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Australian Industrial Relations Commission Transcripts |
AUSCRIPT PTY LTD
ABN 76 082 664 220
Level 4, 60-70 Elizabeth St SYDNEY NSW 2000
DX1344 Sydney Tel:(02) 9238-6500 Fax:(02) 9238-6533
TRANSCRIPT OF PROCEEDINGS
AUSTRALIAN INDUSTRIAL
RELATIONS COMMISSION
COMMISSIONER LARKIN
C2002/6053
C2002/6054
STATE RAIL AUTHORITY OF NEW SOUTH WALES
and
AUSTRALIAN RAIL, TRAM AND BUS INDUSTRY
UNION and ANOTHER
Notification pursuant to section 99 of the Act
of a dispute re alleged refusal of employees
to allow the sale of pre-encoded tickets
APPLICATION FOR CERTIFICATION OF AGREEMENT
Application under section 170LW for settlement
of dispute (certification of agreement)
SYDNEY
2.15PM, FRIDAY, 20 DECEMBER, 2002
PN1
THE COMMISSIONER: Could I take appearances please.
PN2
MR A. WOODS: Commissioner, with leave I appear for State Rail.
PN3
MR G. PANIGIRIS: If the Commission pleases I appear with
PN4
MR S. LANSDOWNE for the Rail, Tram & Bus Union.
PN5
THE COMMISSIONER: Mr Panigiris, do you have a position on Mr Woods' application for leave to appear?
PN6
MR PANIGIRIS: I have no objections, Commissioner.
PN7
THE COMMISSIONER: Leave is granted, Mr Woods. No appearance on behalf of the ASU?
PN8
MR WOODS: No, and I think it's fair to say from the table, certainly from our side we thought there was going to be an appearance from Mr Moon from the ASU. Mr Panigiris in discussions wasn't quite so certain whether or not he was going to be here today as opposed to Monday when the second day of this is proceeding and where Mr Moon and his union appear to have a greater interest on the topic that was divided off administratively, or expected to be divided off administratively for that day.
PN9
THE COMMISSIONER: Mr Panigiris?
PN10
MR PANIGIRIS: Commissioner, I think at our last conference Mr Clarke did indicate that the ASU had no interest in relation to the travelling issue however did have an interest in relation to the pre-encoded issue but I did speak to Mr Rule from the ASU yesterday. He asked me what the matter was about. I explained to him the matter and he indicated to me that he would advise Mr Moon not to attend so I presume that's what occurred out of those discussions yesterday.
PN11
THE COMMISSIONER: Gentlemen, a document has been received. It's my understanding that the RTBU and State Rail have a copy of that document. It was forwarded by Mr Moon to my chambers on 18 December and it's stated to be a written submission in accordance with the directions. In a sense it's a statement of a submission I suppose from a Mr David Speed, salesperson at Town Hall Station for State Rail Authority. Pending any objection I planned to mark that document.
PN12
MR PANIGIRIS: Commissioner, I read that document and saw that as being part of the pre-encoded issue more so than the travelling issue.
PN13
THE COMMISSIONER: But that doesn't mean I shouldn't mark it.
PN14
MR PANIGIRIS: I understand, Commissioner, I was just explaining it.
PN15
MR WOODS: We would have no objection to that being marked. Ultimately we received a faxed cover sheet with that one page statement by Mr Speed, just to make sure we're all talking about exactly the same document.
PN16
THE COMMISSIONER: Yes, it's a covering sheet and it had Mr Speed's, for want of a better word, statement and also a copy of the notice of listing.
PN17
MR WOODS: We've got Mr Speed's one page document.
PN18
PN19
THE COMMISSIONER: Now, I received material from the RTBU and also from State Rail not quite on the day I expected to receive all of it but never mind, I have received it. I've looked through that material. Where are we, gentlemen? Mr Woods?
PN20
MR WOODS: Commissioner, you have before you two dispute notifications, one under section 99 and one under 170 LW and there have been discussions between the parties about how to most effectively move to a way in which, Commissioner, you can determine the issues that are raised in those notifications. There are three issues that are raised in those notifications and they are identical to each; one dealing with a question of any allowance or issues in relation to the sale of CountryLink tickets by CityRail station staff, one dealing with the pre-encoded ticket issue, and the third one dealing with what's described as flexible ticketing which through the course of discussions has been identified as sale of pre printed tickets at a sales booth at a station by a CityRail staff member.
PN21
That third matter is going with ongoing discussions and so the parties seek to have that set to one side as it were for the moment and would be continuing discussions over the next month or so and would like to achieve a listing at the Commissioner's convenience in, say, the first week of February for a report back on that aspect of that matter.
PN22
THE COMMISSIONER: You may not get the first week in February but you want a date in February?
PN23
MR WOODS: A date in February, somewhere in that vicinity, Commissioner. The other matters the parties notwithstanding no representation from the ASU today, my instructions and understanding from discussions with Mr Panigiris is that they are equally seeking the Commission's assistance in coming up with a determination which will be accepted and all the parties would be bound by.
PN24
Now there has as I understand been some question about the jurisdictional issues that give rise to being able to achieve that outcome and they're not entirely simple in terms of that, particularly the role of 170LW and the notification of the dispute in relation to that.
PN25
The position of State Rail is that we see that that notification could result in an arbitrated decision but there are issues around it and we don't wish to make an issue of finding that right ground today but we don't walk away from a view that it can be done but in terms of achieving an outcome that can be used by all parties then we have had discussions in relation to using section 111AA and achieving a consent recommendation and we can do that by using the vehicle of the section 99 notification as well and the conciliation discussions that have been had so far and with the consent which even though Mr Moon or the ASU is not here to give today we understand they are at one on and so the parties - Mr Panigiris will indicate his position - but my understanding is that the parties, we certainly consent to allow the withdrawal or lapsing of the 170LW notice on the basis that the parties are proceeding with a 111AA hearing of sorts to achieve a recommendation which by consent the parties will all be bound by and implement.
PN26
So in terms of getting the show on the road, that's the procedural methodology which we see and we understand that both the ASU and RTBU are in agreement with to move the matter forward.
PN27
THE COMMISSIONER: So what you are saying, Mr Woods, is that StateRail would withdraw its section 170LW application and in regards to which is matter number C2002/6054, and continue with the section 99 notification which is 6053 and part of resolving, vehicle to resolving that issue, you are saying to me you would seek a recommendation by consent under 111AA and that StateRail is formally recording that they will comply with the Commission's recommendation?
PN28
MR WOODS: Yes, that's the procedure which we see as happening.
PN29
THE COMMISSIONER: Mr Panigiris, I might ask you just to address that issue at the moment.
PN30
MR PANIGIRIS: We support that application. We are not quite as confident as our friends in State Rail in relation to the earlier arrangements but we think we can resolve and get an outcome in relation to section 1100 and we will accept any recommendation handed down by this Commission.
PN31
THE COMMISSIONER: Mr Panigiris, you don't have authority to speak on behalf of ASU in that regard?
PN32
MR PANIGIRIS: No, I haven't, Commissioner.
PN33
THE COMMISSIONER: I would require the ASU's position on that and I would ask you, Mr Panigiris, if you would please at the end of the proceedings today notify the ASU on my behalf and if that is their position, in other words the same position as Mr Woods has outlined for State Rail and you have outlined for the RTBU then I would like formal advice as to that situation from them. So could you be kind enough to embark upon that inquiry for me?
PN34
MR PANIGIRIS: Yes, Commissioner.
PN35
THE COMMISSIONER: Now, it is my understanding that I am hearing the parties today, this afternoon, on one issue and the other issue in my understanding is to be addressed on Monday, 23rd. I think I'd indicated to the parties that I would list that matter and this possible listing has already gone out on that. Is that your understanding as well?
PN36
MR PANIGIRIS: Yes.
PN37
MR WOODS: Yes.
PN38
MR PANIGIRIS: It's all been dealt with as one but just for the convenience of witnesses and other matters dividing up the way in which we deal with those issues.
PN39
THE COMMISSIONER: I am in your hands, gentlemen whenever you are ready.
PN40
MR WOODS: Commissioner, I might just seek to hand up, if it might be of assistance to you, Commissioner, in terms of some issues that arise during the course of proceedings. It is not matters I would seek to identify for evidence but perhaps could be in effect marked, is to bring to your attention for identification purposes. There will be discussion during the evidence in respect of an folded tickets. I've just got a sample of those which as I understand it. It might help, Commissioner, to know that. There has also been a discussion at different points about books of tickets that are sold separately and if the Commissioner wishes we can show you a sample of that as well. It is just there for identification purposes, it is not for the purpose of evidence.
PN41
THE COMMISSIONER: Both items or just the fan folded or the book?
PN42
MR WOODS: Both items we can have marked.
PN43
THE COMMISSIONER: So that is two types of tickets in a sense, one is a fan folded and one is a book?
PN44
MR WOODS: Yes.
PN45
THE COMMISSIONER: I will mark them MFI1, thank you, tickets.
MFI #1 TICKETS
PN46
THE COMMISSIONER: I gather I can't use them, Mr Woods?
PN47
MR WOODS: No. Well, not as far as I know, Commissioner. I wouldn't want to run into the revenue protection officers and State Transit officers.
PN48
THE COMMISSIONER: No, one wouldn't want to.
PN49
MR WOODS: There is one other item which I might seek to tender before I ask Mr Francis to step into the witness-box. That is just a salary classification rates that are applied at the moment without the industry allowance, just so that during the course of the hearing the question of salary rates are likely to come up and I will take Mr Francis to some evidence in his affidavit about that but I just seek to tender this. These are not matters that Mr Francis is on top of and in a position to give particular evidence. So I would seek to tender that, Commissioner.
PN50
THE COMMISSIONER: Mark the document SRA1, please.
PN51
MR WOODS: It's a document entitled State Rail Authority of New South Wales Classification and Rates of Pay, with a date of 4 December 02 on it. It relates to rates of pay showing three columns, April 01, April 02 and March 03. The last two columns under the current enterprise agreement.
EXHIBIT #SRA1 STATE RAIL AUTHORITY OF NEW SOUTH WALES CLASSIFICATION AND RATES OF PAY, DATED 04/12/2002
PN52
MR WOODS: Please state your full name and address?---Geoffrey Bruce Francis. Unit 15, 10-12 Gerard Street, Cremorne.
PN53
Mr Francis, you swore an affidavit for the purposes of these proceedings dated 18 December 2002?---Yes.
PN54
You have a copy of that with you?---Yes.
PN55
I formally tender that affidavit, Commissioner.
PN56
PN57
MR WOODS: Mr Francis, you have in paragraph 1 of your affidavit set out - there's just a few matters I would seek to cover in-chief in addition, Commissioner - your history. I understand you've also been a station manager?---That's correct.
PN58
How long ago was that?---About 10 12 years ago approximately.
PN59
How long were you in that position?---I was in that position for approximately 4 years.
PN60
Back in those days was the stations at which you were located responsible for country train travel sales?---Yes, that's correct.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN61
Now, I just wonder if you could - are you familiar with the station lay out and the equipment used for Countrylink ticket sales now?---Yes, although the lay outs are different from location to location. yes, I'm fairly familiar.
PN62
I understand that there is a computer terminal that's used for the sale of Countrylink tickets?---That's correct.
PN63
Generally from your experience where in a station is that located?---It's in the booking office in close proximity to the ticketing window.
PN64
So it is not physically at a ticketing window, it's set back from the ticketing window?---Generally in very close proximity to it.
PN65
For the purpose of processing a ticket sale that computer terminal is the terminal that's used by the person selling the ticket, to complete the booking, create the ticket and issue it, is that right?---That's correct.
PN66
Now, you have attached to your affidavit commencing at page 71 - the page numbers are on the top right-hand corner - a document called Joint City Rail, Rail Train and Bus Union Report of Travel Reservation Systems and there is a reference in the middle of the first page of text - sorry, under the heading Method, a reference to station locations at Moss Vale, Campbelltown, Maitland, Blacktown and Penrith. The RTBU in its submissions has also raised a reference to Seven Hills station. Can I just show you a bundle of documents which are CityRail stations job and work design. I think Seven Hills for the first page, Blacktown for the two pages following that, Campbelltown for the two pages following that and Penrith for two pages following that. Can you tell me what that document shows in respect of a particular station?---These are the resource plans and the classifications that are allocated to each of the locations to operate the station.
