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.

What's worse than using a model that has been rejected, I guess using ficticious jobs in the model.

Q. The model portends that there are 94 CD 9s pop -- DC-9s populated by 415 captains throughout the entire period; correct?

A. That's correct.

Q. And it moves pilots in and out of those positions in the years starting in 2008, throughout the entire run?

A. Yeah. And that's because, to understand our modeling, we were modeling it based on our philosophy in the case, which is the snapshot, that anything that happened to the fleets after January of '08 is not relevant to this analysis.

Q. You drive to fictitious jobs. And then what happens is –

A. Let me be clear, though. We're not really driving to fictitious jobs. You're saying they're fictitious jobs, jobs that don't exist, because you're looking at the world from July 1 of '08. And we're looking at the world from January 1 of '08, when the airlines effectively, in our view, stopped acting as stand-alone carriers. We can't know -- it's been our view and our testimony that the DC-9 likely would have been
replaced in the future. We're not going to -- I'm not going to sit here and debate that with you.

He must not have aware of Stevens testimony that NWA was not managing the airline as though there was going to be a merger.

Stevens testimony:

Q. My question is a very precise one. And that is, up until -- certainly until mid-March of 2008, did anyone at Northwest tell you that they were managing the airline as though there was going to be a merger with Delta?

A. To your precise question, no.

Why do people post these things? It's clearly stated that these hearings are NOT open to the press, yet people post transcripts in a public forum. Why?

I think Reroute may want to reroute those posts to the delete box. We can argue the merits of the case without the names and specific testimony.

Kinda like when Carl posted transcripts of the hearings?

Exactly like that, it's completely inappropriate. If these transcripts are only available to those with a password, don't you find it inappropriate to post them on a public site? If the union wanted them available to everyone then they would make them accesible to everyone.

I could be wrong and will freely admit if I am, but I believe the hearings themselves were closed to the public but the transcripts are public documents and are releasable.

None of the exhibits were released and hence not posted (on the DALPA website) but the transcripts were and were posted (on the DALPA website).

Again, I could be wrong.

Denny

Just to add, I think that is why some of the testimony given by NW was in closed session. Because these are public documents and there was sensitive company information qiven in testimony and it was withheld from the transcripts.

Denny

Exactly like when Carl posts the transcripts!

I'm not aware of any prohibition of posting transcripts. It's certainly being done on the other ALPA boards.

I've never really considered it though, so I'll stop doing it.

Carl