2013 HOCKEY ARBITRATION COMPETITION OF CANADA

Carl Gunnarsson v Toronto Maple Leafs (NHL)

SUBMISSION ON BEHALF OF TORONTO MAPLE LEAFS HOCKEY CLUB

TEAM #14

TABLE OF CONTENTS

PART I – INTRODUCTION AND REQUEST FOR HEARING ...... 2

PART II – ANALYSIS OF CARL GUNNARSSON ...... 2

PART III – SELECTION OF COMPARABLE PLAYERS ...... 4

PART IV – GUNNARSSON AND THE COMPARABLE PLAYERS ...... 5

A) CODY FRANSON ...... 6

B) ANTON STRALMAN ...... 7

C) RYAN WILSON ...... 7

PART V – CONCLUSION ...... 9

1 PART I – INTRODUCTION AND REQUEST FOR HEARING

This brief outlines the position of the Toronto Maple Leafs Hockey Club (the “Club”) in this arbitration hearing to determine the salary of Carl Gunnarsson (“Gunnarsson”) for the 2013-

14 NHL season. The framework for information that may be considered in this arbitration hearing is set out in Article 12.9, subsections (g)(ii) and (iii) of the 2012 Collective Bargaining

Agreement (“CBA”) between the (“NHL”) and the National Hockey

League Player’s Association (“NHLPA”). 1

The reason for conducting this arbitration hearing is because the Club and Gunnarsson have, to this point, been unable to negotiate an agreeable salary for the upcoming 2013-14 season. Based on the arguments contained in this brief, the Club respectfully contends that

Gunnarsson should be paid a salary of at least $1 below $3,150,000.

PART II – ANALYSIS OF CARL GUNNARSSON

Carl Gunnarsson was born on November 9, 1986 in Orebro, Sweden.2 On Se[tember 15th of this year, Gunnarson will be 26 years old and thus eligible for arbitration pursuant to section

12.1 of the CBA. He is a left-shoting defenseman standing 6’2” tall and weighing in at 196lbs.3

Gunnarsson was drafted as a twenty-year old in the 2007 NHL Entry Draft by the Toronto Maple

Leafs in the 7th round (194th overall).4

Gunnarsson signed a two-year entry-level contract in 2009 that paid him $630,000 in base salary with an $80,000 signing bonus and another $170,000 available as performance

1 http://cdn.agilitycms.com/nhlpacom/PDF/NHL_NHLPA_2013_CBA.pdf 2 http://www.nhl.com/ice/player.htm?id=8474125 32 Ibidhttp://www.nhl.com/ice/player.htm?id=8474125. 43 Ibid. Ibid. 4 Ibid.

2 bonuses in each year.5 During the first year of this contract his time was split between the

Toronto Marlies of the (“AHL”), 43 games played at the NHL level with the Club and a number occasions where he was a healthy scratch for the Club. His second season with the Club saw him spend no time at the AHL level while registering 20 points in 68 games played. This represented a modest decrease in overall productivity on the ice as his points per game went from 0.35 in his rookie campaign to 0.29 in his sophomore season. He was also unable to avoid the injury bug as he missed 22 games with a hyperextended elbow.6

During the off-season Gunnarsson was rewarded with another two-year contract paying him $1,400,000 in the first season and $1,250,000 in the second. Over the course of these two years Gunnarsson solidified himself as a regular NHL player. However, his average time-on-ice did not see any noticeable increase from his previous year-to-year averages. This suggests that he was not taking on any bigger role than he had already been fulfilling in the past when he was awarded his second NHL contract. His career best 0.41 points per game in his PY represent only a slight increase from the 0.35 points per game he registered during his rookie campaign with the club.7 The Club would argue registering the same 15 points in only 6 fewer games a full three seasons after his rookie season shows the limited offensive upside that Gunnarsson has. There have been no significant developments or breakthroughs in his offensive abilities during his four seasons with the Club.

Gunnarsson has not taken on any significant leadership roles within the hockey Club and generally does not have any special fan appeal that is relevant to this discussion of his value to

5 http://capgeek.com/player/1212 6 http://www.tsn.ca/nhl/teams/players/bio/?id=5218 7 Supra, note 2.

3 the Club. He has been praised for his physical traits, including his long-reach and height.8

However, his playing style has been noted as lacking physicality and he has been criticized for not putting up large point totals at the NHL level.9 His playing style is most aptly described as a puck moving defenseman.