PN67
Can I tender that resource plan.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN68
PN69
MR WOODS: Now if we just take the first page for example, there is a reference to the initials down the grade, "SM" I take is station manager?---That's correct.
PN70
"DM" is duty manager?---Duty manager.
PN71
"Sales" is reference to the sales person?---Sales person.
PN72
"CSA2" is the customer service officer?---Attendant.
PN73
Attendant 2. Similarly for 1 in terms of those descriptions?---Yes, that correct.
PN74
Now looking at that first page for Seven Hills and looking at the hours and I take it that they are the rostered hours for that particular station?---That's correct.
PN75
The functions are shorthand of functions that are undertaken by the person?---That's correct.
PN76
I think to your affidavit you have annexed a number of position descriptions in respect of various positions and they cover pages 14 through to 48 in your affidavit and covering off on customer service attendants classes 1 and 2 and sales person and sales support officer?---That's correct.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN77
You've said in your affidavit that those persons holding those positions have within their responsibilities sales responsibilities?---That's correct.
PN78
The document that is the resource document you identified highlights that those people have some sales responsibilities?---That's correct.
PN79
Now in relation to CountryLink tickets, are all of those persons able to sell CountryLink tickets?---The only one that doesn't is the CSA1 position, they sell tickets under supervision.
PN80
To be able to sell CountryLink tickets using the computer system, I think there are two things that need to have occurred or a particular officer, there has to be a computer at their station and they have to have undertaken some CountryLink sales training?---That's correct.
PN81
So that again looking at Seven Hills for example, do you know if that has a CountryLink computer?---No, it doesn't.
PN82
If we went to Blacktown on the next page, you've identified the number of positions under sales account T/L, I take that as sales account team leader?---That's correct.
PN83
So that all those people identified with sales responsibilities sales persons, the team leader could sell CountryLink tickets you would expect?---That's correct, yes.
PN84
Would you expect at Blacktown that all would be trained?---Yes.
PN85
The CSA2 on that document doesn't have sales attached?---No, that is because their position is primarily out on the station, the ticketing gates and because of the high volume location they are dedicated sales people.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN86
So if we looked at then perhaps the Campbelltown position, again there is dedicated sales people for that location?---That's correct.
PN87
Similarly again for Penrith?---Yes, that's correct.
PN88
Now if we just go back to Blacktown for a moment and look at the hours for those dedicated sales people, it would appear that there is a significant overlap between shifts across people through the course of the day?---Yes.
PN89
Between the team leader and the four sales officers. So is it that at any particular time of anyone on that shift, any one of those five people during their shift could be called upon to do a CountryLink sales?---Yes, that's correct, as long as they've had the training.
PN90
As long as they've had the training. In terms of looking at the classifications and the dedicated sales person, I understand that there is a sales volume requirement to move - to give a station a dedicated sales person, is that right?---That's correct.
PN91
And that number is?---400,000.
PN92
So if a station sells more than 400,000 tickets in a year, and I take it that's tickets through the booking office as well as the automatic ticket machines?---That's correct.
PN93
Then they qualify for a sales persons?---That's correct.
PN94
Could I just show you another document - - -
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN95
THE COMMISSIONER: 400,000 tickets per year?
PN96
MR WOODS: Per year.
PN97
I am just showing to you a document which ignoring the fax header has a handwritten heading, "Ticket Issues" and it is on the left hand corner, partly obliterated becomes the issues and 2000/2001 and on the right hand "Passenger Journey's 2000/2001". Now I understand that document is for the financial year July to June 2000/2001?---That's correct.
PN98
It has three columns identifying by station the number of issues which is ticket sales, actual tickets?---That's correct.
PN99
The revenue generated by those sales and there is another number dealing with journeys?---Passenger journeys. That's correct.
PN100
Could I tender that.
PN101
PN102
MR WOODS: If we go down to number 62 which is Stanmore in the left hand column, it has 411,874 ticket sales for that year. Beneath that 63, Punchbowl, is 396,706. Now if you applied a strict allocation that is the point at which you might get a sales person or lose a sales person?---That's correct.
PN103
Being in the year 2000/2001 this would have covered the Olympic period as well?---That's correct.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN104
Are you able to say whether that was one of your busiest periods?---Yes, undoubtedly, our busiest period, very successful.
PN105
Now there is also attached to your affidavit is a copy of a report which commences at page 49 where the author is Jade Novakovic of S Das & Associates dated April 2002, do you have that document?---Yes.
PN106
Can I take you to page 5 of that document - - -
PN107
THE COMMISSIONER: What page is in SRA2?
PN108
MR WOODS: It should be page 49 in the top right-hand corner of the cover page of that and then I'm going to go to page 53 which on my copy on the top right-hand corner the number is obliterated but it also has the number 5 in the top right-hand corner.
PN109
It's a table, second page of the table, do you have that?---Yes.
PN110
Now, if you just work across those headings, I think that that identifies the different types of sales persons whose activities were reviewed for the purpose of this report, is that right?---That's correct, yes.
PN111
And we have going across from left to right, someone who had no CountryLink sales, a CSA2 who did sales manually for CountryLink and then a salesperson with phone manual sales, phone and fax and then TravelLink CL sales in the third-last column going across the page. Now, I take it is that a person having a computer, access to a computer?---Yes, it is.
PN112
You see there in the CountryLink component of this position there's an average of 32 per cent per day?---Yes.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN113
Do you have a view in relation to this sort of salesperson and that number?---I do find that extremely excessive.
PN114
Why is that?---Just based on experience and knowledge. The majority of sales in CityRail stations are actually CityRail tickets, I would say that it would be 4 to 5 per cent would be the normal CountryLink sales through a reservations terminal, the TravelLink computer.
PN115
So again, if we went back to our example before looking at Blacktown where we had some five people who during the course of the day were responsible for sales, have you got that, the resource document?---Yes. I know the document.
PN116
So in terms of saying 4 or 5 per cent of sales being CountryLink sales would you expect that to be a rough estimate for the whole of Blacktown Station or per sales officer?---That would be for the whole of the station.
PN117
For the whole of the station?---That's correct.
PN118
So that in this instance would be spread across these five people?---That's correct.
PN119
During the course of a day?---That's correct.
PN120
If I take you back to the document which had the ticket issues identified I'd look at item 11 in that left-hand column and we see Blacktown appearing with 1,492,197 sales?---Yes.
**** GEOFFREY BRUCE FRANCIS XN MR WOODS
PN121
Are you in any way able to estimate what the sales would be for an individual sales officer from those figures or it is mathematically not possible at the moment?---It's very hard to determine because that figures takes into consideration I think it's either four or five ticket vending machines and those five, at any point in time I think there's three windows at Blacktown Station, so it's broken up into - that figure incorporates ticket vending machines and the individual sales in those individual windows, so it's very hard to determine.
PN122
I think, sorry to take you back again to that resource document for Blacktown, for Blacktown it lists over two pages, I think there's a note at the bottom which also has issues, journeys and revenue figures, do you know what year those figures relate to?---They were the chop and work re-design 1999, 1998/99, 1998, yes, sorry.
PN123
Can I get you to go to page 70 of your affidavit which is annexure JBF7 again, on my copy the zero of the 70 is obliterated but it's a document that lists out various positions and salary rates. Now, correct me if I'm wrong, I take it that these are rates of pay with industry allowance but prior to the current enterprise agreement taking effect, is that right?---That's right, yes.
PN124
That took effect in November?---Yes.
PN125
Nothing further, Commissioner.
PN126
THE COMMISSIONER: Mr Panigiris?
PN127
PN128
MR PANIGIRIS: Mr Francis, you say that you are a Station Manager approximately what, 10, 12 years ago, is that correct?---Yes.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN129
What station was that you were the Station Manager at, Mr Francis?---I've worked various locations, I was permanent at Rhodes for approximately 12/18 months but prior to that at Martin Place and as relief filling in actually at the majority of the CityRail stations there is a Relief Duty Manager or Assistant Station Manager and Station Manager.
PN130
have you ever used the CountryLink Travel Reservation system yourself?---I've utilised a system that's not the TravelLink as such but an IRT terminal.
PN131
That's the previous system to this one?---Yes, I must say quite a long time ago.
PN132
You understand the complexities associated with the current system?---Yes.
PN133
You have knowledge of the complexities associated with this current system?---Yes.
PN134
You would also acknowledge that in relation to those complexities the Authority in its wisdom recognised those complexities by improving the training course from a 3-day course to a 5-day course?---That's correct.
PN135
You accept that?---Yes.
PN136
You also accept, Mr Francis, that the RTBU in pursuing its claim for an allowance for its membership is really only looking at some 19 or 20 locations within the system?---Yes.
PN137
You understand why we are doing that?---Well, yes, I can understand why.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN138
You understand that those 19, 20 locations pursuing that allowance is aware there is a CountryLink TravelLink reservation system in place?---That's correct.
PN139
Why do we have those CountryLink TravelLink systems in place at those locations, Mr Francis?---Because they are identified as high volume locations.
PN140
High volume?---That's correct.
PN141
Would you agree that we generate, I say we, StateRail generates from the CityRail network somewhere between 6 and $7 million a year in CountryLink sales?---Yes, it would be approximately right.
PN142
That is generated from these locations?---Yes.
PN143
Utilising that particular system?---Yes, I think the 6 or 7 million would probably be pretty much to an overall total.
PN144
Now, Mr Francis, you would also agree that when you talk about the statistics in relation to five staff at, say Blacktown Station, selling CountryLink products, you know as well as I do that that doesn't happen. You only have one travelling system there and only one person can operate the system at any give time. Is that right?---That's correct.
PN145
So, you would not have five people at any given time operating that system. You are talking about one individual - - -?---No, it is five people are qualified to operate the system. Only one person can operate it at one time.
PN146
Are five people qualified at Blacktown, do you know?---Personally I haven't got their records in front of me but I would say yes they would be.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN147
So they would all be qualified?
PN148
And in your submissions and I take you back to State Rail exhibit number 3 where you were provided with the City Rail Stations job and work redesign staffing levels for Seven Hills, Blacktown, Campbelltown and Penrith. Would you acknowledge that when those resource plans were put in place State Rail did not recognise the sale of CountryLink tickets as part of the overall staffing?---No, I'm sorry I don't accept that.
PN149
Sorry?---I don't accept that.
PN150
You don't accept that?---No. I believe that the CountryLink component was taken into consideration through the job and work redesign process. Through the- - -
PN151
So, you say that recognition was given to the sale of the CountryLink tickets- - -?---Yes.
PN152
- - - during the job and work redesign process?---That's correct and the competencies required to sell the tickets.
PN153
Can I take you, Mr Francis, to the Jade Novakavic, S Dass report, in particular to the recommendations of that report which can be found on page 68. In that report in recommendation 5 says:
PN154
CountryLink transactions be acknowledged in staff reviews.
PN155
?---Sorry, where?
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN156
It would be page, the recommendations commence on page 68. I am referring to page 69, recommendation five?---Okay, yes.
PN157
That "CountryLink transactions be acknowledged in staff reviews". Why would the independent consultant make that recommendation, Mr Francis?---Possibly because she is not aware of our staff review process.
PN158
You're saying that when you staff review stations you consider CountryLink sales?---That's correct.
PN159
Why did she say in her recommendation in recommendation 9 that:
PN160
The sales persons position description specify competency in travelling computer systems as an essential requirement?
PN161
?---I would say because she wanted to emphasise the use of it. Maybe it is not emphasised enough in the position description.
PN162
So, you are saying that in the current job description it is emphasised but she wanted to put more emphasis on that?---Yes.
PN163
If I were to tell you that it does not appear in the current job description what would you say to that, Mr Francis?---I would say I would disagree. It is in the competencies for the position description.
PN164
You say it is in the competencies. I am saying in the job description that is advertised through your job opportunity booklet. If I say to you that it is not in there what do you say about that?---I am not aware of the position description but the job description is in more detail and it lists all the skills, essential qualifications and requirements for the position.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN165
So, you say that it is in the competency structure, it is for sales persons?---That's correct.
PN166
Where do I find the competency structure for a sales person specifically relating to the sale of CountryLink tickets?---It is on page - sales persons' role statement, I think it is page 38. The computer equipment is competency 1.28.
PN167
Access, retrieve, net, computer data use and keyboard skills. Practice and - - -
PN168
So, you say where one operates a computer is the recognition?---Yes. 182 which is:
PN169
Sell products and services.
