No, I'm not suggesting they'll adopt ALPA merger policy. What I'm saying is that should they adopt the Nic, they'll then have no choice but to mitigate the inequities it would create for all pilots such decision would present with a slew of complexities to ensure all 3 groups pre-merger career expectations are maintained to the greatest extent possible or perhaps disregard that concept entirely. I simply don't see that. What you seem to be asserting is that the arbitrators will (or should) apply and give weight to "hypothetical" situations that didn't exist (whether right or wrong) before or in lieu of ACTUAL situations to unemotionally (but more accurately) arrive at a fair and equitable result for THIS SLI, the ultimate success being the maximum realization of pre-merger career expectations.

They could do it your way, but to be fair, it would have to be "fence city" for MANY years or instead they could devise a "hybrid" model just like the UAL-CAL result taking into account multiple factors with various weights to minimize or possibly even eliminate the undesirable aspect of fences.