2013 HOCKEY ARBITRATION COMPETITION OF CANADA

St. Louis Blues v Chris Stewart

Brief Submitted on Behalf of the St. Louis Blues

Team 31

Table of Contents

Introduction………………………………………………………………………………………1

Overall Performance of the Player……………………………………………………………...1

Number of Games Played and Injury History…………………………………………………2

Length of Service in the NHL and with the Club……………………………………………...2

Overall Contribution to the Club……………………………………………………………….3

Special Qualities of Leadership or Public Appeal……………………………………………..4

Comparable Players……………………………………………………………………………..4

A) ……………….…………………………………………………………4

B) T.J. Oshie…………….………………………………………………………………..6

Valuation & Conclusion…………………………………………………………………………8

Introduction This brief is in regards to the past performance of Mr. Chris Stewart (the “Player”) of the

St. Louis Blues (the “Club”) for the matter of salary arbitration pursuant to Article 12.1(a) of the

2013 Collective Bargaining Agreement (the “CBA”) between the (the

“NHL”) and the National Hockey League’s Players Association (the “NHLPA”).

The CBA states in section 12.9(g)(ii) seven categories of evidence that is admissible in salary arbitration cases: the overall performance of the player in previous seasons; the number of games played in previous seasons and any injuries or illnesses; the length of service of the player in the NHL and/or with the Club; the overall contribution of the player to the Club’s competitive success or failure; any special qualities of leadership or public appeal; the overall performance of any player(s) alleged to be comparable to the Player and the compensation of any players alleged to be comparable.

As we will show in this brief, Mr. Stewart, due to the above factors, should be compensated with a salary of $3,900,000.

All statistics used in this brief are obtained www.nhl.com, unless otherwise noted.

Overall Performance of the Player Table 1: Chris Stewart Career Statistics Season GP G A P PPG +/- PIM TOI/G Hits 2008-09 53 11 8 19 0.36 -18 54 12:19 80 2009-10 77 28 36 64 0.83 4 73 16:41 100 2010-11 62 28 25 53 0.85 -6 53 17:29 56 2011-12 79 15 15 30 0.38 1 109 15:26 112 2012-13 48 18 18 36 0.75 0 40 15:49 41 Career Totals 319 100 102 202 0.63 -19 329 15:41 389 Mr. Stewart is considered a power forward and reached a career high in goals, assists and points in the 2009-10 season with 28 goals, 36 assists and 64 points in 77 games with the

Colorado Avalanche, for a points-per-game (“PPG”) of 0.83. This PPG was outdone the following season, where he had a PPG of 0.85. That season, Mr. Stewart was traded on February

1 19 from the to his current club, the St. Louis Blues. This trade resulted in a slight increase in his PPG, from 0.83 with Colorado to 0.88 with St. Louis.

In the 2011-12 season, Mr. Stewart posted his second lowest totals in all of the above statistical categories except for minutes and hits, both of which were career highs. This is odd, as a power forward is generally expected to post high penalty minutes and hits along with his point scoring prowess.

Consistency has been an issue with Mr. Stewart, as can be seen from his PPG totals in table 1. Further to these, in his platform season, a lockout-shortened season, Mr. Stewart scored 8 of his 18 goals and 15 of his 36 points in a nine game stretch, scoring the remaining 21 points over a total of 39 games. , the for the Club, has stated "I appreciate the statistics that he puts up, but at the end of the day… we'd like all of our players to have less peaks and valleys and more of a steady game. That [way], we're going to know what we're going to get every night."1 Mr. Stewart’s consistency issues extend further into the , where Mr. Stewart has only scored 6 points in a total of 19 playoff games.

Number of Games Played and Injury History Mr. Stewart has played a total of 319 games over five seasons, an average of 63.8 games a season. Mr. Stewart has battled injuries in the past, especially in the 2010-11 season where he missed 21 games with a broken hand. 2 However, Mr. Stewart played two full seasons in 2011-12 and 2012-13, although the latter was shortened to 48 games due to the NHL lockout.

