More legal nitpicking ==> "STS" is a "term of art". Its really only used by the NMB for very narrow purposes in representation disputes. You're right on the money -- What we need is for RAH to be declared an "air carrier". That's the term used in the contract.

You're right about the DOT. Management and ALPA are relying on the DOT/FAA distinction of "certificate holder" to make their argument that the various units of RAH are separate air carriers. (its sad we have to fight mgmt and our union)

As far as the FAA is concerned, different certificates means different air carriers.
The problem is, that's not what the plain language of our contract says and its certainly not the intent of our contract. If all they have to do is keep separate certificates then that section of our contract is useless. Its a fundamental principle of contract law that people don't waste time writing clauses knowing they will be meaningless. Its assumed they intend for them to have effect.

I think we'd have a fighting chance with the 5 man Board. Unfortunately, the ALPA establishment have managed to convince our MEC not to pursue the case.