PN170
So, where one sells a ticket that is exactly the same as a CountryLink sale, is that what you are saying?---No. Could I just finish. I will highlight the competencies. Competency 601 which is:
PN171
Sell tickets and products for products and services.
PN172
602 is:
PN173
Use technical equipment to provide customer services.
PN174
That in turn incorporates - there is a few computer competencies within the position description. 603, which is, sorry - 603 is through the ticketing barriers. 606 in particular is:
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN175
Advise customers on local destinations, product services and facilities.
PN176
607:
PN177
Advise customers on organisational destinations products, services and facilities.
PN178
608 which is:
PN179
Advise customers on Australian destinations, products, services and facilities.
PN180
And 613 which is:
PN181
Organise bookings and reservations.
PN182
And 614 which is:
PN183
Administer Australian bookings and reservations.
PN184
I think there is a few other minor ones there as well but they are the ones that refer to the reservations and products and services for CountryLink.
PN185
In relation to the processing of a CountryLink product or a CountryLink ticket through the travelling system, how much time would that actually take, Mr Francis, in comparison to a straight City Rail point to point sale?---It takes longer obviously. It can take, depending on the reservation. The reservation if it is a simple reservation to say Canberra or Tamworth. It can, you know, take anywhere between five and 15 minutes, I'd say. I'm just making a, what I think is an educated guess or maybe a bit longer if you are going to Perth via Melbourne or on the Ghan with different products and services.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN186
Would you accept the report's content on page 62 where it is identified that a sale of a City Rail ticket works at eight seconds per sale versus a sale of a CountryLink ticket at 2.5 minutes?---I would say it's close, yes.
PN187
You would accept that?---I would accept that.
PN188
So, you would accept that in most cases where these transactions occur it takes a much longer period for that to occur. Is that right?---Yes. Yes.
PN189
Why do you say that is the case?---CountryLink sales are obviously - as I just say they vary from location to location. They can be Sydney, Melbourne, Perth or to Adelaide or, you know, they could be to Newcastle or Canberra.
PN190
Would you accept the fact that they are more complex?---Yes.
PN191
You would. And would you accept the fact in order to undertake that task you need to have greater knowledge?---Yes.
PN192
Yes. Do you also accept the fact that when you are selling CountryLink tickets you could also be selling City Rail tickets at the same time?---Yes, you could.
PN193
And that doesn't occur right across the system, does it?---It can.
PN194
Well, it can't, can it, there is only 20 locations with CountryLink systems?---A place like - yes it can, where they can issue CountryLink and City Rail tickets at the same time. It is possible.
PN195
There is only 20 locations where you have got this computer system?---That's correct.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN196
Where you have an individual selling tickets through that computer system and selling tickets at the same time so it would only happen at 20 locations?---It could only happen, yes.
PN197
Well it would only happen at 20 locations because you haven't got any more than that, have you?---That's correct, that's right.
PN198
So, you have got another what, 300 odd locations where you do straight sales through the window but at 20 locations where you can do both ticket sales through this system and also sell City Rail products at the same time?---That's correct.
PN199
Now, Mr Francis, there are CountryLink sales on two fronts at City Rail stations. You can do them manually via the phone and ring the Central Reservation System?---Yes.
PN200
Or of course you can do it through the 20 locations through the CountryLink system. Can you explain to the Commission the difference in responsibilities where an individual employee makes the reservation via phone to the Central Reservation System versus the responsibilities where an individual employee makes that transaction on the CountryLink reservation system at that location?---The person who makes it on the phone gets the details off the customer whether - sometimes the customer may ring reservations, Central Reservations first, they will pass on their requirements, travel requirements. They can do that over the telephone and CountryLink reservations will give them, like a reference number. They then come down to the local railway station and quote the reference number and if required they will either fill out a ticket or have a ticket sent through to them via CountryLink or they can do the reservation entirely over the telephone where they will come down, they will get the details from our staff, you know, the train number, their requirements for the reservation. They in turn will then ring reservations who will give them the details of the reservation.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN201
In relation to an error being made by an employee who makes that arrangement through the central reservation system where does the responsibility lie there?---With whoever makes the error.
PN202
That's right, that's with the central reservation system, isn't it?---Mm.
PN203
But if you make an error through one of these twenty locations you as a sales person are held responsible, are you not?---Yes.
PN204
So there's a very clear difference between levels of responsibility. If you sell a CountryLink ticket by phone the level of responsibility normally lies through the central reservation area. If you sell a ticket through the reservation system at those twenty locations the responsibility lies wholly and solely with the sales person that makes that sale, am I right in saying that?---That's correct.
PN205
So you acknowledge there's a level of responsibility between the two?---Yes.
PN206
And there's a greater level for those people who actually sell the tickets through the CountryLink reservation system at those CityRail stations?---That's correct.
PN207
Mr Francis, there was also a second report commissioned by State Rail and there was a joint CityRail report and you will find that commencement of your affidavit at page 71?---Yes.
PN208
There's a recommendation made in the summary and it says this:
PN209
We would suggest a sales person who sells City Rail products exclusively ...(reads)... requirement of additional skills.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN210
Can I ask you this Mr Francis, do you support the findings of that particular working party?---Yes.
PN211
You do, so you acknowledge that there are clearly complexities associated with the competencies associated with the workings of the TravelLink system at those twenty locations?---Yes.
PN212
Mr Francis, are you familiar with the Culligan & Dell process at all?---I am familiar with it but I'm not an expert on how it's applied.
PN213
Do you know when the Culligan & Dell system was first introduced in State Rail?---No, not, I'm sure I've got the written documentation here, I think it was in the early 90s but not off hand I can't.
PN214
And that's one of a number of systems that State Rail uses to evaluate positions, is that right?---Yes.
PN215
Now in relation to station operations, the unions and management were involved in a fairly comprehensive restructuring of the station operations area?---Yes.
PN216
Which led to the job and work re-design process, do you agree with that?---That's correct yes.
PN217
There was an agreement reached that in this Commission 1998 which identified a classification structure for station operations?---Yes.
PN218
We also had an agreement Mr Francis that the sales persons or booking clerks as they were known then be taken out of the clerical admin stream and be placed into the station operations structure, is that correct?---That's correct from my knowledge, yes.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN219
Why did you do that Mr Francis?---I'm not quite sure, I don't know.
PN220
You're not quite sure?---No, I know it was part of negotiations.
PN221
Did we not agree at the time Mr Francis that to restructure station operations and on that basis we would create an autonomous classification structure for that area and that was the reason why we took the clerks or the booking clerks at the time out of the clerical admin and put them into the classification structure of stations?---That's correct.
PN222
Now, Mr Francis, would you agree with me that during that process we developed a number of evaluation systems, we had one for station managers and we called that the OCR process, is that right?---Yes.
PN223
And we still use that today successfully as I understand?---Yes that's correct.
PN224
In relation to the wages classifications we developed a competency based structure?---We actually developed the competency based structure for all station positions and the station positions including the station manager, duty manager, were evaluated under the CED system including the sales position.
PN225
Well how can you say that, we are currently evaluating and in fact only four or five weeks ago we upgraded some 127 station manager's positions under the OCR evaluation system, is that right?---That's correct.
PN226
We didn't apply Culligan & Dell?---No, Culligan & Dell assessed the OCR, when we did job and work redesign we went to a competency based structure, we had working parties with the ASU, RBTU and management and we developed these position descriptions. These position descriptions were then evaluated utilising CED to give the worth of each of the positions and then OCR actually fits in the different levels within station manager grades which as you know of from levels 1 to 7.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN227
So, you're saying that we had a Culligan & Dell process which bench marked the positions initially, then we allowed OCR to take over from there?---No, OCR, as I say Culligan & Dell evaluated the position descriptions, facilitated the position, the rail status position descriptions assisted us in developing them and then OCR actually fits in, OCR as you know is a system which allocates points for different functions and it fits in the overall station manager roles.
PN228
As I understand the current OCR system is designed to facilitate progression of a classification structure that hasn't existed since 1998. In your own affidavit you present a document to the Commission on page 12 which talks about a clerical admin structure ranging from clerk grade 1 to senior officer class 10. This structure in itself has not operated since 1998/1999 max and I'm sure you're aware of that. In particular for the salespersons they were actually taken out of the structure and they were placed in a separate stream within the station operations area?---That's correct.
PN229
You say in your affidavit Mr Francis that there's a number of points allocated per classification, how would those points apply to a current salesperson's position?---Sorry, I don't understand what you're saying.
PN230
Well how would these points that you say in the band where you have the lower and upper margin, how would those points apply to a current salesperson?---As I say I'm not an expert on how the CED system works but I know the position was evaluated utilising the CED and where it currently is on the - - -
PN231
But you see Mr Francis a salesperson falls - the new classification structure of a COA2 and it's between a DE, now if I take that to the extremities that would be somewhere in the vicinity of 155 to 160 points which is a clerk grade 6. The documentation presented to this Commission talks about recognition that the sale of Country Link tickets has the additional complexities for we can't identify exactly what those complexities are worth and I just don't understand, and maybe you can explain to us how you can apply the Culligan & Dell system to a salesperson's classification?---Well all I can say is that the position
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
description of the salesperson was evaluated for points under the CED system and they were allocated those points and came up with that relative pay rate. So as you quite rightly pointed out they're not in the clerk 1 to special grade, they're in the station operations.
PN232
That's right and I'm just finding it somewhat difficult to understand how an assessment could be made by you independent consultants under the Culligan & Dell process when we can't see at least in the documentation you've presented where a salesperson would fall within the new classification structure for station operations?---I think the points were allocated through Jade Novalcavic, she evaluated it for points under CED and I think their nets evaluated it for points under CED and it fits where it currently is in the same position.
PN233
In Mr Etcell's correspondence which is on page 74 he talks about 106 to 160 points as a COA2 but you and I agree they are not COA2s they are sales persons?---That's correct.
PN234
So on what basis did those sales persons get evaluated? Not as clerks surely?---Well, as I say I'm not an expert on the evaluation system and what a COA2 relates to into the classification of clerk positions as you've pointed out, I can't answer.
PN235
But you're not saying are you a booking clerk is the same as a clerk - - -?---Yes, as you say we don't have booking clerks any more.
PN236
I know that but you're suggesting that a person who sells tickets on a station, a sales person, would be the same as a clerical admin officer?---A clerical and admin officer?
PN237
Yes?---No.
PN238
Different altogether aren't they?---Different, yes.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN239
Different responsibilities?---That's correct.
PN240
Different environment?---Yes.
PN241
However, you don't cater for those people within your Culligan & Dell classification structure?---As I say I'm not an expert on C&D so all I can say is the position was evaluated and it showed no movement from - - -
PN242
The point I am trying to make, Mr Francis, is you say in your affidavit that's the system that was used; I am just finding it somewhat difficult to locate a sales person in that system and you do acknowledge that we did create a new classification stream for sales persons station staff in 1998?---That's correct, yes.
PN243
As you're aware, Mr Francis, the RTBU is seeking an allowance for sales persons that are involved in the sale of the tickets at those 20 locations and I understand that there are some concerns about State Rail in relation to the expansion of that allowance in the City Rail network. We have given you a very clear and precise undertaking that the allowance would only be limited to those 20 locations and those individuals identified in using that particular reservation system. Why would you think that the RTBU would be seeking to expand that claim outside that area?---I don't know.
PN244
You don't know? Was it not part of the concern of City Rail operations in relation to our request to have an allowance that we would expand it beyond those 20 locations?---That's distinctly possible, yes.
PN245
But you don't have a view about that?---The organisation's view is that it's currently within the competency and position description of the current position and no allowance should be paid.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN246
Could you explain to us, Mr Francis, how you would think we might expand the claim?---I don't know, I'm not - - -
PN247
THE COMMISSIONER: While we're just paused there for a minute, Mr Panigiris.
PN248
Mr Francis, the staff that are in the different locations, that's staff that are in the twin locations that have this system and other staff in different locations that don't have the system, are they all paid the same money?---Yes, they are.
PN249
So what you're saying is that they all have the same job description and you say to me that job description accommodates the competencies required - - -?---Yes, that's right.
PN250
- - - to operate the - and I must ask people what's the difference between TravelLink reservation and CountryLink reservation as the parties use that term interchangeably and it's - - -?---It's the one think, it is CountryLink.
PN251
So if I use either one it doesn't matter? Everybody knows?---Yes, CountryLink is the brand.
