The WB09-01 Appeal to Step 3 was mailed on Thursday, February 26 via Priority Mail w/Delivery Confirmation. Both Management's Step 2 designee (Sue Mercado) and the Vice President of Labor Relations (Doug Tulino) have received their mailings.
Management's Step 2 decision conveniently ignored the SIT document discussion. Per Article 15.04.G, which allows the Union to make corrections and additions, it was pointed out that the following were discussed at Step 2:
- The SIT plan is comprised of 476 manual test cases
- Since there are 3 user roles in the system, there are actually 1,428 manual test cases to be peformed
- Since Kana repeatedly provides the USPS with a poor application, these tests must be performed over-and-over.
- The Step 2 Union designee stated during the discussion that he was experienced in writing test plans and conducting systems tests, that he estimated it took 1 month to develop the SIT plan, and the remainder of the Union's workhour estimate was due to the repeated testing.
Management's Step 2 denial stated that the Union's workhour estimate was based on "anonymous sources that cannot be shared or confirmed". On the contrary, the Union's workhour estimate is primarily based on the size of the SIT plan and the number of tests repeatedly performed.
Two other "less important" corrections were made, as well as an addition: during Step 2 discussions, management pointed out projects where EAS employees performed bargaining unit work. If our case for eCC is good, it will also be good for these projects pointed out by management. Additional workhours should be added to the remedy.