I'll try to keep it to five minutes. It's a pretty big bill for five minutes.
The first point I'd make is what we would have hoped for, which is that in our view the provisions in the bill relating to the changes to old age security and employment insurance should be removed from the bill, and there should be a separate consultation on those. I think both sets of provisions have very far-reaching ramifications.
I'd also note that I don't think that in either case the government has produced a really clear policy rationale for the changes, and it would be good to have that more informed debate on the issues.
So I'll just make a few points very, very quickly.
On employment insurance, we would certainly have a major concern regarding the new appeal process with the social security tribunal. As members are probably aware, there are now about 1,000 part-time members of EI boards of referees across the country that are assigned to each of the EI regions. In our view—and I think in the view of employers as well—the existing system gives unemployed workers a fair and impartial process. The appeals are dealt with on a speedy basis. We don't see that 39 full-time people are going to adequately replace that in terms of an appeal process.
That concern about the loss of a fair process is of particular concern given the other provisions in the bill relating to employment insurance, which I think imply that there's going to be closer scrutiny of unemployed workers and greater expectations of them in terms of job search and the kind of work they should have, so the interaction there is of concern.
I guess around the new expectations of the unemployed in terms of taking available jobs—with significant wage cuts, in some circumstances—it's unclear to us what the rationale is for this change. Is it the case that the government thinks unemployed workers are or are not turning down suitable job offers at the present time?
Most of the impact of those provisions is going to fall on workers in the higher unemployment regions. In the high unemployment regions in Atlantic Canada and Quebec, there is something in the range of 10 unemployed workers for every job vacancy that's reported by employers. It would seem to us that we're very far from a situation where there are jobs going begging because of unemployed workers turning them down.
Again, particularly in the higher unemployment regions where wages are relatively low to begin with, the other concern is that obliging some subgroup of the unemployed to take significant wage cuts could further depress wages quite significantly.
With regard to the old age security and the guaranteed income supplement, it's again unclear to us what the key objective here is. Is it to require older workers to work longer or is it primarily to save money? If it's to make people work longer, I'd draw to the attention of the committee the fact that the average retirement age actually has been rising over the last decade, in line with rising life expectancy, so time spent in work is not falling, as is often alleged. If you look at people aged 65 to 70, you see that now one in four in that age category is continuing to work while collecting, in the vast majority of cases, an old age security pension. There's no requirement to cease work to collect OAS.
To put it in a nutshell, I guess the concern is that if we look at people in that 65-to-67 age group who are going to lose access to OAS and GIS, there is a very significant subgroup in that population that relies on the guaranteed income supplement in particular to give them a barely adequate standard of living. Thirty per cent of the income of people aged 65 to 67 comes from OAS and GIS, primarily because people at the bottom end really rely on that. There's going to be some important subgroup of people who are unable to continue working past age 65 for reasons of ill health, or for reasons of caring for somebody else, and who are likely unable to work to replace that important income from OAS.
If we look at people age 65 to 67 who are working now, we see that 40% are working part time, and 40% are self-employed, often at very low incomes. So it's far from clear that people in that age group who continue to work, assuming the government wants to encourage them to do so, will be able to earn sufficient income to replace that lost OAS and GIS income.
In conclusion, I would just urge that there be more extended scrutiny of those sections of the bill related to EI and OAS than we're going to be able to give them through this process.
Thank you, Mr. Chair.