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10 October 2022 

Dan Mills, Deputy Minister 

Department of Post-Secondary Education, Training and Labour 

Chestnut Complex  

P. O. Box 6000  

Fredericton, NB E3B 5H1  

Via email:  

Re: Minimum Wage Consultation 

Dear Mr Mills: 

I am writing today in response to your request for feedback on the minimum wage rate in New Brunswick, as part of the 2022 statutory review of minimum wage launched on 8 August 2022. The chamber, our board of directors, and members thank you for the opportunity to give feedback and contribute to the discussion. 

As per our 2020 minimum wage consultation submission, the Fredericton Chamber of Commerce and our members support the system currently in place – namely, that the New Brunswick minimum wage be adjusted annually based on the consumer price index (hereinafter “CPI”). This provides both balance and predictability to employers and workers alike. The minimum wage rises according to our member’s ability to pay —as the economy grows.  

Correspondingly, a minimum wage adjusted with the CPI is beneficial to employees, ensuring that wages adjust to the changes in prices of goods. Adjusting for inflation is also beneficial, because changes in wages are produced gradually and are predictable. It is extremely important for our members to know of a change for a minimum wage (or any ongoing cost) well in advance — so that they can adjust their business plan accordingly. In the current inflationary environment, it is even more important than before to have predictable increases so that employers can properly budget salaries and employees can be assured of cost-of-living increases. 

It is also important to note the economic effects of the COVID-19 pandemic are still being felt by businesses and that many of the hardest hit sectors are disproportionately affected by a minimum wage increase. Businesses have been hard hit and must reconcile both these expected and unexpected costs with their financial plans; as a result, the costs of goods and services have risen, and in some cases, employers have had to limit or reduce their staffing. These challenges, in combination with a slow economy, place additional stress on the already complex and multifaceted endeavor of running a business.  

Changes in consumer behavior, the supply chain, among others, will affect businesses not only now, but in the long term. It is a crucial time to not increase costs to businesses substantially and risk their survival after the pandemic. The recent increases in costs for businesses are well-documented and are now facing federal increases to Canada Pension Plan Benefits premiums, Employment Insurance Premiums and fuel cost increases through the carbon tax as well as market forces. Burdening businesses further – beyond CPI-based increases would be a major blow to the competitiveness, and in some cases existence, of New Brunswick businesses. 

Other Atlantic Provinces 

Notably, an annual-adjusted, CPI-based system is currently being employed in Nova Scotia, Newfoundland & Labrador, as well as other Canadian provinces. However, we are concerned that the Government of New Brunswick chose to deviate from the statutory review process and increased the minimum wage in 2021 by $2.00 per hour based, in part, on competition with other Atlantic Provinces. This type of competition amongst the provinces will lead to wages increasing well-beyond CPI-linked increases and we submit that New Brunswick should either not consider other Atlantic provinces when establishing our minimum wage rate or formally align the rate amongst the provinces through agreements with the other provinces (which should then be linked to CPI). 

According to a May 2021 Working NB report, less than 5% of New Brunswick’s workforce makes minimum wage (the 2nd lowest rate in the country) – many in entry-level positions – but a large portion of these workers are in the sectors that have been hit hardest by the pandemic – 66% working in either the retail trade or accommodation and food service industries. It is also notable that this wage increase comes during a pandemic where the New Brunswick government’s pandemic relief and stimulus efforts over the last two years have been more than $1 billion below the average of other provinces, these businesses will be further challenged to recover – not all of them will. The overall relative strength of the provincial economy as evidence of business’ ability to absorb such an increase is meaningless to these businesses that continue to struggle. 

In summary, we submit that minimum wage should not be looked at in a vacuum, but should be considered with the perspective of: 

  1. the total cost burden on employers and their ability to absorb an increase. Employers must always consider their overall cost burden and every increase – in particular those not predicted –  will force some to make tough cost-controlling decision such as reducing hours or employees – hurting workers, employers and the economy; 
  1. the current system is currently providing predictability and reasonable increases; and 
  1. the efforts for regulatory alignment amongst the Atlantic provinces. 

We therefore submit that no changes should be made to the current process of establishing the minimum wage in New Brunswick. 


Krista Ross 

CEO, Fredericton Chamber of Commerce 

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