PN252
I was wondering whether it was some sort of work process in the system as well but, anyhow, apart from that terminology is interchangeable. Now, the staff at this level all receive the same money?---Ye.s
PN253
They all have the same job description?---Yes.
PN254
You say that their job description accommodates work on the CountryLink or TravelLink reservation system?---Yes.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN255
Yet it appears to me from your evidence under cross by Mr Panigiris that there is a higher skill level required?---That's correct.
PN256
There is a higher level of accountability and responsibility?---Yes.
PN257
And there is extra training?---That's correct.
PN258
How come they're on the same - - -?---Well, so they all fell - - -
PN259
I'm not saying that warrants another classification but - - -?---No, I appreciate that but whilst, yes, there's more accountability, more responsibility. At the other locations they still do the same thing but they do it through a different means. They use a telephone or, you know, and that can be more cumbersome than utilising the TravelLink system itself. See, they all perform - - -
PN260
But that's not work value, cumbersome or more work?---No.
PN261
More work or cumbersome is not work value principles?---It's just a different way of doing it.
PN262
Yes, but there's a higher level of responsibility if you're selling person to person so to speak as opposed to over the phone link?---Yes, but as I say it's more cumbersome, it's difficult but at these higher volume locations the TravelLink system is put in to make that task actually easier and because they're doing it over a longer period of time they can - - -
PN263
They still need a higher skill level though. I don't think that's been disputed?---Yes, that's right.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN264
Thank you, Mr Francis, for that.
PN265
MR PANIGIRIS: Just on that, Commissioner.
PN266
Mr Francis, you did indicate in your evidence earlier that in relation to the accountability of people selling tickets directly through the central reservation system the onus of responsibility for that falls in almost all the cases to the operator in central reservations not with the sales person; is that right?---It varies. Through different means it varies.
PN267
In what sense?---Well, if the City Rail employee writes out the ticket he's generally quoted that price from the reservation centre so he may be quoted the right amount but write down the wrong amount so - - -
PN268
Yes, but that's a general error but in relation to the actual responsibility you pick up a phone, you ring up central reservations, you indicate what the customer wants, the booking is done for you by central reservations, they do all that work for you, they quote you a price, sure if you write it down wrongly you cop the rap for that but generally you don't, X amount of dollars, you collect that or the person comes back and collects the ticket but if you do it through the TravelLink system it's totally different isn't it?---The TravelLink system actually tells you what the fare is and what it is to charge - - -
PN269
Exactly right and you make the reservation don't you and it's done?---Yes, and it will tell you what the fare is.
PN270
Exactly right and you do acknowledge that difference?---And you collect that fare.
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN271
I've asked you this question before Mr Francis I just want to ensure that we have the answer right in relation to CountryLink sales at those 20 locations. You do acknowledge that whilst they're principally CityRail stations and the requirement is to principally sell CityRail tickets. That whilst they are selling or at least providing a service through the CountryLink reservation system, they are at the same time selling CityRail tickets and that is part of their overall function and you do acknowledge that that is an additional responsibility?---They can do that, that's correct.
PN272
Can or do?---Well they can and depending - Blacktown for example they've got three windows so one window can been linked to CountryLink only products whilst somebody is making a reservation.
PN273
What happens when there are queues at Blacktown?---Well we have ticket sellers there - - -
PN274
You don't close the window down do you?---No, we don't, as I say we have three windows at Blacktown to cater for the volume of people.
PN275
If you take a location like Eastwood for arguments sake, there is only on window there isn't there?---No, there are two windows at Eastwood.
PN276
There are time Mr Francis at Eastwood when there is only one window?---There's actually three windows at Eastwood unless closed - - -
PN277
I understand there are three windows but there are time when there is only one window in operation?---There are times when there is one window in operation that's correct.
PN278
What happens when there is one window in operation?---And somebody wants to make a CountryLink reservation?
**** GEOFFREY BRUCE FRANCIS XXN MR PANIGIRIS
PN279
Correct?---Well a number of things can happen, there are other qualified staff that can sell CityRail tickets while he does that or if depending on the time of day, it might be might be 10 or 11 o'clock where it can easily, the volume of traffic, the person can easily sell CountryLink and CityRail tickets.
PN280
You do acknowledge Mr Francis where there is one window open and subject to staff availability, that employee could clearly be doing two things at once?---He can be, yes.
PN281
I have no further questions, Commissioner.
PN282
PN283
MR WOODS: Commissioner, could I first of all apologise I had meant to tender one other document through Mr Francis. It links into the evidence that included Mr Edsell's letter that is attached, it is actually the position description that was provided for the evaluation that Mr Edsell had done. I will just show Mr Francis.
PN284
THE COMMISSIONER: It has been adduced, does that raise any issues with you.
PN285
MR PANIGIRIS: I am just going to have a quick look at that.
PN286
MR WOODS: If there is anything arising from that, I certainly don't have any objection to Mr Panigiris asking any questions about that document.
PN287
MR PANIGIRIS: Commissioner in relation to the statement, we have some issue in relation to it, the last job advert we saw through the authority's career opportunity booklet it made no mention at all about the sale of CountryLink tickets.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN288
THE COMMISSIONER: Where are you looking at on this document which I haven't taken as yet?
PN289
MR PANIGIRIS: I am looking at page 1, it talks about the primary objectives as both CityRail and CountryLink and it says that right through the document, stations sales operations. Personally, we're not aware of this document, more important, the position is advertised for the purpose of individuals seeking promotion to it. The issue of a person being qualified in the sale of CountryLink tickets does not appear an essential or desirable qualification. I am just somewhat surprised that it appears in this role statement.
PN290
THE COMMISSIONER: Is it in any of the material that is in Mr Francis' statement? I must say I read the statement most definitely and looked at the attachments and I didn't see any specific reference to TravelLink or CountryLink function so to speak.
PN291
MR PANIGIRIS: In our submissions to you if you go into the document at page 6 and 7 - - -
PN292
THE COMMISSIONER: Of the RTBU material?
PN293
MR PANIGIRIS: Yes. We have there a Hornsby position, a Mt Druitt position.
PN294
THE COMMISSIONER: That is what I have been looking at, yes. And job ads as well.
PN295
MR PANIGIRIS: I mean we are talking about a place like Hornsby which are fairly significant locations, Mt Druitt and there is nothing there about CountryLink sales?---That's correct. There is nothing there about CityRail sales either. It doesn't get specific about - - -
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN296
THE COMMISSIONER: No no, Mr Francis, this is not a discussion that you gentlemen are having. You are not in a meeting you are in my hearing room. Well what do we do with this Mr Panagiris?
PN297
MR PANIGIRIS: In relation to the documentation Commissioner, we would say to you that whilst there is a document there that's been tabled as a role statement, that does not in my view specify the requirements of sales person on CityRail stations because clearly when someone applies for a position on CityRail stations, they rely on the job advertisement, they are not presented with this documentation. As part of their application they rely purely on that component in the information booklet.
PN298
THE COMMISSIONER: Well I don't even know that that is the point is it? I mean I was remiss in not asking both you and Mr Woods actually at the beginning of this to outline what I have to decide. This is a recommendation by consent 111AA and I don't know - I know there's a claim, I know the claim is for an allowance. I don't know - number 1 I don't believe that State Rail actually gave me submissions, they gave me witness statements and they referred me to an enterprise agreement with no extra claims.
PN299
They told me that the issues were precoded tickets and CountryLink ticketing. They told me that CountryLink tickets fall squarely within the scope of the position and they talk about evaluation. I don't even know if it is a submission. It is only a page and half covering letter to two statements but nowhere in that does it tell me exactly what they're saying so I don't know if anybody wants to tell me what the position is.
PN300
Apart from that gentlemen which you will have to tell me in a moment I suppose whether or not the CityRail or the CountryLink is necessarily part of - it is evidently in one role statement which Mr Woods is attempting to tender now which was amended in August 2002. It's not in the role statements of the material that the union have tendered but at the end of the day whether this role statement attaches to CityRail or CountryLink, is it necessarily completely relevant to me when I think, Mr Francis has said that all these people are on the
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
same rate of pay however, if you operate the CountryLink or TravelLink there is a level and I don't know that level, there is a level, well, a high school level, a higher training level, a higher complexity level and a higher accountability responsible, responsibility level. So, I don't know whether StateRail acknowledge that an allowance should be paid, well, they don't because nobody has told me.
PN301
So, going back tot he tendering of this document that Mr Woods is seeking to put in front of me, how much weight do I place on it to answer the question that somebody will tell me that I have to answer in a moment?
PN302
MR WOODS: Perhaps I might assist, Commissioner, in terms of - - -
PN303
THE COMMISSIONER: I wish somebody would, Mr Woods, it's getting a bit cloudy up here.
PN304
MR WOODS: I'm sorry about that, Commissioner. First of all, in respect of the big picture in respect of the allowance - - -
PN305
THE COMMISSIONER: First off, we've got a witness in the box, so if you are going to give me your positions, then maybe we should dispense with the witness and this document and then you can tell me what your positions are but go ahead.
PN306
MR WOODS: I'm content with either course, to either deal with that or to deal with the document now while the witness is still in the box and I do have some other questions which I would seek to put arising out of the cross-examination, so I could come back to the bigger picture, if you like, at the conclusion of the witness. In respect of the particular document, it flows out of the DAS evaluation and the subsequent joint review and - - -
PN307
THE COMMISSIONER: DAS evaluation, that's the consultant?
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN308
MR WOODS: Yes, the Jade and Navakovic Report from S. DAS and Associates. As a result of that, as Mr Francis was examined, there was the joint review and report by StateRail and the RTBU which identified issues that suggested that there be consideration given to these positions. In Mr Francis' affidavit there is at page 74 an evaluation report from Ian Etsel from StateRail which Mr Francis has been cross-examined about.
PN309
This particular document which is covered by a letter to Mr Panigiris from StateRail dated 23 August is the role statement that was prepared following that joint review which followed the report by Ms Nanakovic and included the references to CityRail and CountryLink and they for convenience have been put in bold and appearing on pages 1 and 2 of the statements. Then in the competencies and the last page of the document, three competencies found or described in the joint review have been included.
PN310
For the purpose of the evidence, it is that role statement which was evaluated by Mr Etsel and resulted in his report, so chronologically - - -
PN311
THE COMMISSIONER: Who is Mr - he is an employee of StateRail?
PN312
MR WOODS: Yes, he's from the Human Resources Department of StateRail and is a person who is qualified to conduct the CED point evaluation. So, in terms of the document which I seek to tender, it fits into the chronology of what has occurred in the examination of the role undertaken by the sales staff in respect of the CountryLink TravelLink sales and it's the - - -
PN313
THE COMMISSIONER: When did this system first come in, Mr Woods?
PN314
MR PANIGIRIS: The beginning of 199 - - -
PN315
THE COMMISSIONER: So, it's operation for two years?
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN316
MR PANIGIRIS: Yes.
PN317
THE COMMISSIONER: But during that course I imagine - - -
PN318
MR PANIGIRIS: I'm talking about the CED system, two years,
PN319
MR WOODS: Yes, that's right.
PN320
THE COMMISSIONER: So, the TRS, for want of a better name, commenced operation about two year's ago.
PN321
MR WOODS: Prior to that there was an earlier system that was operated and as Mr Francis has described, it operated an earlier version of an on line system but the current CountryLink on line booking system from CityRail stations came into operation some two years ago but they had been doing a form of sales on line or assisted line previously.
PN322
THE COMMISSIONER: All right, well, what are we going to do with this document?
PN323
MR WOODS: So, in terms of the tender, I would submit it on the basis of assisting in the chronology and giving the document that was evaluated by Mr Etsel in his review and in his memo of 9 October 2002 about which Mr Francis has been examined. Now, I understand from Mr Panigiris' cross-examination that he has a view in relation to the Cull and Egan Del System and that no doubt is a matter which will be explored in due course but it forms a part in explaining what has been done by StateRail in considering this issue.
PN324
THE COMMISSIONER: All right, do we object, Mr Panigiris, to the - - - ?
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN325
MR PANIGIRIS: Commissioner, no, in looking at the document if it's lodged on the basis that it is part of the process, we would have no objection.
PN326
PN327
THE COMMISSIONER: Mr Panigiris, any question that arise that you wish to put to Mr Francis?
PN328
MR PANIGIRIS: No, thank you, Commissioner.
PN329
THE COMMISSIONER: Yes, Mr Woods, when you are ready.
