanding crews as required. Prepares reports of shift operations. 6. Auxiliary duties: - may be required to supervise a group of labourers as assigned; - may be required to act for Patrol Supervisor in his/her absence;. - as assigned; - may be required to complete daily patrol , documents. NOTE: Incumbents are subject to shift schedules during winter months. 4. Skills and knowledge required to perform job at full working level. (Indicate mandatory credentials or l'icences0 if applicable) Valid Class 'D' Ontario Driver's Licence and an M.T.C. Operator's Permit. Experience in the operation of highway equipment or .related machinery and an acceptable record. Supervisory ability and good physical condition."-' It was acknowledged that the Grievor was not granted an interview because he is unilingual and the qualifications call for an incumbent who is bilingual and the qualifications further provide: "Ability to communicate verbally at the advanced level, in both English and French languages." It would not have' mattered, in th~s .case, if the qualifications called for a lesser ability to communicate verbally in French, as it was acknowledged that the Grievor is unilingual. It was the position taken on behalf of Grievor that the position did not require an incumbent t.? ccm~'.t~icate ,/erba~~../, at any ~evel,. ~n_ the ~-~h. ...... ~ngu~=~~: ...... ~',,~ ~hat any requirement that an incumbent be able %o com, municate verbally in the French language was unreasonable and, accordingly, the grievance ought to be allowed and the qrievcr ~houtd be ~ranted an interview ~n a rerun of the compet~tic, n. There was no dispute to the position taken on behalf of Grievor that he possessed all of the qualifications for the position, as posted,save for the ability to communicate verbally in the French language, and ~f the Grievor"s position is vindicated he would appear to be entitled to the relief sought in some form. ?h.~e incumbent, Serge Fauteux. who was the suc,ze'ssful applicant, was given notice of 'the hearing and advised of his right to attend and participate at the hearing,and he did so attend. Both pa~ties brought the case of Giasson, 2250/87 (Watters) to our attention. In the Giasson case, the grievance also arose as a result of the grievor being denied an interview for a posted position which stated that fluency in French was essential. ?h~e decision to deny the grievor in the Giasson case an 'interview was grieved before a different Danet of the Board and a prelim/nary objection as to arbitrability was heard on March 25, t988, the panel being chaired by J. H. Devlin. The decision on the preliminary objection, dated May 20, 1988, dismissed the Employer's objection and the Board there stated: " ....~-~..e Board has jurisdiction to ~term~ne wh,e~ .... fluency in French which was required for the vacancy ~n the position of Construction Safety Officer which arose in Sudbury in the summer of 1987 was reasonably related to the job to be performed." (p. In the decision o'n the merits in the Giasson ~as~ at ~ .the Board found that the grievor's supervisor: " ... had the capacity to del'iver French services through two bilingual officers and that this ability was lost in June of 1987." Further at p. 9, ~t is stated: "Given the demographics of the region under Mr. Owens' .management, as disclosed by the census data provided to us, we think it more likely than not that the call for such services was more than just an isolated occurrence. In light of his past experience the Board finds it understandable' why Mr. Owens would want to retain one - bilingual officer in the Sudbury complement. importantly, We have been persuaded that this prior practice establishes that 'the. restriction in quos{ion wa~ 'reasonably related' to the job to be performed." In the Giasson case, reference was made to the French L&n~uace Serv;ces 'ac't, s.o. 1'986, 'c..,4~. " .:~ ~i ~ ' At p~. 10-11 of the Giasson case, it is stated: " !-he board can only speculate as to the effect that the French Lancua~e Services Act had on the decision to attach the contested requirement to the posting. As noted,-the final decision maker was not called to give evidence. Both Mr. Owens and Mr. Aki were-aware of the legislation and the impact that it could have on their daily opDrations.. The former appears to have been under t~e mistaken impression that the legislation was in full effect in June, 1987. Notwithstanding this fact, our .assessment of his testimony is that his conclusions as to.the need for the requirement. were based primarily on his past experience with the ~ position. While Mr. Aki received Mr. Owens' recon~nendation together with reasons, we cannot state with any certainty that these reasons by themselves dictated the final decision. It is likely