It is interesting to note that during the 11 games Gunnarsson missed during his PY, the

Club’s winning percentage compared to the 37 games where he was in the line-up remained unchanged at approximately 54%.10 This leads to the reasonable inference that his contributions to the team are not of a unique or special variety and can be replaced by other defensemen within the organization without having a negative effect on the Club’s overall performance.

PART III – SELECTION OF COMPARABLE PLAYERS

The Club used an objective statistic-based formula to select comparable players. All arbitration eligible defensemen from the 2012-13 and 2011-12 seasons were considered in the process but only the players who met the chosen criteria qualified as comparable players for the purpose of this arbitration. Below is the criteria used to select the Club’s comparable players.

Career to Platform (CTP)

• Within (+/-) 35% of Gunnarsson’s 187 games played (between 122 and

252 games played)

• Within (+/-) 25% of Gunnarsson’s 0.29 points per game (between 0.22

and 0.36 points per game)

8 The Hockey News, Player Profile, http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5218 9 The Hockey News, Player Profile, http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5218 10 http://mapleleafs.nhl.com/club/schedule.htm?season=20122013&gameType=2

4 Platform Year (PY)

• Minimum 50% of games played in season

• Within (+/-) 20% of Gunnarsson’s 0.41 points per game (between 0.33

and 0.49 points per game)

The chosen criteria represent a combination of the player’s experience at the NHL level and his production on the ice. These are without a doubt two of the most important and relevant factors in determining a player’s worth to his team. The CTP is the time period from the beginning of the player’s career at the NHL level up to an including the season immediately preceding his PY. The PY is the season immediately preceding the player’s arbitration eligibility.

Ultimately this process yielded three players who qualified as comparable players in this instance. These players are Cody Franson (“Franson”), Anton Stralman (“Stralman”), and Ryan

Wilson (“Wilson”). The following is an in-depth comparison of the Player at Hand to each of these players.

PART IV – GUNNARSSON AND THE COMPARABLE PLAYERS

Before looking closely at the comparable players in relation to Stewart, it should be noted that the salary being used for comparison purposes is that which the player receives in the first year of his new contract. The rationale behind this is that the purpose of this arbitration is to determine Stewart’s worth to the Club next season and not any other future season he may play.

Considering the average annual value of a player’s contract that extends more than one year gives too much weight to a subjective assessment of a player’s future potential rather than rewarding him based on proven past performance. While future potential is no doubt a valid consideration when determining a player’s worth, for the purposes of this arbitration that

5 potential should be limited to the year immediately after his PY and no further. With this in mind, the below tables outline the statistical performance of Stewart and each comparable player in their respective CTP and PY’s.

Career to Platform Year (CTP) 11 Player NHL Seasons GP G A PTS PTS/G PIM PIM/G PPP Gunnarsson 3 187 11 43 54 0.29 44 0.24 22 Franson 2 141 14 36 50 0.35 46 0.33 12 Stralman 5 212 11 63 74 0.35 97 0.46 39 Wilson 2 128 6 31 37 0.29 104 0.81 3

Platform Year (PY) 12 Player GP G A PTS PTS/G PIM PIM/G PPP Gunnarsson 37 1 14 15 0.41 14 0.38 0 Franson 57 5 16 21 0.37 22 0.39 7 Stralman 53 2 16 18 0.34 20 0.38 4 Wilson 59 1 20 21 0.36 33 0.56 4

A) Cody Franson

Cody Franson is a 6’5”, 213lb defenseman who also plays for the Club. The Nashville

Predators selected him in the 3rd round (79th overall) of the 2005 NHL Entry Draft.13 The

Toronto Maple leafs acquired Franson in a 2011 off-season trade and subsequently signed him to a one-year contract paying him $1,200,000. Like Gunnarsson, he is a defenseman with good size that does not play an overly physical game, but has an offensive upside.

Statistically speaking, Franson’s point production is very similar to Gunnnarson. In their

PYs, Franson had a points per game average of 0.37 while Gunnarson produced at a rate of 0.41 points per game. In their careers leading up to their respective PYs, Franson outperformed

Gunnarsson by posting a points per game mark of 0.35 compare to Gunnarsson’s 0.29.14

11 All player statistics sourced from respective player’s official NHL profile page 12 Ibid. 13 NHL.com, Player Profile, http://mapleleafs.nhl.com/club/player.htm?id=8471742 14 Supra, note 11.

