Except they wouldn't be stapled like you are proposing, they would go where their natural seniority would put them.
Let's be clear, I'm not proposing a staple and neither is DALPA. It was just an example which illustrates the absurdity of arguing that as long as there is "no bump, no flush", there can be no harm.
Ratios based on comparable categories and status allow everyone to go where their natural seniority would take them.
Again my bet is the arbitrators will segment the list and use different methods before/after a certain DOH, otherwise there is simply too much asymmetry at one end of the list or the other. The alternative is of course dynamic.
I very much doubt you will see a dynamic list. The arbitrators didn't even think it was worth the time to allow DALPA to refute it.
My bet is ratios with possibly some modest pull outs and plug ins as DALPA suggested.
We all know you are hanging your arguments on the Nicalau award, but even my dog knows we are not even remotely comparable to USair. Everyone but you guys seems to know the difference.
Try, USAirways and Shuttle (Nicolau, 1988) and Atlas and Polar (Harris, 2006). All ratios. You have to go back to the failed Roberts award, an award which a member of NWALPA's merger committee characterized as an example of how not to integrate two pilots groups, to find the last ALPA DOH arbitrated award. Interesting that not a single arbitrated award has gone DOH since Roberts.
The real question is are you guys going to live with what is awarded, or are you going to sue, appeal, and try get it rejected if it's not your SLI?
I don't think that's in question at all. DAL pilots have considently done the right thing. I recall how after LOA 19 the NWA pilots threw a fit. Lots of talk about how DAL pilots would leverage LOA 19 against them, keep them on their contractual "B" scale, etc. Probably because that's exactly how you would have conducted yourselves. Yet from the beginning DAL pilots have consistently stated their goal was to get NWA pilots up to parity at DCC and we did just that.