This is really fascinating read thanks for posting. The biggest thing I kept thinking as I was reading was that as much as some hockey minds hate statistics all the arguments seemed to keep coming back to them. I think you had to use PIMs to highlight Neely’s contribution beyond Goals and Assists given that Hits, TOI, PK time etc. were not statistics back then. Using SOG was also a solid positive for Neely. Pengwin’s point was one I wouldn’t have considered but I agree could only help, the team did better with Neely, although I suspect Burke would counter that the entire team around Neely improved greatly during that period.
From a complete outsider’s perspective I would have mentioned the following additional factors, (feel free to explain why any of these are a bad idea or inadmissible):
1. Neely had not had a major injury thus far in his career (74, 69, 75 GP out of 80). Perhaps you thought never having played a full season would work against you or this wasn’t all that relevant.
2. Neely was 2nd Team NHL All-Star in 1988 and played in the 1988 and 1989 All-Star Games (I think this was all prior to the arbitration date). These seem to be solid proof that he was considered a top player in the league and more tangible than the other evidence available. Further, it may be possible to argue these awards improved his fan appeal?
Ultimately I liked both sides’ arguments and given the limitations of the mock process (comparing eras) I expected Neely to get around $5.5-6 million/season.
A couple thoughts:
1. What are the credentials of the arbitrator(s)? I noticed that “testimonials, videos and media reports” are not admissible as evidence. Googling the arbitrators I saw they are both experienced in arbitration generally but may not be “hockey people”; it seems like this would make using key statistics that much more important to establishing your case.
2. The fact that salary cap restrictions are not relevant is confusing; in a cap era it’s one of the most important elements for a GM to consider. I’m guessing the NHLPA put this provision in because it can only hurt players.
12 team H-2-H 1 year league, daily roster changes, 3 goalie start minimum/week
2xC, 2xRW, 2xLW, 4xD, 3xUtil, 2xG, 5 Bench
G, A, P, +/-, PIM, PPP, SHP, GWG, Hits, W, SV%, GAA
C: Malkin, Backstrom, Stepan, Ribeiro, Legwand
LW: Vanek, Moulson, Carter, Rinaldo
RW: Kessel, Vrbata, Seguin, Cammalleri, Zuccarello
D: Green, Gudas, Zidlicky
G: Lehtonen, Halak, Lack