that the existence of the leqis!ation was factored into such decision. We note in tk~s regard ~hat the employer, in responding to the ~rievance ~t Step C~ne. referred in a genera! way te rights created therein. ~%e board does net, however, find this to be material. In our judgment, the need bilingual officer in the Sudbury office predated the legislation. It is apparent that the French Language Services Act did not create the need, although it may serve to magnify it in future. Indeed, Mr. Owens testified that such an officer would have been required without'even. considering the impact of this legislative initiative. We are inclined to agree with his assessment on the basis the evidence position rather than to the Act in reaching our conc!usicn that the restriction was reasonably related to the tasks to be performed. In the context of the particular case before us, we do not think that much weight should be accorded to the employer's decision vis a vis other postings in the area. /'he Employer submit{ed to us the case of MacKenzie, 1243/87 (Ratushny),'which was decided after the giasson case. It should be noted that in neither of those cases was there any allegation o~ bad faith against the employer, nor was there allegation in the case before us. In the MacKenzie case, as in the case before us, the sole issue was "whether the bilingual '=~<F~rement is reasonably related {o the position in question." (MacKenzie at p. 2). In the MacKenzie case it was stated at p. 2: "It should be noted that the criterion is 'related' rather than 'necessary' The latter test would impose a higher burden upon the employer. Nevertheless, the relationship of the requirement to the job must be more than tenuous or ~}l~se=!.~ speculative." In the MacKenzie case, the ~rievance related to the position of Driver Examiner Supervisor in the New Liskeard office of the Ministry of Transp6rtation and Communications. Approximately 80% of the work of that office involved direct contact with the public including telephone inquiries and inquiries made at the the Highway Traffic Act. Applications are received and permits and licences are issued and modified and written examinations are administered and appointments are made for road tests. There is ? also'banking performed, as well as other paper work associste,~ with the administrat~0n of the office. .There is an i~.=~ examiner who is bilingual and previous Supervisors eT[tending back for at least ten years were bilingual. The Board found, at, p. 4 of the MacKenzie case, that: "... as a matter of practice prior to the vacancy in question, bilingual service was available to the public in ali facets of the operation of the New Liskeard office. When the position of Driver Examiner Supervisor became vacant in April of 1987, bilingual capacity was made a job requirement." At p. 4 of the MacKenzie case it. ~s stated: "The Srievor ~s an Inside Examiner in. the Sudbury Office of the same Ministry. This office is larger than the one at New Liskeard. in addition to the Supervisor, there are three full-time outside examiners and from three to full-time inside examiners including the.Grievo~. Supervisor and one of the outside examfners are able to provide road examinations in F~ench when.requested. There is no such flexibility at New Liskeard since the Supervisor is also the only outside examiner." At pp. 4-5 of the MacKenzie case, in referring to Giasson, the majority of the panel Stated: "The majority in giasson reached its conclusion that the bilingual~sm requirement was reasonably related on the basis of the nature of the position in question, qui~e apart from the potential application of the French Lancuace Services Act, 1986. Nevertheless, the legislation provides important context for assessing the reasonableness of the relationship of the qualification to the position. The Preamble to the Act includes the following: 'Whereas the French language is an historic and h,)noured language 'in Ontario and is recognized by the wheress in Ontario the French language ~s re'co~ an official language in the courts and in an:{ whereas the Leg{statUre Assembly recogn~ contribution of the cultural heritage of the French speaking population and wishes to preserve it for future-generations: and whereas it is desirable to guarantee the use'of the French language in institutions of the Legislature and the Government of Ontario, as provided in this Act ,..' Amon~s-t other things, the Act establishes the right to receive available services in French from government ,?ffices in designated municipalities and districts. Provision is made for the phasing in of this right over a three year eriodcommencing on November 18, 1986, through the esig~ation BY ~b~ FegulatiO~ of the various Government agencies or ~.ns~%utions un%~ all are include~. Counsel for the Grievor did ~ot challenge the purpose or policy of the legislation but merely the implementation of the policy on the facts of this grievance." Notwithstanding certain statements found in the MacKenzie case, it does not appear that the majority of the Boar-~ fo~ind the legislation to furnish other than an "important context assessing the reasonableness of the r. elationship of the q~a.