PN330
MR WOODS: Mr Francis, this as we've just explored in the discussion with the Commissioner, this current CountryLink on line booking system has been about two years in operation, is that right?---That's correct.
PN331
Within that time staff have been trained to be able to operate the system to make their bookings?---That's correct.
PN332
You were asked by Mr panigiris in respect of the responsibilities that are different from those using the on line system and those who do not, is it fair to say that a person having been trained operates the on line system has the customer in front of them and can discuss the confirmation of the booking?---Yes.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN333
And has the ticket to show to the customer at the time of issue to confirm that that is the booking arrangement that is required?---That's correct.
PN334
Is it the case within the computer system that having identified a particular journey on a particular day for a particular classification of customer, adult, pensioner, or whatever, that the computer system identifies what is the sale price?---That's correct.
PN335
Does that print out on the ticket?---Yes, that's correct.
PN336
So that it is not a matter for the sales staff person to look up a table or try to work out a price?---No, it's not.
PN337
Is it so that they go through the process of identifying where, when, what classification and the ticket is produced?---That's correct.
PN338
Now, you were asked some questions in relation to the existing job statement prior to the document we've just tendered following that review, and we've identified that staff, such as CSA2 staff, have a sales responsibility?---That's correct.
PN339
I think when we look at exhibit SRA3 which is the resource document we see for example that a CSA2 at Seven Hills station has a sales responsibility?---Yes.
PN340
But a CSA2 at Blacktown station does not have a sales responsibility?---That's correct.
PN341
But they are paid the same?---The same, that's correct.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN342
If the individual officer transferred from station to station they would take up the duties as at that location?---That's correct.
PN343
Is it fair to say that between different stations there's different volume of traffic, of passengers?---That's correct.
PN344
As a result people who are paid the same grade at different stations have to exercise different duties?---Vastly different duties, that's correct.
PN345
But within their own competency and their job statement?---That's correct.
PN346
That in some places some people can be busier than in others?---That's correct.
PN347
Now, you were asked some questions in relation to the operation of the Culligan and Dell system and the OCR system?---Yes.
PN348
As identified?---Yes.
PN349
I accept that you've identified that you are not an expert in relation to the Culligan and Dell system?---Correct.
PN350
But is it within your knowledge that it is used as a bench marking system?---Yes.
PN351
To identify salary rates?---Yes.
PN352
What it does is look at a job statement, or position description?---Yes.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN353
And through the elements that I think are identified in the descriptors in the annexures at annexure 1 to your affidavit, which is pages 5 through to 11, reviews the activities, assesses the competencies required for those activities and allocates as a result a point system?---Yes.
PN354
It is your understanding that what State Rail has done is with the involvement of the unions established a grading rank compared to a points outcome, is that right?---Yes, that's so.
PN355
Then the salaries link into that grading rate?---That's correct.
PN356
You've agreed with Mr Panigiris that the sales person doesn't appear on the document that is at page 12 of your affidavit?---That's correct.
PN357
But is it still the case that the sales person has been evaluated to score CED points?---Yes.
PN358
It is based upon that CED points as a bench mark that a salary range is established based upon those points?---Yes.
PN359
Is the purpose of this for creating comparability across all classes of employees?---That's correct.
PN360
So that State Rail is trying to pay people with different competencies in very different jobs but the basic competency a similar pay rate?---That's correct.
PN361
So just as in that scale we don't see electricians?---No, that's true.
PN362
We don't see other station staff?---That is correct.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN363
Now, you were asked some questions in relation to the operation of staff at say Blacktown and selling two lots of tickets at the same time?---Yes.
PN364
The staff are responsible for serving a customer?---Correct.
PN365
That customer may be wanting to buy a City Rail ticket or a Countrylink ticket?---That's correct.
PN366
They serve that customer?---That's correct.
PN367
Within the sales staff at a particular time on duty at Blacktown and I think from the resource documentation there could be three or four sales staff at some different times during the day on duty?---Yes. That's correct.
PN368
One of them may sell no Countrylink tickets during the course of the day, one may sell several?---That's correct.
PN369
But it doesn't necessary just one person?---That's correct.
PN370
I think you were suggesting that if you established a Countrylink window then there might be one person on a shift who is selling predominantly Countrylink tickets?---Yes.
PN371
I guess that wouldn't exclude someone else from also selling a ticket?---That's correct.
PN372
Assuming the computer terminal is accessible?---That's correct.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN373
So that if there was an allowance in respect of all the staff on that day some would be receiving allowance but not actually making any sales?---That's correct.
PN374
Earlier on in your cross-examination you were asked by Mr Panigiris in respect of a figure for State Rail Countrylink sales of 6 to 7 million dollars?---That's correct.
PN375
Now, that's all of the Countrylink sales?---Yes, I believe that to be all of them, not just the 20 - I believe that's all Countrylink.
PN376
So it's not the figure from the 20 locations or from State Rail stations?---No, I believe that's entirely just from the whole make up of Countrylink sales right across the board.
PN377
They could be sales from anywhere in the state or anywhere at all?---That are sold by city rail stations not through travel centres.
PN378
THE COMMISSIONER: But only on the 20 locations?---No. The majority of our stations we have 307 of them and the majority of them can all sell Countrylink products.
PN379
I see what you mean. That's what we were talking about earlier by phone into a central reservations area, that's right, that's what we were talking about, no responsibility or what have you?---That's right.
PN380
MR WOODS: Just in terms of the issue of the responsibility, is it fair to say that it is a shared responsibility on that phone system between the sales officer dealing with the customer face to face and the central reservation sort of person?---Yes, yes. It's definitely a shared role.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN381
Either could make a mistake and be responsible for any mistake?---Correct. That's right.
PN382
THE COMMISSIONER: But who has ultimate responsibility if there is an error?---Whoever makes the mistake. If the - - -
PN383
But how do you know?---Well, a lot of time there's a dispute as to - and as I pointed out before the reservation centre may give the details of the fare but if the employee at the station doesn't apply it correctly well he will be responsible for any shortage and vice versa. If the person at the central reservation quotes the wrong fare to the station staff member well he will be responsible for that.
PN384
I see what you mean. If the correct fare is quoted - but how do you know that, is it a written quote or is it word of mouth?---Depends. On the IRT system it's actually on the system itself. On the printed ticket it's generally quoted from the Countrylink reservation centre itself. It varies.
PN385
THE COMMISSIONER: But when it's an individual at one of the 20 locations there's no shared responsibility.
PN386
MR PANIGIRIS: No, that's right, and the person at that location has the opportunity to talk through the sale with the customer to confirm that that's what exactly was required.
PN387
THE COMMISSIONER: Sorry gentlemen, can I just ask a question and it's not necessarily of the witness; do I have any other witnesses today?
PN388
MR PANIGIRIS: We have the RTBUs available witnesses.
PN389
THE COMMISSIONER: We had better move, gentlemen, I have a 4.30 dispute.
**** GEOFFREY BRUCE FRANCIS RXN MR WOODS
PN390
MR PANIGIRIS: I think that is all.
PN391
THE COMMISSIONER: Nothing further from Mr Francis at all?
PN392
MR WOODS: Not at this stage, Commissioner.
PN393
PN394
THE COMMISSIONER: Mr Woods, can I ask you please, this letter I received on 18 December which had the attached affidavits to it from your firm, do I take that to be the submission, the outline of what StateRail are saying in regards - - -
PN395
MR WOODS: It is the outline and perhaps it is very brief.
PN396
THE COMMISSIONER: No criticism but I just wanted to know because I'm just thinking I should mark it.
PN397
MR WOODS: Very well.
PN398
PN399
THE COMMISSIONER: So in just a very quick perusal of that I take it that in regards to the allowance State Rail are saying to me any increase in the skill, the requirements of the operation of this particular function in regards to TravelLink reservations system that it is so minimal that it doesn't warrant a salary incremental advancement nor does it warrant an allowance.
PN400
MR WOODS: That's correct.
PN401
THE COMMISSIONER: And I suppose in your submissions you'll take me to why I should have regard to clause 2.7 and 3.4 of the EBA and you're going to do that tonight?
PN402
MR WOODS: I can do that tonight.
PN403
THE COMMISSIONER: I don't think you'll be doing it on Monday, I think we have got to finish this aspect today. So that's that point. Mr Panigiris, you haven't filed any witness statements.
PN404
MR PANIGIRIS: I haven't but in our submission on page 5, Commissioner, we do indicate what our claim is in paragraph 2.
PN405
THE COMMISSIONER: I did read these submissions, Mr Panigiris, you are doubting me now, aren't you?
PN406
MR PANIGIRIS: Not at all.
PN407
THE COMMISSIONER: I did read them. So what you are seeking is, you say, the added complexity level of training, skill responsibility, warrants $1.50 per hour all purpose?
PN408
MR PANIGIRIS: That's correct.
PN409
THE COMMISSIONER: You say retrospective from 2 February and you give me a reason why, and I believe if my memory serves me correctly you also say that it should only apply to employees required to operate the system on a particular day or a particular time during that day?
PN410
MR PANIGIRIS: That's what we say. We've identified approximately 50 employees at approximately 20 locations - I'm not sure if it's 19 or 20 locations - there's 20 locations, Commissioner, and we put that to you on the basis that we do understand there were concerns from the employees in relation to this particular claim going across the network. We say that it can be contained, however we do say that in a number of locations it will not only apply to sales persons, but it will also apply to customer service attendants and possibly a duty manager or a station manager. So we would be looking at - - -
PN411
THE COMMISSIONER: That's one of the questions I was going to ask you. So really what you're saying is employees - - -
PN412
MR PANIGIRIS: Employees, yes, that's the purpose of the allowance and obviously we'll be saying for the full 8 hour shift in relation to that.
PN413
THE COMMISSIONER: So page 5 I can refer to when considering what your claim is?
PN414
MR PANIGIRIS: That's correct.
PN415
THE COMMISSIONER: The next question I have, first off for the union, but then Mr Woods will want to comment, will be required in a sense to comment. That's three questions, three issues that I had with the parties. The next one was this 111AA that you're seeking, Mr Panigiris, is you're successful first off in regards to a claim for an allowance regardless of what that amount may or may not be, what do you intend to do with it? Is the enterprise agreement to be varied? I don't know that this was raised or that I raised it, we didn't have 111AA; the last time I spoke to the parties I have 170LW which might have been a different kettle of fish but the thought crossed my mind.
PN416
MR PANIGIRIS: An all purpose allowance doesn't require the enterprise agreement to be varied, it could be done through a list of arrangements if we are so successful.
PN417
THE COMMISSIONER: All right; well I'll raise it with the parties so if it isn't a problem to you well so be it but, Mr Woods, do you have a view at all or do you want to seek instructions and perhaps advise me at another time?
PN418
MR WOODS: I'll confirm this, Commissioner, but I see it as sitting outside the arrangement as an extra in effect as something beyond the enterprise agreement as a consent arrangement.
PN419
THE COMMISSIONER: Because your enterprise agreement does talk about the parties will discuss blah, blah, blah, blah, remuneration in regards to technology but I didn't know whether the parties - - -
PN420
MR WOODS: Within clause 3.4 there would be the scope for the parties to agree on an allowance had they agreed on one.
PN421
THE COMMISSIONER: That's fine; I just raise it but if it isn't an issue that's okay. All right; where are we up to?
PN422
PN423
MR PANIGIRIS: Mr Richens, could you please state your full name and address for the Commission?---My full name is Roger James Michael Richens, my job description?
PN424
No, your address?---My address is 7 Bartlett Street, South Wentworthville.
PN425
Mr Richens, what is your current position within State Rail?---I'm a travel consultant at Sydney Travel Centre, I'm a CNA3E and officer.
PN426
Sorry, a C?---CNA3E.
PN427
What does that equate to in dollars?---An annual salary of $46,170.
PN428
Mr Richens, how long have you worked for State Rail?---Since 1979.
PN429
And have you also worked as a sales person or a booking clerk?---Yes, most of my 29 years in the railway has been involved working in booking offices and my current employment in the Sydney Travel Centre.
PN430
THE COMMISSIONER: How many years, I'm sorry?---29.
PN431
MR PANIGIRIS: You are currently required to operate the new TravelLink system in your current role?---Yes, I do that every day, day in day out.
PN432
And the bulk of your work, Mr Richens, is that relating to what we call third party sales or is it point to point sales in relation to CountryLink products?---We do a little bit of, we do a bit of third party and also point to point rail, probably an estimate would be 10 per cent third party and 90 per cent point to point rail.
