Mr. Chris Lundy:

I am the executive secretary of the Association of Electrical Contractors of Ireland, which represents between 180 and 190 electrical contractors of different sizes.

We have gone through the 29 heads of the Bill and I will comment on some of them.
Head 6 refers to the variation of registered employment agreements, REAs. Variations to rates of pay in the past using the analog system have been cumbersome, difficult to handle and difficult to achieve agreement. I think other methods for varying the rates up or down should be examined. The analog system is very difficult to handle.
Head 7 relates to cancellation of a registration, be it of a REO or a REA. We have found it very difficult to get a REA cancelled. We are seeking an easier method of trying to agree changes to the registered employment agreement or to get it cancelled. A case went to the Supreme Court. We feel that it should be easier to bring people together when all agree that the system is not working.
Head 8 deals with the adaptation of worker's contracts. When the REA was in place, a contract of employment for the employees simply followed the lines of the agreement. We suggest that the employment contract will follow the format of the agreement.
Head 9 refers to the publication of particulars in relation to employment agreements and right to obtain copies thereof. We suggest that the publication of new employment agreement could be carried out by employer associations and trades unions; using the websites; and through the national newspapers.
Head 10 deals with breaches of a registered employment agreement. We have a question on whether the Labour Court will be the means by which breaches of agreements will be heard.
Head 12 refers to definitions for the purposes of Part 11 of sectoral minimum rates of remuneration and other terms and conditions. With regard to remuneration our members will have major difficulties agreeing to the proposals on travel time. This has been a bone of contention for a long time, particularly where roads have improved. It will take far less time to get to Monasterevin now than it took many years ago. We have no problems with regard to subsistence and long distance travel.
We also think it is very important to state in the terms of the contract that 21 days are the agreed number of holidays in our industry. The reason is that if companies are coming from other countries they may have only ten paid days holiday. That would make a very big difference in the costing of a job.
Head 14 refers to submission to request terms and conditions relating to remuneration.The term "substantially representative of workers" comes up time and time again. We always have a great difficulty in trying to find where we lie on this and how it is achieved. We would like to look at this issue deeply and have it clarified completely before this term can be fully expressed.
Head 15 refers to Labour Court recommendation. AECI see three rates of pay applying to three different sectors in our electrical contracting industry. We have played around with this many times because we feel there is a "domestic" "commercial" and an "industrial" market. There may be something that we could consider. We are convinced that one rate does not fit all.
Head 16refers to the terms and conditions relating to sick pay, pension and mortality schemes. This provision was included in the old REA, however more thought and time is required in this area to form a decision because it is a very heavy area and we need a great deal of time to consider it.
We will now jump to head 22, which relates to dispute settling provisions. With regard to dispute procedure, we believe the recommendation should read "any dispute at all". I acknowledge that it singles out various way that a dispute should be handled but we believe that any dispute should go through the procedures as set out in head 22.
Head 25 refers to a review of order. As mentioned in the head, we concur with the provision for a three year review.
Our final comment relates to head 27 compliance and enforcement provisions.This is one of the most important elements of the proposed legislation. We think the policing and enforcement of the legislation needs to be convincing as many efforts in the past have failed and we would like to know whether the National Employment Rights Authority, NERA, or a similar body would carry this out.

Whatever is put together with agreements is going to fall at this head if it is not enforced and policed properly.