Nicolau Arbitration Award - Leonidas

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international presence in which planes not in America West's fleet are
flown. However, in most categories, America West's pay scales are
higher. Beyond this, at the time of the merger announcement, US
Airways had a significant number of pilots on furlough while America
West had none. Moreover, the financial future of US Airways was not
comparable to or as bright as that of America West.
These factors, as could be predicted, led to great differences In
the Parties' concepts of a fair and equitable merger. In basic outline,
US Airways argued for a Date of Hire list, adjusted for Length of
Service, subject to certain seven-year conditions and restrictions, a
model that placed the most senior America West pilot far down the
seniority list and merged a number of furloughed US Airways pilots
above active pilots at America West. In contrast, America West, relying
heavily on its view of the pre-merger financial picture at US Airways,
urged a series of ratios that gave little weight to the longer service of
pilots at US Air. Despite indications by the Board that both approaches
created difficulties if the goal was a fair and equitable integration,
those positions were not fundamentally changed.
Before discussing the aforesaid approaches in greater detail,
some uncontroverted facts and then some recent history. US Airways is
the product of a series of mergers stretching back to 1968. At the time