~ification to the position," (MacKenzie at p. 5)° Of significance in the MacKenzie c~se is the fact: "... there was'significant evidence of the demand for services in the French language. The Grievor testified t. ha% her experience in New Liskeard suggested that from of the clientele were French-speaking to the extent of having 'an accent or dialect' indicating that they were 'more French than English' On cross-examination she elaborated, that those falling within this category of fr,2~n 4 to 5~ would have a 'very heavy accent' or would 'have trouble finding the right word' or would speak in 'broken English' She was unable to estimate how many of the remaining 95 to 96~ of the clientele might have preferred to speak in French even though they were able to communicate effectively in English." Further, at p, 8 of the MacKenzie case the Board found: " ... that if a French speaking capacity were available, from !5 to 20% of the clientele would take advantage of that opportunity as their preference ~'i~is view corresponds with what little data was presente2 %.ut indicated that well over 20~ of the populati,sn in beth the Timiskaming area and the smaller area serviced by the New Liskeard office was francophone. Counsel for the Empieyer made the point that the 'reasonably related' criterion must be assessed not by whether people would have been able to 'get by' without speaking French but by whether French language services would be utilized significantly we,'~ available. ..... Bearing %his in mind ~t is a re .... inference that' there W~s a significant deman,~ for French ~.~'~la..~~ g..~ services eve~ thn~,gh ......... re,-~,~s :~. such '~.=-~,~,~_ .... _.,_ not kept and surveys were not taken." The final consideration .made by the majority of the Board concerned: "... whether the Employer. acted reasonably in concluding that alternative means of providing French language services in the office in question were not available." .(MacKenzie case at p. 8.). The Board went on to state: "~..e nearest office to New Liskeard at which such services are available is North Bay~ .This is almost a two and for that reason would not provide an adequate service. It was also suggested that a bilingual outs~d_ examiner could be assigned to New Liskeard on certain days. However, that would disrupt the operation of that examiner's home office (particularly its-French speaking services) and would result in significant expenditures for travel costs and lost time due to travel." We were also referred to the case of ~, 1440/88 (Samuels). " ... the. grievor applied for a posted position as a Travel Consultant. in Niagara Falls. She did not get the position for one reason only - her level of competence in the French language was rated as 'Intermediate', whereas the Ministry wanted someone with an 'Advanced' rating " (Da__~_ at 2.) The Board in the Da!y' case referred to MacKenzie and to Giasson. In the latter case, only to the Award on the preliminary matter by the panel chaired by Ms.Devlin. In the Da!y case, the unreasonableness alleged was not the imposition of a requirement that there be some ~.ev.e] cf competence in the ~e~:chr, !~'..~e ~he requirement that the incumbent have an Advanced" ~eve= verbal sk~ll in French. The Grievor argued that this: " ... was not reasonably related to the job to be performed, and therefore the Ministry violated Article 4.3 when it refused to give 'the Griever] the job." (Daly .at p. 2). The Board in the Dal¥ case found that the French Lancua~e Services Act, 1986, did not apply to the case before it. In this respect, the Dal¥ case is no different from the G~asson or ~acKen~ie cases. In the G~asson case, at p. 11, the ma3ority of the Board concluded: "In summary, we have looked to the position rather than to the Ac_~t in reaching our conc!usion that the restriction was reasonably related to the tasks to be performed .... " In the MacKenzie case, the majority of the Board emp!oyed the Act for the purpose of providing an: " ... important context for assessing the reasonableness of the relationship of the qualification to the posit~on." (MacKenzie at p. 5}. Neither counsel argued that the Act applied directly to this case. Counsel for the Employer argued, however, relying on the MacKenzie case, that the legislation also provided a-significant context for assessing the