NWA Pilot Career Model
From reading the testimony it appears that NWALPA decided to use a pilot career model that's been discreditted and rejected in past arbitrations, furthermore, the witness seems not to have done much research on the history of the model before selecting it.
Cross Examination of GREG AVERILL
Q Turning first to the -- in a broad way, the modeling that was used that undergird the various statistical exhibits you put into evidence.
A Okay.
Q Are you aware of that model having been used in other seniority integration arbitrations?
A Yes.
Q In particular, Air Canada/Canadian and America West/USAirways?
A You're speaking of the Salamat model?
Q Salamat model.
A Yes, that's correct.
Q Are you aware of them having been used in both of those cases?
A I am aware of that.
Q You are aware, then, I assume, that – and in the context of the Air Canada/Canadian award, and I'm talking about the Keller arbitration?
A I'm not that familiar. I will say I'm not at all familiar with the case specifically. I'm just aware of the fact that –
Q That it was used?
A That it was used, right.
Q So are you aware that, in fact, Arbitrator Keller rejected the model in that case expressly in his opinion?
A I am not aware of that.
Q And are you aware that a -- although Mr. Nicolau in his award does not -- in America West/USAirways does not address expressly the Salamat model, that the result in the Nicolau award implicitly rejects the undergirdings of the Salamat model?
A I can't testify to that fact. I don't know the answer.
Q Are you aware in the Canadian/Air Canada award, Arbitrator Keller, as part of the rejection of the Salamat model, rejected the motion that attrition should play any role in connection with seniority integration arbitration?
A I'm vaguely aware of the comment, but I don't believe that's exactly what he said. But I'd have to review it to be sure. But I don't believe he expressly rejected attrition as an issue.
Q He rejected age. Wasn't, in fact, the quoted discussion –
A I am not qualified to -- we could certainly review it if you would like me to give you my opinion.