Nicolau Arbitration Award - Leonidas

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$23 million a year. There are other benefits that will accrue to US
Airways pilots in the form of increased vacations, higher caps and pay
guarantees as well as salaries, that would have been unachievable
until, at the earliest, the December 31, 2009 amendable date of the
US Airways/ AL{PA Agreement. The same can be said for the post-
merger relaxation of onerous work rules that US Airways pilots had
agreed to in concessionary negotiations sought by the Company as a
means of survival.
This, however, does not justify ratios beginning at the top of the
list as America West proposes, for there are compensating factors
such a methodology ignores. Though Date of Hire, whether adjusted
for Length of Service or not, is no longer listed as a determinant or
even stated as a integration criterion, there are occasions when
consideration should be given to that factor. Here, US Airways is far
older than America West, a fact reflected in the average age difference
between the two groups. Consideration must also be given to the
different career expectations based on equipment flown. US Airways
pilots fly wide-body international aircraft, while America West pilots
do not. Those elements weigh in US Airways favor both in placement
and interim restriction and thus argue against the America West
proposal, as do the benefits US Airways pilots will achieve through
their agreed upon receipt of stock options, increasing sums not
factored into simple hourly rate comparisons. Equally worthy of