reasonableness of the qualification with respect to fluency in French to the position. The Employer also referred to Beck 196/89 (Watters). In the latter case, the Chairman, who was also the Chairman in the G~asson case, agreed w~th the comment of the Board in the ~acKenzie c~se that th~ French LaDqu~ce Services Act. provides an "important context for assessing the reasosab!ene?s of the relationship of the qualification to the position." MacKenzie, referred to at p. 15 Beck). .The Board in the Beck case found {at p. !5) that: "Unlike the situation in Giasson, the decision to incorporate the language requirement in the posting was motivated, in part, by the enactment of, and the need to comply with, the French Lanqua~e Services Act, 1986. In our judgement, the process described by Mr. Gibson, which led to the establishment of the qualification, was comprehensive and based on considerations which were directly related to the demands of both the Iegislat~on and the posit~on. Throughout, a major objective of the Employer was to arrive at a result which would enhance the existing level of French language services within the District and the Region. It wished to ins~dre that a reasonable level of-service would be provided to those persons who wished to communicate with government in French. We think it reasonable for the Employer to isolate positions having a significant degree of public contact as such would likely serve to maximize the opportunity for service delivery in that language. More specifically, we find .. that the Employer properly considered the nature of the responsibilities exercised by.the.Purchasing '' .Supervisor. Persons in the position would have substantial contact with contractors and suppliers, often on issues of some complexity .... Whit'e demand for such a service had not been great in. the past, it is a reasonable inference that it would increase if the service actually was available." Further at p. 17 of.the Beck case: "Lastly, we think it was reasonable for the Employer to implement the French Lan~uaqe Services Act, !985 in such a way as to minimize disruption to existing staff .... The Board in the ~ case does not appear to have had the Beck case brought to its attention. It was agreed that th~ major work involved in the posted po=~ion is ~,perat~ng snowpt,~ws in wint=~' - ~ cut~ ~ ~ ...... ;.n~ _ ~tus from the road and performing ~oa~ ma~nt duties in summer. ~nis would include repairing guide rails. fixing broken signs and patching pot holes. Brett Clemens is the Patrol Supervisor in Patrc, l Yarl 25. VanK!eek Hill, and has occupie,1 that positior: since :3ct,~ber cf 19~8 ~d supervises the incumbents in the positi~Dn sought the Grievor. He described the staffing in winter as consisting of four snowplow helpers and fourteen persons occupying the Patro~ Operator AB Positioa classified as Hea~ Equipment Operator 2s. He described the Patrol Operator AB inc~ents as performing general equipment operator dutie~ or night patrol ,Juries. Of th~ 14 Patrol O~era%ors who work d~.~r~ng %~e ,.~=.~.s. ~hree are assigned to Night Patrol duties ~e Vankle~k Hill Patrol Yard service~ a~ area i~ci~.~ii~9, county of Prescott whose ~oDulation having French as a mother tongue is approximately 75~ and the county of Glengarry were the percentage is ap9roximately 40~. ~ere are two shifts for the snowplow crews, one beir~g from 8:00 a,m. to ~:00 p.m. and the other from 8:00 p,m. to ~:00 a.m.. and both crews operate five days a week from Monday to If crews are required outside of regular hours and weekends., such needs are met by overtime ausig~ents. ~e three Night Patro!mer~ referred to work either an 8:00 a.m. to 5:00 p.m. or an 8:00 to 6:00 a.m. shift. ~$re are two night patrolmen on duty days a week with two of them working while the other is off. In and 5:00 p.m. to 8:00 p.m. w~!! be covere~i. Al! Patrel are sub~ect to being selected to work a~ Night ~.~-~',' serving as a Patrol Operator, an employee operates equipment and performs general maintenance. Incumbents are also responsible for the other duties above referred to. As Night ~trc!men ~hey are responsible for supervising the snowplow crews. In summer, there are six full time Patrol Operators who work a five day week from Monday to Friday, there being one shift from ?:45 a.m. to 4:30 p.m. During the summer, the average time-off taken by a Patrol Operator is five weeks, with four weeks representing vacation time and one week representing overtime accumulation from the winter operation. Vacation and overtime accumulation time- off must be taken during the summer months. Winter is treated as being the period from November 1 to March 31. It was the position of the Employer that there are a number of occasions when Patrol'0perators must perform tasks, few of them being specifically set out in the position specification, which require them to have the ability to communicate in French. This submission was also said to be applicable to a Patrol Operator when he acts as a Night Patrolman. Those occasions referred to were as follows: 1. Assisting the travelling public whose vehicles have become disabled on the highway. 