2012 HOCKEY ARBITRATION COMPETITION of CANADA

TEAM #6

WINNIEPEG JETS AND ONDREJ PAVELEC ARBITRATION

BRIEF FOR: THE WINNIEPEG JETS SUMMARY

1. Ondrej Pavelec is the starting goalie for the .

2. In five seasons in the NHL, Pavelec has recorded average statistics and been a positive,

although not a standout, addition to the franchise and fan community.

3. Based on the salaries of appropriate comparison players, Pavelec should receive a one-year

contract for about $3.25-million.

THE PLAYER AND THE TEAM

PLAYER AGE AND EXPERIENCE

4. Pavelec is 25 years old,1 was drafted in 2005 (during the second round as the 41st pick

overall) by the (as they then were) .2 He has played five seasons with the

Thrashers/Jets.3

5. At present, Pavelec is the Jets’s starting .4

PLAYER PERFORMANCE

6. Over five seasons, Pavelec’s performance has been average. He did not have a winning

season until 2011-12 (29 wins to 28 losses), although his save percentage has been about

.900 since 2009-10. Unfortunately, his goals-against average has been problematic: hovering

1 http://www.nhl.com/ice/player.htm?id=8471715&view=stats 2 http://www.nhl.com/ice/draftsearch.htm?team=ATL&year=2005 3 http://www.nhl.com/ice/player.htm?id=8471715 4 http://jets.nhl.com/club/depthchart.htm?dcid=349

1 around 3.00.

NHL CAREER REGULAR SEASON STATISTICS5

SEASON TEAM GP WINS LOSES SV% GAA

2007-08 Thrashers 7 3 3 .905 3.11 2008-09 Thrashers 12 3 7 .880 3.61 2009-10 Thrashers 42 14 18 .906 3.29 2010-11 Thrashers 58 21 23 .914 2.73 2011-12 Jets 68 29 28 .906 2.91 NHL TOTALS 187 70 79 .907 2.99

7. Compared with NHL , in 2011-12, Pavelec’s league-comparable performance

was disappointing at:

 18th in wins;

 Second in loses;

 35th in save percentage; and,

 39th in goals-against average.6

8. The 2011-12 season was especially disappointing because Pavelec was fifth in games played

among goalies,7 giving him ample opportunities to rally his statistics.

9. Pavelec’s 2010-11 season has been his best, although his performance has been consistently

average. As noted, 2011-12 was not a break-out season.

5 http://www.nhl.com/ice/player.htm?id=8471715 6 http://www.nhl.com/ice/player.htm?id=8471715 7 http://www.nhl.com/ice/player.htm?id=8471715

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TEAM SITUATION

10. The Winnipeg Jets are in a unique position in the NHL. As the newly relocated Atlanta

Thrashers, the team still plays in the Southeast Division of the Eastern Conference.

11. Because of the move, the team is owned by a new ownership group that requires the

flexibility to establish itself in a new city, new climate and new country -- all factors that

suggest more accommodation should be considered around the length and amount of new

contracts.

PLAYER'S ROLE ON TEAM

12. Pavelec is the starting goalie for the Winnipeg Jets, although he is not a franchise player.

13. Pavelec’s relationship with the club and the city is positive, although he has kept options

open to play in the KHL.8

14. Over the summer, Pavelec has also been the subject of embarrassing stories in the press

stemming from calls by Manitoba community groups calling for stricter punishments for

Pacelec’s off-ice behaviour.9

COMPARABLE PLAYERS

15. As a goalie, Pavelec has a restricted peer group. However, the few appropriate comparable

8 http://www.winnipegfreepress.com/breakingnews/Jets-sign-Pavelec-to-5-year-contract-160290775.html 9 http://www.winnipegfreepress.com/sports/hockey/jets/punish-pavs-madd-says-163000756.html

3 players make the comparisons more statistically straightforward.

16. Pavelec is a mid-20-year-old, starting goalie with middling career statistics and no breakout

season.

Tuukka Rask

17. Tuukka Rask has a one-year contract with the (2012-13), with an annual cap

hit of $3.5-million.10

18. The 25-year-old has spent his entire NHL career (five seasons) with the Bruins, amassing a

.926 save percentage and a 2.20 goals-against average. In the 2009-10 NHL playoffs, Rask

had a .912 save percentage and 2.61 goals-against average.11

19. Rask will be Boston’s starting goalie in the 2012-13 season, replacing 2011

Champion goalie .

