BCGEU SUBMISSION TO THE FAIR WAGES
COMMISSION CONSULTATION
May 30, 2019
Introduction and overview
On behalf of BC Government and Service
Employees’ Union (BCGEU) members, we appreciate
this opportunity to provide a final submission to the
provincial government’s Fair Wages Commission.
The BCGEU represents more than 78,000 workers
in various sectors and occupations in more than 550
bargaining units throughout British Columbia. Our
diverse membership includes direct government
employees who protect children and families,
provide income assistance to vulnerable individuals,
fight forest fires, deliver care to people with mental
health issues and addictions, administer B.C.’s public
system of liquor control, licensing and distribution,
staff correctional facilities and the courts, and
provide technical, administrative and clerical
services.
Our membership also comprises of workers
throughout the broader public and private sectors
where members provide clinical care and home
support services for seniors, a diverse range of
community social services, highway and bridge
maintenance, post-secondary instruction and
administration, as well as other non-governmental
industries, including financial services, hospitality,
retail and gaming.
In this submission we make two sets of
recommendations, covering:
1. Practical suggestions to reduce the
discrepancy between the minimum wage
and the estimated living wage (for example,
through a combination of regulatory
actions to support current and future wage
adjustments, and investment-based actions to
increase affordability); and
2. Broader institutional strategies designed to
bolster average wage growth and the overall
bargaining power of workers across British
Columbia (for example, through additional
changes to the Employment Standards Act
and Labour Relations Code that will enable
wider organizing potential in non-union
workplaces, and better security for non-union
workers generally).
The big picture for British Columbians,
and some successes to date
The BCGEU and its members have been essential
participants within the Fair Wages Commission’s
ongoing consultations since 2017. Our advice
has covered a range of specific items and issues
throughout this process, including the suggested
wage rate, transition and implementation,
(eliminating) exemptions, and measures to ensure
effective monitoring and ongoing review in the
future.
These contributions—made in written submissions
and through in-person hearings—are also shaped
and informed by our continuing involvement with
other related consultations and public forums. For
example, through the province-wide consultations
on a poverty reduction strategy, multiple
submissions to both the Employment Standards Act
and Labour Relations Code reviews, the Rental
Housing Task Force, and the annual provincial
budget consultation process.
In most cases, the specific issues or items for
consideration (and our members’ viewpoints) fit
within a much larger and encompassing discussion
of wide public significance. For the moment, this
pressing discussion concerns the ability of working
individuals and their families to lead secure and
reasonably prosperous lives in exchange for their
employment. Again, the BCGEU has submitted its
views on numerous occasions regarding elements of
this widely experienced struggle for British
Columbians, be it on wages, affordability, housing,
the availability of quality public services and
programs, or underlying principles of fairness and
economic equality.
Our union is pleased with the substantial progress
government has made in key areas of policy to
improve the economic security of B.C. residents—
including, of course, with the commitment to reach
a $15 minimum wage by June 2021. We are
likewise greatly encouraged by the impact that
public child care investments have had on reducing
the living wage estimate for most B.C. communities
in 2019 (a notable outcome of which is the first
decrease in 11
years for the Metro Vancouver region—to $19.50 per
hour, down from $20.91 in 2018).1
This is a profound achievement, and it confirms a
very promising avenue for ongoing policy change. In
taking stock of this success, however, we suggest to
the Commission that there are other, perhaps even
larger challenges to raise and address at the same
time.
Keeping up the pressure (but
identifying some limitations)
No doubt, achieving a lasting convergence between
the estimated living wage and the statutory minimum
is essential. For now, at least, the difference between
the two provides a crucial yardstick for gauging
progress on baseline earnings and affordability in
the province. By that measure, though, B.C.’s least
affordable region will still face a gap of $5.65 per
hour in June 2019, or 41 per cent of the minimum
wage. This is a very significant disparity.
In beginning to answer the Commission’s question
on how to address this discrepancy between the
minimum wage and a living wage, we think,
certainly, that the approach involves continuing
to apply pressure from both sides: policies, public
programs and services that deliver a measurable
impact on essential living costs for families and
workers (e.g. public child care, housing and
transportation investments; stricter rental increase
protections in the housing market); and, at the same
time, transparent, predictable and regular increases
to the provincial minimum wage by way of a
permanent commission.