2. Assisting persons who have been involved in accidents on the hi,~hway. 9. Dea!in~ with the~public who make' complaints with respect to such matters as fencing and drainage, Engaging in traffic control where there has Peen a ve~%~c!e break~cwn c.r an accident on the highway. 5. Dealing with private contractors who perform repairs ~n Ministry equipment. This would include prlvate contractors who operate local garages. 6. Dealing with snowplow contractors who are hired by the Ministry in winter to operate snowplows and salt units. Patrol Operators have to work with these contractors, as they plow the roads as a team. Depending on weather conditions, different formations are utilized and the Patrol Operators and private contractors must harmonize their method of operation. 7. During the summer, pr.ivate contractors haul gravel for shoulders and Patrol Operators are assigned to supervise this work which occurs once a week in the case of shouldering and as much as twice a month in connection with hauling gravel. Each operation may take two weeks. Ditching operations are also conducted during the sum~er and contractors are hired to assist in this operation. Mr, ~" Clemens testified'that approximately §0~ of the contractors have French as their mother tongue, 8. The Patrol Operator~ are also required to deal w~th propert)~ owners a~,~g. Highway 417, a ma~or~ highway being ..'~"~.-~,,, ~ ....... ~". the Vankieek Hill Patrol Yard. ~e Patrol Qperat?rs are responsible for carrying out fencing operations along adjoining properties and they frequently have to deal with the adjacent property owners who are approx{mate fr,~ncopho~e. Questions are frequently asked about the nature of the work to be conducted ~d requests are frequently made for repairs. Mr. Clemens estimated that contact with the travelling public by Patrol Operators would occur, on average, twice a week. Fifty percent of the travelling public were said to be francophone. While the francophone population did not insist on being spoken to in French, they ~ould normally speaM French and some of them cannot speak En~!ish. Mr. Clemens testified that there are two bilingual Patrol Operators assigned to the Vankleek~Hill patrol yard, one of whom i~ the incumbent of the position bein~ sought by the ~i{~vor. During the winter months lw~. Clemens assigns a bilingual Patrol' Operator to each shift so that it would be possible, through radio communication, to provide service in En~Iish and French. It was the position of the Employer that' the composition of the public being dealt with by Patrol Operators, comprising large percentage of francophones, including a large percentage of francophone contractors, makes it a reasonable requirement that the incumbent be able to communicate with contractors and the public in French. This was said to .be even more ~ecessary t?~e planning that must be carried out with a view te the ~equ~rements of the French Lan,~ua~e Services Act whi~~ ar= ~ke!y to apply to the Vankleek Hill patrol yard. Although it was submitted on behalf of the grievor the ~v~eption ~-,f traffic control the Patro1 Oper~o~ does not include the duties and responsibilities involving communication with the public and with contractors listed above, we find that they were part of the actual duties and responsibilities of Patrol Operators. We are concerned with the actual duties and responsibi!±ties of a Patrol Operator and we are satisfied that the position includes .alt of the listed Fontacts. They are somethin~ than mere adjunct responsibilities and they are essent~a! to the position even though they involve only minor percentage of the incurabents' working t~me. The question is: is the ability to communicate verbally in the French language a reasonable requirement for appointment to the position7 Much of the Grievor's ability to testify as to the contact responsibilities of the Patrol Operator was affected by the fact that although he has worked in the snowplow operation for seven years, it was as a snowplow helper operating the wing at the side of the snowplow. He did not fulfil the functions of Patrol Operator, I believe that he did not wish to mislead us but I accept the evidence of M~. Clemens,. who did function in the position for a period of time, and would find that his evidence · ::s to the frequency of contact and the nature of the Patrol Operators with the public and with contr.