**** ROGER JAMES MICHAEL RICHENS XN MR PANIGIRIS
PN433
one hundred per cent point to point, that's using a travelling system to sell rail products, that is a ticket from say Central to Broken Hill, Central to Newcastle, north or south - - -?---Not to Newcastle but Sydney to CountryLink destinations.
PN434
Is that the same sort of function that's required to be undertaken by CityRail station staff that have a travel link system?---It would be similar, yes, it would be the same.
PN435
Exactly the same?---Yes.
PN436
In relation to the new travel link system, I say new because it's only been there for two years, was it a much more complex system than the previous IRT system?---It has been, it is probably one of the most complicated systems I've used. When they initially brought it in there was a lot of teething problems with it, there still are some faults with it, especially ticket exchanges, re-bookings, re-issues, you've just got to be very careful what you do or else if you make a mistake you can lose money and you're responsible for the shortages.
PN437
And were you provided with additional training in relation to this particular system?---I actually went to the first training course which is a five day course, after that I commenced annual leave about a week after I did the training, when I came back from holidays there was a lot of things that were changed, I need an additional one day's refresher course.
PN438
So even though you were a travel consultant you were provided with a five day training course in relation to this new system?---Yes.
PN439
Now where you are at the moment in the Sydney Booking Office or Sydney Travel Centre, you're only required just to sell CountryLink products, is that right?---We do CountryLink products and also Greyhound coach line tickets, accommodation.
**** ROGER JAMES MICHAEL RICHENS XN MR PANIGIRIS
PN440
That's a third party?---Third party, yes.
PN441
Are you required to sell any CityRail tickets at all?---No.
PN442
You don't sell any CityRail tickets whatsoever?---We do, they co-ordinate a rail/coach service to Bathurst which is CityRail.
PN443
And that's only been recently terminated, Bathurst is now part of that CityRail network, prior to that it was part of CountryLink, wasn't it?---Bathurst was yes, it's only just changed I think in the last eighteen months or so.
PN444
No further questions.
PN445
PN446
MR WOODS: Mr Richens, you are required to be able to do third party transactions, aren't you?---Yes.
PN447
And you have additional responsibilities in doing that?---In doing third party?
PN448
Third party?---Yes, we're required to make sure if we book accommodation and coach tours everything is co-ordinated properly yes.
PN449
Have you ever seen, do you recall ever seeing a position description for your position?---Yes.
**** ROGER JAMES MICHAEL RICHENS XXN MR WOODS
PN450
Just have a look at that document for me, I want to see if you recognise it generally as a position description that you've seen before, it might be in a different format but I just want to see if it's that?---Yes.
PN451
That document sets out all the things that you are required to be able to do within your position as a travel consultant?---As a travel consultant.
PN452
And as you understand it it's based on those duties that you are paid your salary to be able to fulfil that position description?---Yes.
PN453
I would seek to tender that description, unfortunately I've only got one copy with me.
PN454
PN455
THE COMMISSIONER: Mr Woods, I will give that back to you but you want to ensure this afternoon that you get copies to the other side and myself.
PN456
MR WOODS: Nothing further.
PN457
THE COMMISSIONER: Thank you. Mr Panigiris, anything in re-examination?
PN458
MR PANIGIRIS: No, Commissioner.
**** ROGER JAMES MICHAEL RICHENS XXN MR WOODS
PN459
PN460
PN461
MR PANIGIRIS: Mr Astill, would you please state your full name and address for the Commission?---James William Astill, 14 Walter Street, Kingswood.
PN462
Mr Astill, what is your current classification within StateRail?---Salesperson competent.
PN463
THE COMMISSIONER: Sorry, salesperson?---Competent.
PN464
It's part of the classification, is it?---Yes, you've got to be competent to be a salesperson.
PN465
Well I would imagine you would have to be competent but I don't know - - -?---They have a salesperson in training and then they have a salesperson competent.
PN466
I think we might have to work on that, I think it will have to be 1 and 2, my apologies Mr Panigiris, I've just interrupted you.
PN467
MR PANIGIRIS: Mr Astill, how long have you been a salesperson?---Salesperson or how long have I been selling tickets? 36 years I've been employed as a booking clerk.
PN468
How long have you been a booking clerk and a salesperson?---36 years.
PN469
Obviously you must love your job?---I love interacting with people.
**** JAMES WILLIAM ASTILL XN MR ASTILL
PN470
Mr Astill, can you tell the Commission the difference between selling a CityRail ticket versus selling a CountryLink ticket through the travelling system?---A CityRail ticket is single to the city, yes thank you very much, there's your change and away you go. A CountryLink ticket is an approach by a customer who states, I wish to go from point A to point B, we'll make Penrith to Dubbo as an example, and I would say, "Yes madam, what day would you wish to travel". She will give me the date, I shall put Penrith to Dubbo in the computer, type in the date and I would ask the customer, "Do you have any concessions madam or are you the only one person travelling". She would say, "Yes I'm a pensioner or not". I shall then proceed to put the right allocation into the computer, I will then go through the whole process, put the cursor on to hold which will hold that seat that I've already allocated, I will then move the cursor across if that's the only place she's going to Dubbo, I shall put book and assign, I shall then go across and I would say, "You're not going any further madam, just the one seat, everything's under control", I would then press P&R which would take me back to another screen, I would then put in the details of the person's name, sex, phone number and I shall go to another screen which says document and I will press document and it will come up and it will say that the accommodation has been held and I will go and press next screen that says, P&R number and then you press ticket quote and then you press ticket and then the process goes and then you get the ticket out and hand it to the customer.
PN471
Mr Astill, how much training do you acquire to take on this additional skill?---I had five days training.
PN472
You had previously operated what they call the IRT system?---I had.
PN473
The comparisons between the old IRT system and new TravelLink system, how would you rate them as a long-standing sales cum booking clerk type person?---The degree of difficulty in the new system would probably be two thirds more difficult.
PN474
Two thirds?---Two thirds. It's a very complex system for someone that doesn't have computer knowledge.
**** JAMES WILLIAM ASTILL XN MR ASTILL
PN475
As far as the sale of those tickets through the TravelLink system would it be true to say that you would be held responsible for any errors made?---I am, yes.
PN476
You have been around the system for some considerable time; would that be right?---I have.
PN477
The other sale of CountryLink's tickets is through a phone type faxing system; is that right?---A phone system. There are two locations currently on City Rail stations that do have a faxing system but basically the phone.
PN478
In relation to the levels of responsibility in making errors and being accountable for funds between the phone/faxing type system versus the new TravelLink system who would be responsible in relation to the phone/faxing type system?---The originator of the booking.
PN479
Who is that?---CRCs.
PN480
Central reservations system?---Central reservation centre.
PN481
Now, as you are aware, Mr Astill, there are some 20-odd locations that have TravelLink computer reservation system?---Mm.
PN482
Those locations would you agree would be at the top of the list in relation to City Rail ticket sales?---Yes.
PN483
For the purpose of explanation when I say top of the list they sell quite a number of City Rail tickets?---Yes, they're only put in larger locations who have a high volume of customers, both City Rail and CountryLink although they're not put into underground stations.
**** JAMES WILLIAM ASTILL XN MR ASTILL
PN484
So where we have a location that not only sells a high level of City Rail tickets they are also at the top end in relation to the sale of CountryLink tickets through this reservation system?---They are.
PN485
So the responsibility is not just the sale of CountryLink tickets you've also got this high volume of City Rail tickets as well?---I do, yes.
PN486
Would it be fair to say that from time to time you're required to not only sell CountryLink tickets through your reservations system but you'd also be selling City Rail tickets?---It's expected from the City Rail customers that they don't miss their trains to work, etcetera, yes.
PN487
So you have to prioritise in relation to - - -?---I work for City Rail.
PN488
You work for City Rail but CountryLink may get second billing sometimes?---Second, yes.
PN489
There's been some conjecture in relation to the revenue taken from the 20 locations that have identified themselves as being CountryLink reservation locations; are you aware, Mr Astill, just in relation to the volume of revenue that those 20 locations would generate for CountryLink?---The latest figures I have are 1998/99 because it's very difficult to get them were $6.5 million so if you allow for inflation it would be probably over 7 million.
PN490
Commissioner, I have a document and I've only got one copy at this stage and I would like to tender that. It identifies the ticket sales for the period 1997/98 and one can only assume that that has increased fairly dramatically since then but for the period 1997/98 our estimation on the document that I've got is $5.93 million for those 20 locations. I would like to tender this document and provide you with copies some time this evening, if that's all right.
**** JAMES WILLIAM ASTILL XN MR ASTILL
PN491
PN492
MR PANIGIRIS: We presume that there's been a gradual growth over that period anyway of roughly 3 to 5 per cent per year.
PN493
THE COMMISSIONER: You will get me a copy of that this afternoon and also for State Rail.
PN494
MR PANIGIRIS: Yes, Commissioner. Would we have that marked as - - -
PN495
THE COMMISSIONER: Yes, I said RTBU 1.
PN496
MR PANIGIRIS: Thank you. Sorry, Commissioner, I thought our submissions - - -
PN497
THE COMMISSIONER: I don't think I've marked any submissions. You haven't gotten to them.
PN498
MR PANIGIRIS: No, you haven't. I thought you marked the SRA submissions SRA 6.
PN499
THE COMMISSIONER: Yes, I did. When we have finished with Mr Astill you might address that and we'll mark that.
**** JAMES WILLIAM ASTILL XN MR ASTILL
PN500
MR PANIGIRIS: Mr Astill, there are a number of other locations that are considered to be fairly busy throughout the network, Wynyard, Circular Quay, Fairfield, Cronulla; would you agree that those locations do in fact have their own CountryLink travel centres?---Yes, they have a separate CountryLink travel centre office.
PN501
At those locations in essence the public are required to go to those travel centres and they're managed by people like Mr Richens?---Correct, yes.
PN502
These 20 other locations we have identified that particular sale component is done by those station staff?---Sales persons, yes.
PN503
Well, is it sales persons or could it be a duty manager at some stage or it could be an appropriately qualified customer service attendant?---Morisset and Springwood are the only two that - - -
PN504
Come to mind?---Come to mind, yes.
PN505
So you do accept that it may not just be a sales person?---It may not.
PN506
No further questions, Commissioner.
PN507
PN508
MR WOODS: Mr Astill, I'm going to get these initials wrong I think, the IRT system; is that right?---Integrated Retail.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN509
Was that located at the 20 locations when it was around?---It was actually located at 32 locations.
PN510
Right?---When they introduced the TravelLink system because of the financial restraints they put them into 18 locations. We have recently put two more back in because of the volume at Morisset and Pennant Hills.
PN511
AT the same time that they changed over did they establish these CountryLink separate booking offices at busy stations such as you just identified to Mr Panigiris; did that happen about the same time?---No, they were also there under IRT.
PN512
So through the presence of the IRT system and through the current CountryLink computer system people going for sales positions know that a number of those positions have sold CountryLink tickets through one of those systems?---General knowledge would be that they have a CountryLink computer reservation system there.
PN513
I suppose If you were a sales support person or a CSA2 you can know at a station there was an IRT system or now a CountryLink system?---TravelLink system, yes.
PN514
So that if I was a CSA2 and I was going for a position as a sales person I would more than likely know that it might, depending on where I was, involve selling CountryLink tickets?---You would certainly make inquiries to see if it was part of your duties, yes.
PN515
So if I responding to a particular ad I know that they're sold through the City Rail system I could find out whether or not a particular station that was advertising a sales person's position had a CountryLink activity?---You could gain that information, yes.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN516
In terms of the doing the sales, in your role your days will vary as to how many sales you would do of CountryLink?---It does vary.
PN517
It does vary from day to day. Which station are you located at now?---I am at Penrith.
PN518
And at Penrith there are a number of sales people who would undertake - sorry a number of persons who undertake the sales activities?---Morning and afternoon shift at Penrith, yes. There is three shifts but the morning and afternoon shift are the only ones that operate TravelLink.
PN519
Alright. Can I just show you from SRA3 a resource list for Penrith and you see there it identifies - it is the last two pages of that exhibit, Commissioner, identifies four positions, identified sales positions?---There are four positions, it is just that the times are wrong, that's all.
PN520
The times are wrong?---That's all.
PN521
And in addition to that station managers and duty managers come to take sales from time to time?---No. No.