BCGEU’s recent submissions to government have
discussed these and other proposals at length, and
with additional context and detail.2 It is encouraging
1
  Living Wage for Families Campaign, “BC’s child care investments
have a major impact on 2019 living wage,” News release, (May
1, 2019). Accessed May 14, 2019. https://d3n8a8pro7vhmx.
cloudfront.net/livingwageforfamilies/pages/52/attachments/
original/1556748068/2019_Calculations_Release_for_Web.
pdf?1556748068
2
  See, for example: BCGEU, “Submission to the Select Standing
Committee on Finance and Government Services,” October
16, 2017. Available at: https://d3n8a8pro7vhmx.cloudfront.
net/bcgeu/pages/5289/attachments/original/1508275775/
BCGEU_Budget_Submission_2017.pdf?1508275775 ; BCGEU,
submission to the fair wages commission
that many elements of this policy agenda are
reflected not just in the submissions and appeals
made by other similarly concerned organizations,
but in the significant efforts that have already been
made by government to improve programs and
services, and to make life better for a majority of
working British Columbians. We ask our government
to continue this impactful work with the following
actions:
1. Establish a permanent and independent Fair
Wages Commission
Appropriately managing the provincial wage floor
requires an independent and non-political body
to oversee regular, predictable increases to the
minimum wage. Its mandate should be clearly
defined alongside transparent evaluation criteria that
will guide future wage-related recommendations,
free from political interference.
2. Eliminate all exemptions to the general
minimum wage
Allowing industry-specific exemptions to the
minimum wage only promotes continued insecurity
for low-wage workers, and reinforces the potential
for lasting wage gaps between different workers,
industries, and demographics (for example, food
and beverage workers, farm workers, care workers,
women, migrant workers, workers of colour, and
other minority groups). It also maintains an incentive
for certain employers to misclassify workers to avoid
paying a higher (and universal) minimum wage.
“Submission to the Fair Wage Commission,” December 7, 2017.
Available at: https://d3n8a8pro7vhmx.cloudfront.net/bcgeu/
pages/6432/attachments/original/1512687416/BCGEU_Fair_
Wages_Commission.pdf?1512687416; Stephanie Smith, “Re: B.C.
Labour Relations Code Review,” March 20, 2018. Available at: https://
d3n8a8pro7vhmx.cloudfront.net/bcgeu/pages/7335/attachments/
original/1521734339/Labour_Relations_Code_Review_Submission_
March_20_2018.pdf?1521734339; BCGEU, “Submission to the
Rental Housing Task Force,” July 6, 2018. Available at: https://
d3n8a8pro7vhmx.cloudfront.net/bcgeu/pages/8075/attachments/
original/1530917566/BCGEU_RHTF_Submission_20180706.
pdf?1530917566; BCGEU, “Submission to the Select Standing
Committee on Finance and Government Services,” October 11,
2018. Available at: https://d3n8a8pro7vhmx.cloudfront.net/bcgeu/
pages/8527/attachments/original/1539297554/budget-submis-
sion-finaldraft2.pdf?1539297554; Stephanie Smith, “Re: Modernizing
the Employment Standards Act Consultation,” March 31, 2019.
Available at: https://d3n8a8pro7vhmx.cloudfront.net/bcgeu/
pages/9488/attachments/original/1557867894/LT-Min.Bains_ESA-
Consultation.pdf?1557867894.
Page 2
3. Continue making essential public investments
in high-quality services, programs and supports
that make B.C. a livable and more affordable
place for workers and families
Our government has already shown the incredible
value that targeted programs and interventions can
have to improve public access to critical, often
expensive, goods and services—the effect of which
is to meaningfully (and rapidly) reduce the living
wage estimate across our province. To build upon
and sustain this progress, government will need
to continue to expand its investments and key
regulatory activities in areas that include:
• Public child care (reaching $10-a-day
province-wide);
• Affordable housing;
• Public transit;
• Provincial health services (e.g. dental care,
optometry, paramedical care, and enhanced
pharmacare); and
• Access to post-secondary (e.g. expanding
tuition grants, a wider open textbook
program)
Above and beyond these more specific
recommendations and related successes to date,
however, we wish to highlight an emergent theme
that cuts across our many contributions within this
process—which is that, fundamentally, the position
of workers in our province and our economy needs
to change.
