Carl,
Here are the numbers I have gleaned from your company's public releases:
32 DC-9
3 747-200F
10 more DC-9
4 A-320
3 757
That equals 52 in my book. I think you are only looking at the planes announced a month ago. Don't forget the other announcements earlier in the year.
As for the DC-10's, you had 36 in 1998, do you really have 72 A-330's? You also had 35 747's and 8 Freighters. Fleets change with time, that was only 10 years ago, what will your fleet look like 10 years from now? Neither you nor I have any clue on that and neither will an arbitrator.
You state that an arbitrator will definitely look at retirements yet Nicolau ignored all of the East's pilots claims about attrition and career expectations. How do you explain that? Just to be clear he also ignored the West's pilots claims that the East was days away from liquidation so they had no careers left.
Again, retirements only mean something if you make some prediction about future fleet size, even if you predict a static fleet. How does your prediction of a static fleet differ from a prediction of fleet growth? Both are future predictions which will change with time. Given the recent history, growth at Delta is easier to prove than a static fleet at Northwest. I believe that arbitrators will avoid these future looks because they are just a guess. Somehow you think your guess at the future is more relevant than a company's business plan that has been designed by management and approved by the Board of Directors. You must be a good guesser.
Your retirements hit a few years earlier than Delta's, but then Delta has much more retirements. You would have to convince an arbitrator that the short time when you have more is the only relevant time, please provide that explanation.
Date of hire used to be written into ALPA Merger Policy and it was removed. The US Air arbitration was the first big merger since the policy was changed. You are kidding yourself if you think it will not be viewed as precedent in any future arbitrations. Date of hire was specifically removed, the world changed since the Roberts award.
I believe that Northwest just had 70 displacements. Delta just bid out 70 new positions for the 777 (35 each seat). Does that trend mean anything to you? The 737-700's show up next month. The next 777 delivery is in December.
You guys must be betting a lot on the Date of Hire concept, the one that was specifically removed from ALPA policy. Each month the ratios get worse and worse for your side.