PN522
They don't?---They don't.
PN523
Just as a matter of staffing resources they don't?---They don't.
PN524
But station masters and duty managers do undertake sales activities in some locations from your experience?---From my experience the only TravelLink would be Morisset and Springwood, on afternoon shifts at Springwood.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN525
Okay. Now, within the Penrith with the four positions that cross over at different times during the day - I take it the times aren't correct - some people on a particular day may make no CountryLink sales?---The 6.30am, on here at 6am now, but the 6am does not make CountryLink sales. They don't have access to the TravelLink system.
PN526
But that person might have been trained so that they could go onto other shifts?---Yes.
PN527
So, you identify that shift person as not doing it. The other three shifts would all do it?---The 4.45 who is responsible for the day work TravelLink computer and the 1.30 shift to 9.30 shift also is responsible for it, for the TravelLink and the sales accounts team leader does from 12.45 to 1.30.
PN528
So, there is three people who at different times of the day can be involved in CountryLink sales but on any given day may make no sale?---Christmas Day that is about the only day.
PN529
But in terms of the number of sales there may be very few on a particular day by any one officer?---Anyone.
PN530
Or maybe a number depending upon the particular day?---Do you want me to give you a range or just answer - I can answer yes that it is a - sometimes if it is a quiet day we would say there would be five bookings and a busy day could be 22, 23.
PN531
You have seen the report by S Dass & Associates that was undertaken?---Jade, yes I saw that.
PN532
And there is in that report an identification of the time taken to do a sale. Do you recall that being in the report?---I recall her saying eight seconds for a City Rail and two and a half minutes for a CountryLink.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN533
Yes. And as you have described the activities between a City Rail sale you said it was, if you want to go somewhere and I push a button", to paraphrase you a little bit ?---I said yes, "single to the city, there is your change, thank you very much".
PN534
That's right. So that within that you would identify what type of ticket the person wanted because they will either say it or you would ask them, whether they are an adult or a concession, you would establish that?---I would.
PN535
And you would press the appropriate button to issue the appropriate ticket and go through the change, the receiving money and changing?---Yes.
PN536
And while the process in terms of the CountryLink ticket takes a bit longer you are essentially doing the same things, aren't you, apart from getting their names, sex and phone number for the booking?---Unfortunately with a City Rail ticket you must produce your concession card to buy it, to have a concession, so everyone produces their concession card, they say we are pensioner and all that. With a CountryLink ticket you have to physically ask them if they are a concession before you make the booking, that is slightly harder to get the information out of them.
PN537
Alright, so someone came up for a City Rail ticket and said can I have a concession ticket you would ask for the concession card to check that before you would sell?---Exactly.
PN538
And if you had a person who was on a CountryLink you would, as an activity prompt, is this a concession, are you a pensioner? You would ask the question rather than wait for their proposal?---I would but the ramifications are entirely different with a City Rail ticket and a CountryLink ticket because if you buy a pensioner ticket and you make a mistake in the next five people you would be able to sell that pensioner ticket to them.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN539
That is in a City Rail sale?---In a City Rail sale.
PN540
So, you can put it aside, sell it to the next person, not go through any cancelling paperwork?---It has got to be cancelled within 10 minutes but the pensioner tickets they are quite high sellers. But under a CountryLink system if you do make a - book them as a pensioner and they don't have a current or a valid card that's a whole different process to go in and cancel and do the booking again.
PN541
So that as a routine you would ask if the person has a concession card, a pension card?---Yes.
PN542
So that you can establish that up front and don't make the error?---Exactly right.
PN543
So that you identify where they want to go as you do for a City Rail ticket?---Yes.
PN544
The day of travel is perhaps different except if you are selling City Rail periodicals which you can buy and you need dates for?---Yes, it is - - -
PN545
So, you have got to identify the date?---You have got to identify the date.
PN546
Identify the concession. You identify how many tickets are being sold?---How many people are travelling.
PN547
Yes, and you do that for both, if someone said they want more than one ticket, that would have to identify that to you and you would respond in a City Rail sale?---I do.
**** JAMES WILLIAM ASTILL XXN MR WOODS
PN548
There are clearly issues in terms of identifying a seat and putting it on hold and there are conditional issues of the identifying name and sex and phone number for booking purposes in the CountryLink. You don't have to do that with City Rail. And then you, either through the cursor or keys progress through to ticket sale and the ticket is produced and the price is produced for you on the CountryLink?---That's right.
PN549
Just as it is on the City Rail ticket?---With much greater volume of price. The price is much greater.
PN550
The price is different, no question about that?---Greater.
PN551
But just as the City Rail ticket issuing system issues with information printed on it and displays what the price is so does the CountryLink system?---It does.
PN552
Nothing further, Commissioner.
PN553
PN554
MR PANAGIRIS: Mr Astill, do you accept that it takes 2.5 minutes to undertake or complete a Countrylink reservation?---It can take two and a half minutes, or it can take - like an episode I had on Sunday that took 45 minutes.
PN555
You accept that 2.5 is an average?---No.
PN556
What would you consider to be an average?---Between 10 and 12 minutes.
PN557
In relation to applying for a position say at Penrith, is there a requirement on a person who applies for such a position as a sales person to be trained in Countrylink reservations?---There is.
**** JAMES WILLIAM ASTILL RXN MR PANAGIRIS
PN558
There is a requirement?---There has to be.
PN559
Is that training provided?---Five days at Petersham College.
PN560
But is it provided?---Not at Penrith, no.
PN561
Where is it provided at?---In the Australian Rail Training Centre at Petersham/
PN562
Who provides that training?---Countrylink.
PN563
Is that done on application or what is the process?---You must apply to be trained in that, in the Countrylink system. If you were to take up a position at Penrith you would not be able to do three of the shifts at Penrith without qualifying in the Countrylink system.
PN564
The question I am asking, sir, is it automatic that you get the training that you are asking?---No, it's not automatic, you have to apply.
PN565
So you could be promoted to a position of a sales person and not be trained in the travelling system?---You can.
PN566
Do you undertake the task?---No, until you're trained.
PN567
Until you're actually trained?---Must have the training. Without the training you couldn't do it.
PN568
But you are not forced are you to be trained?---No.
**** JAMES WILLIAM ASTILL RXN MR PANAGIRIS
PN569
So if you don't want to be trained, you don't have to be trained?---No.
PN570
Mr Astill, in relation to the 20 odd locations, and you said there used to be 30 locations?---Thirty-two.
PN571
Thirty-two locations, was Seven Hills one of those locations?---it was.
PN572
What happens to Seven Hills now in relation to the selling of Countrylink tickets?---They refuse to sell them.
PN573
There is a travelling system at Blacktown, is there not?---There is.
PN574
What happens to the trade from Seven Hills?---It would progress to Blacktown.
PN575
THE COMMISSIONER: I am sorry, what?---It would progress to Blacktown. The people would - they'd be told we don't have a - we don't sell Countrylink tickets here, you either have to go to Blacktown or Parramatta.
PN576
MR PANIGIRIS: No further questions.
PN577
THE WITNESS: Can I expand on that?
PN578
MR PANIGIRIS: Sorry?---We did have a commitment from the department that they would force all stations to sell Countrylink tickets but it hasn't been forthcoming yet.
PN579
THE COMMISSIONER: So, Seven Hills then isn't a station so they just don't have the system?---They don't have the system.
**** JAMES WILLIAM ASTILL RXN MR PANAGIRIS
PN580
So therefore the system has to be at Blacktown or - - - ?---The next station on is Blacktown.
PN581
Or, there's one other?---Parramatta.
PN582
Parramatta?---Parramatta Travel Centre. It's Countrylink Travel Centre.
PN583
MR WOODS: Commissioner, there is just a couple, if I could, can I just ask a couple of questions in relation to those things which didn't in the Seven Hills issue didn't really arise.
PN584
PN585
MR WOODS: The staff at Seven Hills could use the phone to make a booking through with the Central Reservations Centre, couldn't they?---They could.
PN586
So they're chosing not to undertake those sales?---They are.
PN587
But from your - being an experienced person in booking office and sales, it is part of their job to actually do those sales by phone, isn't it?---It is.
PN588
In respect of the training for Penrith, it is expected that everybody who is a sales person at Penrith is trained to undertake the Countrylink sales isn't that right?---If a person was appointed to Penrith the station manager and the sales account team leader would ensure that that person would be trained in travelling.
**** JAMES WILLIAM ASTILL FXXN MR WOODS
PN589
That's right because it's necessary for that position. I think that's all, Commissioner.
PN590
PN591
MR PANAGIRIS: Just on Seven Hills, Mr Astill. They did have a computer reservation system, didn't they?---They did and when they took it out.
PN592
PN593
THE COMMISSIONER: Mr Panigiris, do you want to make your submissions?
PN594
MR PANIGIRIS: Commissioner, our submissions are based on the documentation we referred to the Commission. We would say clearly to you, on the evidence presented by our witnesses and the fact that we believe we've proven to the Commission that there is a clear level and degree of complexity in relation to the sale of Countrylink tickets through the reservation system and that is clearly also acknowledged in State Rail's documentation.
PN595
Our application is outlined in page 5 of our submission which we would seek you to mark in due course.
PN596
THE COMMISSIONER: That is what I was just asking you if you wanted to mark them. I won't interrupt you, I will hear you.
PN597
MR PANIGIRIS: I say this, Commissioner, that we believe that $1.50 is appropriate. We've applied some mathematics to this in relation to where the sales person currently lies, where the next classification within the station classification system lies, we've clearly identified that in order to pursue an additional grade for these individuals would clash with their supervisors, which is the sales team leaders. It would also clash with the duty managers at those locations that is required to manage those stations, especially in the PM.
PN598
The application of $1.50 in our submission could clearly be roped off for those 20 locations. We would say that the individuals who operate this system at those 20 locations could clearly be identified through the rostering system and the amount of money is clearly not significant in real terms in relation to the overall application fo the system and of course bearing in mind the revenue that this particular system generates for those 20 locations. Again, Commissioner, we say to you that the figures that we have at the moment is $5.93 million for the '97/'98 period which we believe could be well adjusted into the 6 to 7 million dollar bracket for the 2001/2002 period. Commissioner, other than that our submissions lie on that basis.
PN599
THE COMMISSIONER: Yes, thank you, Mr Panigiris. I will mark - there's two sets of submissions I've received from the RTBU, in a sense addressing the two outstanding issues at this point in time. The submission filed at 10.30 on 19 December in relation to Countrylink issues is marked RTBU2. The submission filed on 19 December at 3.40 in relation to pre-coded ticket issue is RTBU3.
EXHIBIT #RTBU2 SUBMISSION FILED ON 19/12/2002 RELATING TO COUNTRYLINK ISSUES
EXHIBIT #RTBU3 SUBMISSION FILED ON 19/12/2002 RELATING TO PRE-CODED TICKET ISSUE
PN600
THE COMMISSIONER: You will give me a copy of RTBU1, Mr Panagiris. If you would do that and you might try and do that some time this afternoon if you would, so that I have with me. Mr Woods also has something that he has got to give me a copy of as well.
PN601
Mr Woods, you are going to give me submissions in relation to this issue?
PN602
MR WOODS: Yes, I am happy to do that, Commissioner.
PN603
THE COMMISSIONER: How long do you think you will be?
PN604
MR WOODS: I won't take more than 10 minutes.
PN605
THE COMMISSIONER: I might hear you. I have another dispute - - -
PN606
MR WOODS: The same people.
PN607
THE COMMISSIONER: You took the words right out of my mouth, Mr Francis. Mr Greenhaush, you're on your feet?
PN608
MR GREENHAUSH: It might be another party, Commissioner. It may be another party to the other matter, we are not certain.
PN609
THE COMMISSIONER: My associate might see if there is anybody outside to explain to them that we will be a bit late. If you are only going to be 10 minutes. I don't believe there would be any reply in relation to this issue, would there? If you are only going to be 10 minutes then I will hear you and then this matter is adjourned until Monday, at 10 o'clock to address the issue of the pre-coded tickets. Yes, Mr Woods, when you are ready?
PN610
MR WOODS: The proposition for State Rail in respect of this is that there is no basis upon which to make any allowance in respect of the CountryLink sales. It is important to note that these sales, whether through the IRT system or through the current computer system have been going for a long time. We have a change in the system in the last two years but we have had through that time a number of salary increases and adjustments with different enterprise agreements and the issue of sales of CountryLink tickets through whatever computerised system has been always part of these duties.