Policymaking demonstrates that programs and
services can make a difference for what working
families can afford in necessary services like quality
child care (and to that end, a reasonable
improvement in their standard of living).
Policymaking can also deliver significant
adjustments to raise the minimum hourly wage (not
to mention by an amount that was deemed
outrageous just a few years prior).
Regrettably, however, if these efforts leave an
unresolved question of the significant gap in
between—particularly during a time of sustained
economic growth, comparatively high productivity,
submission to the fair wages commission
and consistently low unemployment—then we
need to consider the possibility that our market
economy is not functioning properly for most of its
participants, and that its legitimacy is in question.
Shifting the discussion from
affordability to bargaining power
Average wage growth is stagnant across most
advanced economies,3 and this includes Canada.4
In B.C., average individual income grew just 1.48
per cent per year between 2009 and 2017, 5 and yet
the provincial economy grew an average of 3.14
per cent per year over the same period6—more than
double the rate of increase to individual earnings
annually. In effect, this means that workers are taking
home less and less in an economy that continues to
grow abundantly.
Beneath this simple fact lie additional and more
troubling distributive issues, including an alarming
overall increase in inequality across the provincial
(and national) economy. If the average annual
income for individuals in the province was $47,100
in 2017 (adjusted for inflation), then the median
was just $35,400—a difference of $11,700 per year
(or 24.8 per cent less). This alone reveals something
significant about the distribution of economic
rewards: the total income, wages, and other earnings
that accrue to a small and select proportion of
residents at the top is so large and disproportionate
that it dramatically inflates the statistical average by
exactly a third of the median.
The unfortunate reality is that 50 per cent of B.C.
workers earn below $35,400 per year (a statistical
3
  See: OECD, “Wageless growth: Is this time different?”, OECD
Employment Outlook 2018 (Paris: OECD Publishing 2018), 11-19.
Available at: http://www.oecd.org/social/oecd-employment-out-
look-19991266.htm
4
  See: Anne-Katherine Cormier, Michael Francis, Kristina Hess,
and Guillaume Poulin-Bellisle, “Drivers of Weak Wage Growth in
Advanced Economies” (Ottawa: Bank of Canada, 2019). Available
at: https://www.bankofcanada.ca/wp-content/uploads/2019/01/
san2019-3.pdf
5
  Calculations based on data from: Table 11-10-0239-01 Statistics
Canada, “Income of individuals by age group, sex and income
source, Canada, provinces and selected census metropolitan areas.”
Accessed: May 22, 2019.
6
  Calculations based on data from: Table 36-10-0222-01 Statistics
Canada, “Gross domestic product, expenditure-based, provincial and
territorial, annual (x 1,000,000).” Accessed: May 22, 2019
Page 3
fact), and although this median value approaches
the estimated living wage calculation for Metro
Vancouver in 2019 (in annual terms), somebody
earning the minimum wage as of June 2019 will be
making $10,694 less than that per year (-30.2%).7
Continuing to raise the floor on minimum earnings
can help shrink this gap, and it can bring the lowest-
paid, most vulnerable workers within reach of an
‘affordable’ position economically (especially if we
continue to apply downward pressure on the living
wage through services, supports and other public
investments at the same time).
In the longer term, however, this effort cannot in
itself significantly alter the position of workers and
households relative to their output and contribution
in the overall economy, or the distribution (and
realization) of shared returns from continued growth.
To make this shift, what we need are bolder
measures to: 1) significantly increase average (real)
wage growth on a continuing basis (relative to total
economic product); and 2) simultaneously compress
and equalize the distribution of these earnings—
starting with the very bottom (and the very top).
In a labour market with near-full employment,8
and where wages have become stubbornly
decoupled from growth in productivity,9 this can
only be done through measures that strengthen
7
  Calculations based on average annual working hours for B.C.
residents, obtained from: Table 14-10-0043-01 Statistics Canada,
“Average usual and actual hours worked in a reference week by type
of work (full- and part-time), annual.” Accessed: May 22, 2019.