6 Additionally, Franson was used more frequently on the powerplay during his platform year, at

1:30 minutes per game, and produced seven powerplay points, while Gunnarsson produced none.

Their minutes per game are nearly identical. During their platform, Franson had

0.39 penalty minutes per game, while Gunnarsson registered 0.38 penalty minutes per game.

B) Anton Stralman

Anton Strahlman is a 5’11”, 190lb defenseman with the New York Rangers. Similar to

Gunnarsson, Stralman was drafted in the 7th round (216th overall) by the Toronto Maple Leafs, this time in the 2005 NHL Entry Draft. He then played two seasons with the Leafs, before playing two seasons in Columbus. Stralman’s PY was with the New York Rangers during the

2011-2012 season, after four years of professional hockey and 212 games played. In july of

2012, following a season where Mr. Stralhman helped the Rangers finish first place in the

Eastern Conference, Stralman re-signed as a restricted free agent to a two-year deal worth $1.7

Million a year. Stralman is best described as a puck-moving defenseman who doesn’t play a very physical game and has established himself as an NHL player over five seasons.

During his platform year, Stralman produced points at a rate of 0.34 points per game, very similar to that of Gunnarsson. Further, his style of play led to a penalty minutes per game exactly identical to that of Gunnarsson at 0.38. Stralman has also suited up significant parts of four seasons in the NHL, playing 45% or more of the games in each of those four seasons, where the lone season below 60% (2008-2009) was split between the American Hockey League and the

NHL.

C) Ryan Wilson

Ryan Wilson is a 6’1”, 207lb defenseman who was undrafted and signed by the . Before playing with the Flames he was traded to the and played 60

7 or more games in each of the prior to his platform year, also with the Avalanche. Following

Wilson’s platform year in 2011-2012, he and the Avalanche signed a three-year deal worth

$2,250,000 a year. Wilson is best described as a solid all-around defenseman who plays a simple game and is capable of playing with a physical edge when required.15

Wilson’s time on ice during his platform year is similar to that of Gunnarsson, with only a 2:32 minute difference. Of this, Wilson played 36 seconds per game of powerplay time; not much different from Gunnarsson’s 45 seconds of powerplay time-on-ice per game average.

Point production for each player in their platform year is very similar with only 0.05 points per game difference separating the two. Their CTP point production rates are identical at 0.29.

Furthermore, Wilson’s style of play is of a more physical nature. At 0.56 penalty minutes per game compared to Gunnarssons 0.38 rate. The added physical nature of Wilson’s game really comes across in the types of penalties he received during his PY, with 3 major penalties for fighting, and a few roughing penalties16, while Gunnarson’s penalty minutes were limited to slashing, hooking, tripping, holding, and interference. 17 This physical dimension to a defenseman’s game typically commands a higher salary, all things being equal, than a non- physical player in the competitive NHL marketplace. Given the similarity in the nature of their point production, ice-time per game, and Mr. Wilson’s added physicality, the $2.25 Million salary should be viewed as an upper limit for this arbitration.

15 The Hockey News, Player Profile, http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5415 16 NHL.com, Player Profile - Split Stats, http://www.nhl.com/ice/player.htm?id=8473700&view=splits&season=20112012&gameType=2 17 NHL.com, Player Profile - Split Stats, http://www.nhl.com/ice/player.htm?id=8474125&view=splits&season=20122013&gameType=2

8 PART V – CONCLUSION

The Club takes the position that based on the performance of comparable players who signed deals following their platform years of $1,200,000, $1,700,000 and $2,250,000 respectively, Gunnarrson should be awarded a salary of at least one dollar less than $3,150,000.

The most comparable player in terms on point production, Cody Franson, receives less than half the salary that Gunnarson is seeking. Anton Stralman, a more experienced player with similar numbers earns $1,450,000 less that what Gunnarsson is demanding. Ryan Wilson, a solid all- around defenseman who can play with a physical edge earns $2,250,000 a year, a number that should be viewed as the upper limit for the purposes of this arbitration. Each of these players produced points per game within a rate of 0.07 points per game of Gunnarsson’s. Most importantly, it has been made clear the Club did not suffer any negative impacts with

Gunnarsson out of the line-up due to injury.

9