Cory Schneider

20. has a three-year contract with the (2012-15), with an

annual cap hit of $4-million.12

21. The 26-year-old has spent his entire NHL career (four seasons) with the Canucks, amassing a

.928 save percentage and 2.24 goals-against average. In the 2010-11 and 2011-12 NHL

10 http://capgeek.com/players/display.php?id=237 11 http://www.nhl.com/ice/player.htm?id=8471695 12 http://capgeek.com/players/display.php?id=685

4 playoffs, Schneider improved to a .940 save percentage and 1.91 goals-against average.13

22. In addition to having playoff experience, Schneider became the go-to goalie for the Canucks

in the 2011-12 playoffs, replacing starter first for the playoffs then for the

2012-13 season. In recent seasons, Schneider has shown potential -- both on the ice and in

the minds of the fans and franchise -- of becoming a franchise player.

23. Before the Canucks resigned Schneider, he was one of the most sought-after players in the

NHL and a top pick for franchises looking to add immediate goalie strength.

Devan Dubnyk

24. Devan Dubnyk has a two-year contract with the (2012-14), with an annual

cap hit of $3.5-million.14

25. The 26-year-old has spent his entire NHL career (three seasons) with the Oilers, amassing a

.910 save percentage and 2.85 goals-against average.15

26. Like Pavelec, Dubnyk is in his mid-20s, has spent his career with the franchise and earned

average career statistics.

27. Dubnyk’s performance with Edmonton also compares favourably to Pavelec’s result in

Winnipeg: Dubnyk had better save percentage and goals-against average statistics in 2010-11

13 http://www.nhl.com/ice/player.htm?id=8471239 14 http://capgeek.com/players/display.php?id=49 15 http://www.nhl.com/ice/player.htm?id=8471227

5 and 2011-12 than Pavelec, despite Edmonton finishing 30th in 2010-1116 (Atlanta was 25th)

and 29th in 2011-1217 (Winnipeg was 22nd). In other words, Dubnyk had better statistics in

2010-11 and 2011-12 with a poorer team.

CONCLUSION

28. Pavelec’s contract value is between $3-million and $3.5-million per year. He has:

 Middling statistics;

 A few years experience as a starting goalie, but without a breakout season; and,

 No extraordinary attachment to the city, franchise or Winnipeg Jets fans.

29. Compared with the appropriate comparison players, Pavelec’s appropriate compensation

should be within the $3-million to $3.5-million range because:

 Tukka Rask is a young, breakout goalie with excellent statistics and a one-year, career-

setting contract of $3.5-million. Pavelec does not have Rask’s excellent statistics, nor

would Pavelec be filling the same role in Winnipeg as Rask is filling in Boston -- the

replacement of a Championship-level, franchise player. A one-year, $3.5-million contract

should be considered above Pavelec’s value, simply because, statistically, Rask is the

better goalie.

 Cory Schneider has tremendous statistics compared with Pavelec and also brings playoff

experience and is strong team and fan favourite. At three-years with an average salary of

$4-million per year, Schneider is -- like Pavelec -- the starting goalie in a hockey-mad

Canadian city, but with significant public relations value and exceptionally higher

16 http://www.nhl.com/ice/standings.htm?season=20102011&type=LEA 17 http://www.nhl.com/ice/standings.htm?season=20112012&type=LEA

6 statistics.

 Devan Dubnyk has average (although slightly better than Pavelec’s) statistics and is --

like Pavelec -- is goalie for a team that has finished well away from a playoff berth in the

past several seasons.

30. Compared against these players, Pavelec cannot command $3.5-million to $4-million annual

salaries of these comparison players.

31. Schneider is worth $4-million because he is a better goaltender and is beloved by the

community.

32. Rask, another excellent goalie, is -- unlike Pavelec -- new to the starting role and has signed a

short-term contract to reflect this new step.

33. Dubnyk is the player closest to Pavelec’s statistics and provides an appropriate statistical for

goalie performance from low-standing teams.

34. Pavelec’s fair value, based on his career so far and those of his comparison peers, should be

between $3-million and $3.5-million.

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