"We understand the panel desires the Canadian Union of Public Employees to answer the following question.

• If you become the bargaining agent for the intermingle unit of Flight Attendants, how will you deal with the integration in the said bargaining unit of the employees who you do not currently represent?

CUPE can answer the above-noted question easily and succinctly. This is because CUPE has dealt with this very same issue many times over many years..."

"CUPE characterizes the integration referred to above as full seniority integration. All Flight Attendants will be integrated into the new bargaining unit on the basis of their flight attendant bargaining unit seniority held with each of the employers prior to the "merger" of the two bargaining units. In other words, each Flight Attendant will carry their seniority into the new bargaining unit."

"CUPE not only believes but also practices full and fail seniority integration. All Flight Attendants (from whatever bargaining unit they originally come from) are treated the same by CUPE once they are within CUPE bargaining units. In other words, the same rules apply regardless of which of the origional bargaining units the Flight Attendants originally came from. The various seniority lists are essentially dovetailed to include all Flight Attendants in the new bargaining unit..."

"The policies and practices of the Airline Division are applicable to all Flight Attendants who come within the jurisdiction and representation of the Airline Division and its various components..."

The Airline Division is Bound to such policies. CUPE has accepted and endorsed the policies since the Airline Division joined CUPE over one decade ago..."

"CUPE has been able to avoid over the past decade the bitter, costly and time-consuming seniority disputes the have plagued other bargaining units and unions in the airline industry in Canada..."

This was only possible because CUPE already had the policies, practices and expertise in place. Everyone knew in advance what CUPE would do and where they would stand at any given time in this situation..."

"...it is equally fair to say that seniority is the most critical right for any member of an aircrew in a bargaining unit in the airline industry in Canada. As the Board is painfully aware, seniority disputes can cause an incredible amount of disruption for employees, bargaining agents and employers alike..."

"These policies have created precedent, predictability and consistency in the CUPE flight attendant bargaining units across the industry. Every Flight Attendant knows well in advance how this issue will be addressed even before a merger takes place..."

"...In addition to all of the above, CUPE submits that it has the personnel available to assist the smooth integration of Flight Attendant bargaining units in this case. CUPE submits that its personnel have the expertise and resources available to them (including the policies to rely upon referred to earlier..."