Length of Service in the NHL and with the Club While Mr. Stewart has spent the last five seasons in the NHL, he has only spent 153 of his 319 games with the St. Louis Blues. In that time, Mr. Stewart has amassed 89 of his 202 points, resulting in a PPG of 0.58. This is a decrease from 0.68 PPG he averaged with Colorado.

1 http://blues.nhl.com/club/news.htm?id=678464 2 http://www.tsn.ca/nhl/teams/players/bio/?id=5722

2 Overall Contribution to the Club In his first season with St. Louis, Mr. Stewart played in 26 of their games after being traded to them in February of 2011. The Blues finished 11th in the Western Conference with 87 points, 3 spots and 10 points out of a playoff spot. In those 26 games, Mr. Stewart scored 23 points. The Blues went 12-12-2 after acquiring Mr. Stewart, a drop from their 26-21-9 record before the acquisition. Mr. Stewart finished 11th in team scoring and 9th among forwards on the team, as well as 6th in TOI/G, despite only playing 26 games.

The next year, which was his first full season with the Club, Mr. Stewart regressed from his previous two seasons, scoring only 15 goals and 30 points in 79 games. However, the St.

Louis Blues saw increased success under coach , finishing second in the Western

Conference with 109 points, only 2 shy of the President’s Trophy. This coincided with a reduction of Mr. Stewarts ice-time, from 18:16 the season prior when he joined the Blues, to

15:26. While this ice-time reduction could possibly explain a drop in points, it also shows Mr.

Stewart’s lack of contribution to one of the most successful seasons in recent team history. Mr.

Stewart finished 8th in team scoring and 6th among forwards, while being eighth in TOI/G.

In his platform season, the Blues finished 4th in the Western Conference with 60 points.

Mr. Stewart’s point totals rose to an average of 0.75 PPG, without a significant increase in ice- time. Mr. Stewart led the team in scoring, while being 7th among forwards in TOI/G.

While Mr. Stewart has attained both personal and team success in the regular season, his game has taken a dramatic step-back in all three of his playoff appearances, two of which were with his current Club. In 13 games with the Blues, Mr. Stewart has only scored 3 points. His

TOI/G dropped to 10:47 in 2011-12. Furthermore, in 2012-13, his TOI/G was eighth among forwards, worse than in the regular season, and he recorded just one assist in 6 games.

3 Special Qualities of Leadership or Public Appeal While special qualities of leadership are not quite as apparent since Mr. Stewart has had a fluctuating role with the Blues, he did lead the Club in scoring last year and had the best start to a

Blues Career in Franchise history with 6 goals in 5 games after his trade. These factors could add to his public appeal, however they should not warrant any special consideration for this matter.

Comparable Players Given Mr. Stewart’s overall performance, age, length of NHL service and contribution to his NHL teams, 2 notable comparable players will be discussed. Mr. Stewart’s worth is assessed with respect to each of these players below.

A) David Perron Mr. Perron signed a 4 year contract worth $15,250,000 with the St. Louis Blues in 2012, with an average annual value of $3,8100,000.3 Mr. Perron was 24 years of age during the offseason in which he signed his contract, 1 year younger than Mr. Stewart. Mr. Perron serves as an excellent comparable to Mr. Stewart, since both players are similar aged wingers that played for the same team during their platform years.

Table 2: Career Statistics Player GP G A P PPG +/- PIM TOI/G Chris Stewart 319 100 102 202 0.63 -19 329 15.41 David Perron 292 74 99 173 0.59 45 55 15.83 Table 3: Platform Year Statistics Player GP G A P PPG +/- PIM TOI/G Chris Stewart 48 18 18 36 0.75 0 58 15.49 David Perron 57 21 21 42 0.74 19 28 18.17 In 292 prior NHL games, Mr. Perron recorded 74 goals, 99 assists, and 173 points. Mr.