~ctors is ~..o_ ~ accurate. Malcolm MacMaster also testified on behal~ of the Em~i~ He is the District Engineer for t.he area. including V~nkleek Hilt, and is the senior manager for the District. Mr~ HacMaster agreed with the evidence of Mr. Clemens relating to the contact of the Patrol Officer with the public and with contractors and added the contact betwe~h the Patrol Operator and representatives of municipalities, where there is overlapping jurisdiction between provincial and municipal authorities. He testified that except for the reference to flagmen in the position- sp~cification, there was no reference to the duties and responsibilities involving dealing with the public,.contractors, and municipal authorities, but he added that it was, nevertheless, an intrinsic part of the job carried ou% by all Patrol Operators. Mr. MacMaster's evidence, in addition to dea!inq with the various contact responsibilities of Patrol Operators, also dealt with his role in the implementation of the. French Lan~uace Services Act for the District. He was the persbn responsible for ~mplementation of the Ac__t in the District. He testified that he became aware of the Ac___%t in August of 1986 and completed Exhibit ~7, which is part of the planning process prior to the implementation of the Act with respect to the District. Exhibit ~7 != entitled: "French Language Set/_., Act ......... Planning Process" ."7~..e relevant portions of the document are as "tev~l ....n~ded A11 lezations must have at leas~, .... .one ,-~qu~emen~s r,f the o,~tion ~n ,',= ~ Act Present level District Office and certain patrols/crews cannot meet this requirement. Action required The competition process will be used to meet the requirements of the Act. Time frame All locations to have this capability by for action November 18, 1989. Given the percentage of francophones in the area se, v,c~d by the Vankleek Hill Patrol Yard, it was not unreasonable to anticipate that the area in which the Vankleek Hill Patrol Yard is located would be ~esignated in a schedule so as to be affected by the provisions of section 5 of the .Ac%. In light of this reality, Mr. MacMaster prepared Exhibit 97, The action provided for: "The competition process will be used to meet the requirements of the Act", was a reasonable response by M~.. ~acMaster, given the ~inguistic breakdown of the area serviced by the District, Mr. MacMaster testified that the original number of bilingual Patrol Operators to be appointed over time was five, but this was reduced to two on the basis that it would be sufficient to have one person on each shift who could fulfil the language requirement. In addition, because of the reduced number .:,~ persons work,nc du..nc s an a ..... p.. wou.d ............ ,:,per,to·.. with two persons who.could communicate'in. French, c~,~ were required they could be considered at a later date One person was deemed to be insufficient as this would only ~nable. ,-,~e..~ shift to be ~_.~ered,~, . It was felt that in the one bilingual ?~troi Operator would be insufficient bec.~use cf the fact that this is When vacation and accumulated overtime time off is taken. Mr. MacMaster concluded that two persons who · filled the language requirement would represent a reasonable attempt to serve the Vankleek Hill Patrol at this time. I would find that designating the position as bilingual was a reasonable response by the Employer. ~nere was no suggestion in the evidence ~iven on behalf the Employer that the imposition of th~ requirement was·for any other purpose than to place the District in a position where it could comply with the Ac__t when its requirements applied to the area served by the VankIeek Hill Patrol Yard. The Employer' does not have to wait until s. 5(1) of the Act becomes app!~cab!e to the area serviced by the Patrol Yard. A reasonable employer, in the circumstances, could take necessary steps so that the Ac___~t would not create a chaotic situation within the District upon its being made applicable to the Vankleek Hill Patrol Yard. Although the impetus for the introduction of the requirement that the incumbent be able to communicate verbally in French was the enactment of the French Lan~uace Services Act, the .~ ........... s of the position an~ in ~spect of sue~ zationshi~ was mot. than tenuous or speculative. See reference to the MacKenzie Award test at p, 14 of the Beck Award. 'eve!, it is irrelevant for the purposes of this Decision tllat the ~loyer imposed a standard of communication ~n Frep. ch "~ the ~,,~'-~ ~','~" For at! o~ the a~ove reasons, the grievence is denied. DASD AT Toronto, Ontario this ~th day of J~ 199~-. M. R. Gorsk,/ ¥ice-Chairperson "! D~SENT .," (Dissent: wi~:hout writ:ten reason) G. Ma jesk.~ ....... Me~er D. Montrose ......... I~ember