PN611
So there is nothing new in respect of this activity and we've identified the various percentage changes in salaries over the years at page 13 of Mr Francis' affidavit. So first of all there is nothing new about this. Yes, we have a piece of technology that has been in place for two years and yes, there are some activities that are additional in operating this system than to operating a CityRail sale. With Mr Edsell we've explored that and we've explored that it can take two and half minutes to complete a CountryLink sale. You might get a CityRail sale complete in 8 seconds.
PN612
You might take longer depending upon the complexities of a CountryLink sale if there were lots of tickets that needed to be issued and you had different places in which you were going to go. Essentially what the person is doing is operating a particular system. Not everybody in State Rail operates that system and hence anyone who does needs to have the training so they've got the confidence to be able to use that system. That training is provided.
PN613
Essentially they are selling a ticket to travel on the New South Wales rail network and they are using a computerised system to effect that sale having identified where the customer wishes to go, when they want to go, what their fare classification is and with a couple of additional activities for the CountryLink sales dealing with seat allocation and confirmation of name, sex and phone number which is important for making sure that the right person is travelling and the concession issue is important to identify and is identified up front in the example that Mr Astell gave.
PN614
So we've got no real change, we've got remuneration happening, we've got Mr Francis having very carefully identified within the position descriptions which were prior to the Jade Novakovic review. Identifying the competencies that fit within ticket sales and they fit within ticket sales whether they are CityRail or whether they are CountryLink sales. So that we have those competencies identified. We have a system in the State Rail for identifying salary levels against competencies and activities because the State Rail is a big employer with lots of different people and it is important to identify levels of fairness in identifying salaries and so they have this system.
PN615
This system has been applied to the CountryLink sales activities and it is identified within the band of salaries width for the particular officers. So they have conducted that assessment, established the points, compared it against the scale and even after adding the three extra competencies in State Rail exhibit 5 - - -
PN616
THE COMMISSIONER: 5 was the position description for the consultant's report.
PN617
MR WOODS: Yes, 5 is the position description following the Novakovic review where they added the three additional competencies for the sales person and with Mr Edsell evaluated and his evaluation is annexure JBF9 at page 74 and he evaluates the point scoring under the CED system and identifies that against the point scoring previously allocated for the same position and to link that back to the salary bands and found that it still fell within the salary bands for the existing position.
PN618
So that having gone through the exercise, conducting a fair evaluation consistent across the whole of the State Rail, we come up with a salary outcome that is no change. Yes, there are some more things to do but you can have across the network people in individual locations doing more than others. You have the CSA2 as Mr Francis has identified who in some locations undertakes a sales activity and some does not but they are both paid the same. There needs to be some flexibility and the job descriptions and evaluations are prepared on that basis and so the people are paid for those job descriptions and move around the network and undertake different duties.
PN619
So that when you look at all of those factors there is no basis for a further allowance in respect of this activity. It would just fly in the face of do you pay a CSA2 more if they have a sales role than if they don't but it is all part of their same job description if they move between different stations. We then come to the prospect that even if you were to turn your mind to seeing that the activities for the CountryLink sales deserve some form of allowance then we have, in the example of Penrith, some people who might do five or might do 20 sales in a day and yet they are going to be paid for that all day every day and they may do no sales.
PN620
Then we have to identify each week the one person out of the sales shifts at Penrith who is on the early morning shift and who doesn't do any sales at all. Well why is that person any different on that day when they have the same competencies training, they have the same activities but they are just not selling any tickets that day? Is that person different to someone else on a different shift, the same day who doesn't have a customer who comes in? They don't use their competency skills, they don't do anything to earn their allowance on that particular day, they are just on a different shift.
PN621
So you don't have that as a basis. You then have in other stations the prospect of duty managers who might do CountryLink sales if they are trained for it and they would have been. Station managers, CSA2s could have been trained in respect of those sales. So sometimes they might do a sale and sometimes they may never do a sale because there are other sales people to deal with them. So we end up with a situation where you have a broad band of people all of whom who have had a training some of who might get allowance some of who might not. Some of who might not do any work in respect of that allowance on a particular day but be paid the allowance.
PN622
THE COMMISSIONER: Isn't the claim for that it is only to be paid for persons that are rostered?
PN623
MR WOODS: The claim is for those who are rostered but just because you are rostered and you are available we have from Mr Astell, three people in a day at Penrith, as an example, who are in a position to sell CountryLink tickets. The fourth person for some reason doesn't have access to the computer on the day. Those people may be rostered but may do no sales. So if you were paying an allowance for competencies and responsibilities - - -
PN624
THE COMMISSIONER: But they are all working selling tickets aren't they?
PN625
MR WOODS: They are selling tickets but they are selling standard State Rail tickets.
PN626
THE COMMISSIONER: Yes but they may move around onto the other computer when someone goes to lunch or has a break.
PN627
MR WOODS: In terms of that location of the computer, it is set back on the basis of Mr Francis, we didn't as Mr Astell how Penrith was laid out but it is not at a window, it is available for use by anybody.
PN628
THE COMMISSIONER: Well there you go, that is even more so because what you would have to do then is leave your window and go over to the machine.
PN629
MR WOODS: You might go over to your machine to do it but - - -
PN630
THE COMMISSIONER: You go over to the machine.
PN631
MR WOODS: The machine, your actual window, you are serving whichever customer happens to be there, if there is a CountryLink customer you serve that customer but you may have no CountryLink customers at all during the day, in that case you are exactly the same as the person who was on the shift that didn't have access to the computer, they've not made any sales but they also have had that training.
PN632
THE COMMISSIONER: Mr Greenhouse mightn't get an industrial during the day either.
PN633
MR WOODS: He might not.
PN634
THE COMMISSIONER: Neither Mr Panagiris mightn't get a complaint from a member during the day and I may not hear a matter during a day.
PN635
MR WOODS: And we would all be very happy for a lot of those things to happen on many days but it's - - -
PN636
THE COMMISSIONER: I hear what you say, Mr Woods.
PN637
MR WOODS: When you put that concept and paying the duty matters, what happens if a Station Manager or Duty Manager steps in to take a sale because the salesperson has gone off for a toilet break or something, they are available to deal with it, are they being paid that allowance all day as well, even though as in their role they fill in these activities and expected that they will be filled in. Are we going to be paying them the same role?
PN638
Similarly for a CSA2 who might not be filling in on that particular day, expected to fill in the day but does do so because they have the training and conduct that sale. Are we supposed to be paying those people all day as well? When you start to look at how people could claim or not claim the allowance and do we pay for an hour because they've filled in for an hour, the complexities of that in terms of the expansion of the claim is another issue but when you look at that and look at what is their current job and the current pay rate and how it's part of what is expected of their positions, Mr Panagiris in cross-examination of Mr Francis made points about job ads not referring to CountryLink sales.
PN639
Well, Mr Astel has made it quite clear as to what people who apply for positions can expect to know and would be expected to find about a particular position and whether there are CountryLink sales, so they know what the issue is in relation to that station in which they are applying for a position. So, that the concept of a structure in this separate allowance for limited time periods for limited numbers of people doesn't work and it doesn't need to work because the jobs activities that they are doing and the salary arrangements which they are being paid, fit within the ban which covers all of that.
PN640
The references in the submissions in respect of the enterprise agreement, the clause 3.4 which was one that I referred to and talks about customer service, it talks about new initiatives, it's not entirely apt to this issue because there is nothing - - -
PN641
THE COMMISSIONER: You don't have a copy of certified agreement provisions, do you?
PN642
MR WOODS: I can make one available, Commissioner.
PN643
THE COMMISSIONER: If you have a spare copy of the agreement that would benefit me, my copy is probably in one of my files.
PN644
I don't think I need to mark that, gentlemen. So, you want me to have regard to 2.7 and 3.4, Mr Woods?
PN645
MR WOODS: No, I raise it in terms of the submissions, 2.7 related to no extra claims, we are slightly outside of that, I accept because of the nature of the way we are approaching this. I refer to 3.4 just for clarity, this is not a new initiative, 3.4 is about new initiatives, so we don't rely upon that. The question is this case is, what is the current salary structure, what falls within the accepted duties for that salary structure and we say that all the CountryLink activities fall fair and square within those duty structures and salary rates. Thank you, Commissioner.
PN646
THE COMMISSIONER: Yes, thank you, Mr Woods.
PN647
Gentlemen, nothing further?
PN648
MR PANIGIRIS: Commissioner, could I just clarify a point, I think it is relevant that you do look at 3.3 of the agreement and also, just to put my friend at ease, we are only talking at those locations where salespersons are actually rostered to sell tickets and I take on board my friend's concern about toilet breaks and lunch breaks and those sort of breaks that people have from time to time. We are actually talking about people rostered to sell tickets.
PN649
MR WOODS: Commissioner, just in respect of 3.3 we wouldn't see that as applying because it's not implementing of technological change, this is an activity that has been ongoing for many years.
PN650
THE COMMISSIONER: I don't know that I would say many years, two years.
PN651
MR WOODS: Well, there was a prior system that was on line, this particular system has been in operation for two years but there's another prior system that goes back for many years beyond that, so the issue of CountryLink sales through an on line assistant system has been going for many years.
PN652
THE COMMISSIONER: All right, gentlemen, I will have regard to what submissions you have put before me. Now, we are part-heard, that's dispensed with, what the parties wish to put before me in regards to the CountryLink TravelLink issue, Monday is to deal with the pre-encoded tickets at 10 o'clock. I realise that the parties are seeking that I make an ex tempore decision on Monday in relation to the issues, that I will attempt to do.
PN653
The Commission is adjourned till Monday and the dispute, gentlemen, that I have listed for 4.30 I'll have back in conference in about 10 minutes, so you have a courtesy break between matters. The Commission is adjourned until Monday, thank you.
ADJOURNED UNTIL MONDAY, 23 DECEMBER 2002 [5.00pm]
INDEX
LIST OF WITNESSES, EXHIBITS AND MFIs |
EXHIBIT #ASU1 STATEMENT OF DAVID SPEED PN19
MFI #1 TICKETS PN46
EXHIBIT #SRA1 STATE RAIL AUTHORITY OF NEW SOUTH WALES CLASSIFICATION AND RATES OF PAY, DATED 04/12/2002 TC
GEOFFREY BRUCE FRANCIS, SWORN PN52
EXAMINATION-IN-CHIEF BY MR WOODS PN52
EXHIBIT #SRA2 AFFIDAVIT OF GEOFFREY BRUCE FRANCIS DATED 18/12/2002 PN57
EXHIBIT #SRA3 RESOURCE PLANS AND CLASSIFICATIONS TO OPERATE STATIONS PN69
EXHIBIT #SRA4 DOCUMENT HEADED
CROSS-EXAMINATION BY MR PANIGIRIS PN128
RE-EXAMINATION BY MR WOODS PN283
EXHIBIT #SRA5 JADE AND NANAKOVIC REPORT FROM S. DAS AND ASSOCIATES PN327
WITNESS WITHDREW PN394
EXHIBIT #SRA6 OUTLINE OF POSITION OF STATE RAIL PN399
ROGER JAMES MICHAEL RICHENS, SWORN PN423
EXAMINATION-IN-CHIEF BY MR PANIGIRIS PN423
CROSS-EXAMINATION BY MR WOODS PN446
EXHIBIT #SRA7 POSITION DESCRIPTION PN455
WITNESS WITHDREW PN460
JAMES WILLIAM ASTILL, SWORN PN461
EXAMINATION-IN-CHIEF BY MR ASTILL PN461
EXHIBIT #RTBU 1 COPY DOCUMENT IDENTIFYING REVENUE FOR COUNTRYLINK OVER THE 20 LOCATIONS FOR THE YEAR 1997/98 PN492
CROSS-EXAMINATION BY MR WOODS PN508
RE-EXAMINATION BY MR PANAGIRIS PN554
FURTHER CROSS-EXAMINATION BY MR WOODS PN585
FURTHER RE-EXAMINATION BY MR PANAGIRIS PN591
WITNESS WITHDREW PN593
EXHIBIT #RTBU2 SUBMISSION FILED ON 19/12/2002 RELATING TO COUNTRYLINK ISSUES PN600
EXHIBIT #RTBU3 SUBMISSION FILED ON 19/12/2002 RELATING TO PRE-CODED TICKET ISSUE PN600
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