Perron’s 0.59 career PPG was lower than Mr. Stewart’s 0.63 career PPG. Mr. Perron’s platform year PPG of 0.74 was nearly identical to Mr. Stewart’s platform year PPG of 0.75.

A comparison of each player’s career PPG suggests that Mr. Stewart’s overall performance has been better than Mr. Perron’s. However, this ignores the fact that Mr. Perron’s

3 http://www.capgeek.com/player/962

4 performance was better in his most recent seasons. Mr. Perron recorded 0.64 PPG in the 150 games immediately prior to signing his contract, while Mr. Stewart recorded 0.57 PPG in his last

150 games. Furthermore, while Mr. Perron’s performance progressed at a relatively consistent rate, Mr. Stewart’s performance has been inconsistent and variable over the course of his career.

Table 4: Performance Progression Season 07/08 08/09 09/10 10/11 11/12 12/13 Chris Stewart PPG N/A 0.36 0.83 0.85 0.38 0.75 David Perron PPG 0.44 0.62 0.57 0.70 0.74 N/A Although Mr. Stewart performs quite well when at his best, his level of play drops by an extreme, unpredictable margin when he is at his worst. Mr. Perron’s progression and performance is far more predictable and exposes the signing team to a substantially lower level of risk.

Furthermore, since both individuals played for the St. Louis Blues, a very relevant comparison can be made in regards to their individual contribution to the team. Mr. Perron recorded a corsi of 2.81 during his platform season.4 This indicates that with Mr. Perron on the ice, the St. Louis Blues average 2.81 more attempts than their opponents and as a result, spend relatively more time in the offensive zone. During the same season, Mr. Stewart recorded a corsi of -0.11.5 This comparison is even more telling when considering Mr. Stewart’s quality of competition and zone starts. Comparing Mr. Perron’s corsi rel qoc of 0.827 to Mr. Stewart’s corsi rel qoc of 0.299 shows that Mr. Stewart also had the advantage of playing against weaker opponents.6 Furthermore, while Mr. Perron was entrusted with starting in the defensive zone

52.7% of the time, Mr. Stewart was only given the same responsibility 42.5% of the time.7 Not only does this indicate that Mr. Stewart’s defensive game was less trustworthy, but also that his

4http://www.behindthenet.ca/nhl_statistics.php?ds=30&f1=2011_s&f2=5v5&f5=STL&c=0+1+3+5+4+6+7+8+13+1 4+29+30+32+33+34+45+46+63+67 5 Ibid 6 Ibid 7 Ibid

5 contribution to the St. Louis Blues shot attempts was lesser than Mr. Perron despite Mr. Stewart having a significant advantage of beginning his shifts in the offensive zone more regularly.

Mr. Stewart’s unreliable defensive game is more evident when considering his inability to kill penalties. In the 2011-12 season, Mr. Stewart only played 0.09 shorthanded minutes per

60 minutes played by the St. Louis Blues, while Mr. Perron played 0.74 shorthanded minutes per

60 minutes played by the St. Louis Blues. Furthermore, in Mr. Stewart’s platform season he played 0.01 shorthanded minutes per 60 minutes played by the St. Louis Blues, which was the very least on the team. 8

B) T.J. Oshie Mr. Oshie and the St. Louis Blues signed a 5 year contract in 2012 worth $20,875,000, with an average annual value of $4,175,000.9 Mr. Oshie also serves as an excellent comparable to Mr. Stewart, since both players were 25 year old wingers playing for the St. Louis Blues during their platform years.

Table 5: Career Statistics Player GP G A P PPG +/- PIM TOI/G Chris Stewart 319 100 102 202 0.63 -19 329 15.41 T.J. Oshie 262 63 112 175 0.67 40 131 18.24 Table 6: Platform Year Statistics Player GP G A P PPG +/- PIM TOI/G Chris Stewart 48 18 18 36 0.75 0 58 15.49 T.J. Oshie 80 19 35 54 0.68 15 50 19.32 In 262 prior NHL games, Mr. Oshie recorded 63 goals, 112 assists, and 175 points. Mr.

