Although other governments in Canada have imposed wage
capping legislation, the Public Service Salary Restraint
Act, SA 2013, c. P-43 (the "PSSRA") is
unique given its "very broad and very focused effect" on
one group, the Crown bargaining unit of the Alberta Union of
Provincial Employees ("AUPE"). In its decision released
February 14, 2014, the Court of Queen's Bench stated that the
PSSRA, "guts the bargaining process by removing any
effective leverage on the part of the workers who, as a result of
other provincial laws, cannot withdraw their
labour. The effect of this legislation is to
emasculate the AUPE..."
Bill 46, the PSSRA became legislation in early
December 2013 at the same time as another Bill aimed directly at
public workers. Bill 45, the Public Sector Services
Continuation Act, was introduced in response to an illegal
strike by corrections officers who were members of
AUPE. This Act applies to 100,000 unionized
workers in Alberta, who are members of a