8
B.C. still has the lowest unemployment rate in the country, and
there is a growing consensus among economists that the provincial
labour market is operating at very close to full employment. It
should be noted, however, that much of the employment growth
and job creation seen recently in the province has been in
part-time and temporary positions (notwithstanding some slight
improvement in full-time growth in early-2019). At the same time,
observations also remain that, despite a very hot labour market,
overall wage gains are sluggish and just managing to keep pace
with underlying inflation. See, for example: Tyler Orton, “B.C.
adds 4,400 jobs in December amid ‘so-so’ numbers for country,”
Business in Vancouver, January 4, 2019. Available at: https://biv.
com/article/2019/01/bc-adds-4400-jobs-december-amid-so-so-
numbers-nation; Albert Van Santvoort, “Canada hits record low
unemployment rate, B.C. bucks trend,” Business in Vancouver,
December 7, 2018. Available at: https://biv.com/article/2018/12/
canada-hits-record-low-unemployment-rate-bc-bucks-trend
9
OECD, “Decoupling of wages from productivity: What implications
for policy?,” OECD Employment Outlook 2018 (Paris: OECD
Publishing 2018). Available at: http://www.oecd.org/eco/outlook/
Decoupling-of-wages-from-productivity-november-2018-OECD-
economic-outlook-chapter.pdf
submission to the fair wages commission
the overall bargaining power of all workers—
union and non-union alike—and enable them to
capture a significantly greater share of the profits
and economic rents currently extracted by today’s
businesses and employers.
We need to change the rules of the game for workers
in our economy, and with the nature and underlying
structure of work shifting the way it has in recent
years (toward irregular, flexible, and precarious forms
of employment), the need is especially urgent.
As the work of the current Fair Wages Commission
begins to wrap up, the BCGEU asks government
to carefully consider the following actions and
strategies:
4. Provide additional enhancements to the
Employment Standards Act to strengthen the
overall security and bargaining power of non-
union workers in the province
Amended legislation introduced on April 29, 2019,
will offer some essential improvements to the Act,
including: access to supports for worker complaints
and better enforcement; avenues of redress for stolen
wages; and stronger protections for young workers
who face exploitation.
The outcomes of this legislative review, however,
could have gone much further to empower non-
union workers—which is particularly urgent given
that temporary, part-time and precarious work forms
are increasingly the norm, and that constraints on
wage growth are now deeply entrenched despite
record-low unemployment and consistently strong
economic growth.
We ask this government to introduce additional
amendments to the Act that would:
• Require employers to post work schedules
at least two weeks in advance (guaranteeing
four hours’ pay if the schedule is changed
with less than 24 hours’ notice);
• Implement paid sick leave for all workers
(accrued at a minimum of one hour of paid
sick time for every 35 hours worked), and
prohibit termination based on employee sick
leave; and
Page 4
 • Eliminate the three-month eligibility
requirement for termination notice or pay in
lieu of notice; require just and reasonable
cause in the event of termination; and
implement an expedited administrative
adjudication process to assist workers who
have been unjustly dismissed.
5. Actively support wider unionization in the
province, and strengthen the rights of non-
union workers to organize by providing further
amendments to the Labour Relations Code
The strongest determinant of workers’ aggregate
bargaining power in any labour market and economy
is the extent of unionization (or density)—and
related to that, the strength of the legal institutions
that support and reinforce both a bargaining unit’s
formation and the relative force of its activity vis-à-
vis collective action (or the threat thereof).
While the historical decline of union density across
most advanced economies—and in Britain, the U.S.,
and Canada particularly—is well documented, the
social and economic consequences for wages and
income distribution are now being explained with
increasing empirical rigour and clarity.
Arguments made within the previous literature
saw de-unionization as a part of the explanation
behind rising inequality, and perhaps as a related
but natural side effect of changing technologies
and work processes. But the most recent and
authoritative studies now show a dominant and
causal relationship between the decline of organized
labour and the rapid growth in economic inequality
seen across societies.10 It also shows that the overall
flattening of wage growth, and the decoupling
of wages from productivity, are explained less by
technological changes and other so-called ‘market
forces’ than previously thought, and significantly
more so by the greatly weakened bargaining position
of all workers—which, again, is brought on by
declining union density and a host of deliberate
  See: Henry S. Farber, Daniel Herbst, Ilyana Kuziemko, and Suresh
10
Naidu, “Unions and Inequality Over the Twentieth Century: New
Evidence from Survey Data.” NBER Working Paper 24587. (Princeton,
NJ: Princeton University, Industrial Relations Section, May 2, 2018).