Oshie’s career PPG of 0.67 was higher than Mr. Stewart’s career PPG of 0.63. However, Mr.

Oshie’s platform year PPG of 0.675 was lower than Mr. Stewart’s platform year PPG of 0.75.

Table 7: Performance Progression Season 08/09 09/10 10/11 11/12 12/13 Chris Stewart PPG 0.36 0.83 0.85 0.38 0.75 T.J. Oshie PPG 0.68 0.63 0.69 0.68 N/A

8 Ibid 9 http://capgeek.com/player/966

6 Mr. Oshie has been very consistent in his performance. On the other hand, as mentioned earlier, the high degree of variance in Mr. Stewart’s seasonal point production makes his impressive platform year PPG difficult to accept as a conclusive indicator for future production.

Furthermore, Mr. Oshie recorded a superior corsi, while facing tougher competition, and starting a higher portion of his shifts in the defensive zone, as compared to Mr. Stewart. Mr.

Oshie’s statistics for his platform 2011-2012 year are aggregated with the previous section’s findings of David Perron and Chris Stewart below.

Table 8: Contribution Statistics 2011-201210 Player Corsi Def. Zone Start % Corsi Rel QoC Chris Stewart -0.11 42.5 0.299 David Perron 2.81 52.7 0.827 T.J. Oshie 7.21 54.1 1.094 Mr. Oshie’s contribution statistics are superior to Mr. Stewart’s in every respect by even greater margins than are Mr. Perron’s.

It should be reiterated that the above contribution statistics were taken from the 2011-

2012 season, the platform year for only Mr. Perron and Mr. Oshie, since it allowed for the most optimally standardized comparison as all three individuals played for the St. Louis Blues during that year. However, a comparison can also be made using Mr. Stewart’s platform season by using each player’s platform season relative corsi figure. The relative corsi figures take into account any differences in quality that might exist between the 2011-2012 St. Louis Blues and the 2012-2013 St. Louis Blues since it is calculated by subtracting the team’s overall corsi without the player on the ice from the player’s individual corsi. The findings are below and Mr.

Stewart’s statistics are once again inferior to both other players.

10 Ibid

7 Table 9: Contribution Statistics Platform Seasons11 Player Corsi Rel Def. Zone Start % Corsi Rel QoC Chris Stewart 2012-2013 -8.1 45.4 0.672 David Perron 2011-2012 -3.7 52.7 0.827 T.J. Oshie 2011-2012 1.0 54.1 1.094 Mr. Oshie’s defensive game is also entrusted with killing penalties on a regular basis, unlike Mr. Stewart. In the 2010-2011 season, Mr. Oshie played 1.77 shorthanded minutes per 60 minutes played by the St. Louis Blues, while Mr. Stewart played 0.09 shorthanded minutes per

60 minutes.12

Valuation and Conclusion Mr. Stewart’s career PPG falls at the exact midpoint between the career PPG figures of

Mr. Perron and Mr. Oshie. The 0.04 difference between Mr. Stewart’s and Mr. Perron’s PPG figures suggest Mr. Stewart to be of higher value. However, this difference in value is nearly completely counteracted by Mr. Stewart’s inconsistency, inferior defensive game, and lesser contribution statistics. Therefore, Mr. Stewart’s salary should be very similar to that of Mr.

Perron. On the other hand, the 0.04 difference between Mr. Stewart’s and Mr. Oshie’s PPG figures suggests Mr. Oshie to be the superior player. In this case, while Mr. Stewart’s higher platform year PPG counteracts the difference in career PPGs to some degree, Mr. Stewart’s inconsistency, poor defensive game, and substantially weaker contribution statistics clearly affirm that Mr. Oshie is of higher value. Mr. Oshie’s superiority should at the very least be monetized at $375,000. Given Mr. Oshie’s average annual value of $4,175,000 and Mr. Perron’s average annual value of $3,810,000, the St. Louis Blues request that Mr. Stewart be awarded a salary of $3,900,000.

11 Ibid 12 Ibid

8