Available at: https://www.nber.org/papers/w24587
submission to the fair wages commission
labour market reforms.11
In other words, the reduced bargaining power of
workers has led to slower average wage growth
for the entire economy (relative to total economic
growth); and has resulted in increasingly unequal
and ‘polarized’ distributions of wages and earnings
at the same time. To be sure, the principal means
for correcting this imbalance is through wider
unionization, and through policies and institutions
that make it easier for non-union workers to
organize. This is our best opportunity and avenue for
eventually making all wages a living wage (including
the minimum wage).
For simple perspective: in B.C., membership in a
union extends an immediate wage premium worth
on average 21.8 per cent more per hour than what
workers with no union coverage receive (+$5.48/
hour).12 (Coincidentally, this hourly advantage
happens to be almost exactly equal to the current
gap between the minimum wage as of June 2019 and
the calculated living wage for our province’s most
expensive region – see above.) Collective agreements
also tend to provide valuable extended benefit
coverage such as medical and dental, which help
reduce essential living costs for workers and families.
These are obvious wins for affordability—at
least for most union members. But the presence
of strong unions and strong organizing rights
have wide spillover benefits that help increase
bargaining power and wages for all labour market
participants—including non-union workers who,
under more empowered circumstances, represent
a more significant and credible threat of future
11
  Alan B. Krueger, “Reflections on Dwindling Worker Bargaining
Power and Monetary Policy” (lecture, Jackson Hole Economic
Symposium, April 24, 2018). Available at: https://www.kansascityfed.
org/~/media/files/publicat/sympos/2018/papersandhand-
outs/824180824kruegerremarks.pdf?la=en; Anne-Katherine Cormier
et al., Drivers of Weak Wage Growth in Advanced Economies”
(Ottawa: Bank of Canada, 2019); OECD, “The role of collective
bargaining systems for good labour market performance,” OECD
Employment Outlook 2018 (Paris: OECD Publishing 2018), 73-124.
Available at: http://www.oecd.org/social/oecd-employment-out-
look-19991266.htm; OECD, “Decoupling of wages from productivity:
What implications for policy?,” OECD Employment Outlook 2018
(Paris: OECD Publishing 2018). Available at: http://www.oecd.org/
eco/outlook/Decoupling-of-wages-from-productivity-november-
2018-OECD-economic-outlook-chapter.pdf
12
  Calculations based on data from: Table 14-10-0066-01 Statistics
Canada, “Employee wages by job permanency and union coverage,
annual.” Accessed: May 24, 2019.
Page 5
union certification for their employer. Creating this
institutional environment is the surest means of
overcoming not only the living wage hurdle, and
closing the gap with the minimum wage beneath
it, but altering and strengthening the position of
workers—thereby establishing them as an essential
wage-setting force in our economy.
To this end, we ask the government to extend
additional—critical—enhancements to the recently
introduced amendments to the Labour Relations
Code. These should include new changes that
would:
• Introduce multi-employer sectoral
certification (to empower workers within
private, often-low wage and traditionally
difficult-to-organize sectors, such as retail,
food and beverage, and hospitality);
• Eliminate the current two-step certification
process and remove the need for a second
vote in cases where 60 per cent of workers
have already voted to unionize by signing
their names to membership cards; and
• Replace all references to “proper cause” in
the Code with “just and reasonable cause”
to protect vulnerable workers, including
those who have recently unionized but not
yet reached a first collective agreement.
submission to the fair wages commission
Conclusion
The work of this government, as well as the Fair
Wages Commission, is making a significant and very
real difference for working British Columbians and
their families. The BCGEU applauds this important
effort and supports government’s continued
execution of a winning strategy: chiefly, through
regulatory, wage-, and public investment-based
measures that help push a convergence between
minimum earnings and basic affordability.
At the same time, we highlight for policymakers
a related but even greater message about the
necessity (and urgency) of equipping workers
with much-needed bargaining and wage-setting
power in our economy. Only with the legal and
institutional empowerment of workers can we
expect to resolve depressed wage growth, and start
to deliver the means for reclaiming a rightful share
of the province’s continued economic growth and
prosperity.
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