NHL SALARY ARBITRATION

BETWEEN:

ONDREJ PAVELEC

– AND –

THE WINNIPEG JETS

BRIEF IN SUPPORT OF ONDREJ PAVELEC

Team 14

Salary Arbitration Between Ondrej Pavelec and The Winnipeg Jets

Introduction1

In accordance to the terms of the Collective Bargaining Agreement between the

NHL and the NHLPA set out in Article 12, Ondrej Pavelec of the Winnipeg Jets has elected to pursue salary arbitration to determine his compensation for the 2012-13 season.

Based on his on-ice play, his overall contribution to the team’s success, and his measure against comparable players, Ondrej should be compensated $4,000,000 for the 2012-13 season.

1) An Overview of Ondrej Pavelec’s Career

Exhibit 1 - Ondrej Pavelec Career Statistics GP W L OT GAA SV% SA SA/G MIN 2011-12 68 29 28 9 2.91 .906 2,036 29.9 3,932 2010-11 58 21 23 9 2.73 .914 1,705 29.4 3,225 2009-10 42 14 18 7 3.29 .906 1,353 32.2 2,317 2008-09 12 3 7 0 3.61 .880 301 25.1 599 2007-08 7 3 3 0 3.11 .905 190 27.1 347 NHL Totals 187 70 79 25 2.99 .907 5,585 29.9 10,421

Ondrej Pavelec is a 6’3, 220 lbs from the Czech Republic. At the time of this salary arbitration, Ondrej is 24 years old. The Atlanta Thrashers drafted Ondrej in the second round, 41st overall in the 2005 NHL Entry Draft. Ondrej has spent his entire

NHL career with the Atlanta Thrasher/Winnipeg Jets Organization.

Ondrej experienced his first NHL action in 2007, when he played seven games for the Thrashers. In the following year he played 12 games, before playing over half of the games in the 2009-10 season. In 2010–11 Ondrej moved into the role of starting

1 All statistics used, unless otherwise noted, are obtained from www.nhl.com

1 goaltender and in his platform year (2011-12) he has seen his number of games played rise to 68.

Ondrej has been a consistent performer since he came into the league. As a result of his high-end performance, his number of games played has rose steadily year after year. a) Injury – October 8th 2010 On-Ice Collapse

Exhibit 2 – Ondrej Pavelec Comparison Pre and Post Injury GP W L OT GAA SV% SA SA/G MIN One Year Pre Injury 42 14 18 7 3.29 0.906 1353 32.2 2317 One Year Post Injury 58 21 23 9 2.73 0.914 1705 29.4 3225

On October 8, 2010, Ondrej lost consciousness during a game, and was required to be taken off the ice by a stretcher. The injury was later diagnosed as a neurocardiogenic syncope, a common type of fainting spell. Moreover, Ondrej suffered a concussion by hitting his head on the ice as he collapsed. While Pavelec was released from the hospital on October 11, 2010, he was sidelined until October 30, 2010 with a concussion. 2 Even though a concussion presents serious uncertainty towards future injury, it is not as worrisome for a goaltender as they do not endure the same level of contact as forwards and defensemen in the NHL.

As shown above, Ondrej’s statistics are better after his injury. Moreover, Ondrej has never had a second concussion since his recovery. By being able to jump back into action after an injury, Ondrej demonstrated dedication to the Jets, and perseverance, as he did not allow the injury to affect his performance or skill level.

2 http://www.nhl.com/ice/news.htm?id=540225

2 2) Platform Year – 2011-112

Exhibit 3 - Ondrej Pavelec Platform Year Statistics GP W L OT GAA SV% SA SA/G MIN Ondrej Pavelec 68 29 28 9 2.91 0.906 2036 29.9 3932

Section 12.9(g)(ii)(D) of the CBA states as evidence that may be offered; the

“overall contribution of the Player to the competitive success or failure of his Club in the preceding season.” This sentence provides quite an accurate depiction of Ondrej’s role on the team this past year. Ondrej’s was a workhorse for his coaches during his platform year. His 68 games played has him ranked tied for fifth most among NHL .

Furthermore, Ondrej does not have the benefit of playing in front of an elite defensive corpse on the Jets. The 2036 shots faced by Ondrej was the 5th most in the league.

Ondrej also faced more shots per game than goaltender, Pekke

Rinne, who lead the league in shots against. Ondrej has proven to be a reliable and durable starting goaltender, and his salary should be reflective of this.

3) Searching for Comparable Players

The use of recently signed contracts by comparable players is used to best reflect the current NHL marketplace. In attempting to search for comparable players, Ondrej presents a unique situation, as there are no true comparable goalies that have signed contracts recently. Nevertheless we will provide the most comparable goaltenders to be used as benchmarks when determining his salary. Goaltenders Cory Schneider and

Devon Dubnyk both signed contract this summer. Even though neither goaltender has played the role of starting goaltender, their recently signed contracts shed light on the current NHL market value for goaltenders.

3 a) Comparable Player: Cory Schneider

Platform Year

Exhibit 4 – Ondrej Pavelec VS Cory Schneider Platform Year Statistics Player GP GS W L OT GAA SV% SA SA/G MIN Ondrej Pavelec 68 67 29 28 9 2.91 0.906 2036 29.9 3932 Cory Schneider 33 28 20 8 1 1.96 0.937 945 28.6 1833

At first glance it appears that Cory obtained significantly better statistics than

Ondrej. Not only did Cory have a better winning percentage, but he also registered significantly higher goals against average and save percentage despite only facing an average of one less shot per game. However, when these statistics are further analyzed, it becomes evident that Ondrej is more important to his team, and Cory’s statistics are inflated.

Exhibit 5 – Ondrej Pavalec VS Cory Schneider GP By Tier Ondrej Pavalec GP Cory Schneider GP Top Tier 22 7 Middle Tier 22 8 Bottom Tier 24 18 *Tiers are calculated in thirds based on winning percentage of opponents played during the year

The first evidence that Ondrej is more important to his team stems from his games played. Not only did Ondrej play (and start) more than double the amount of games than

Cory did, but he also ranked fifth in the entire NHL in games played. Furthermore, while

Ondrej seemed to play in an equal distribution of games against opponents of various rankings, Cory was more frequently dressed against the bottom tier of the NHL. This further laments Cory’s position as ’s backup goalie.

4 Exhibit 6 - Ondrej Exhibit 7 - Cory Schneider Pavelec Platform Year Platform Year

21% GP 33% GP 35% GP 0.909 SV% 0.914 SV% 0.893 SV% 55% GP 29.9 SA/G 27.2 SA/G 32 SA/G 0.940 SV% 28 SA/G 24% GP 32% GP 0.953 SV% 0.912 SV% 29 SA/G 30.9 SA/G

Top Tier Middle Tier Bottom Tier Top Tier Middle Tier Bottom Tier

By breaking down both Ondrej and Cory’s statistics based on the quality of their opponents it becomes evident that Cory’s save percentage is inflated as a result of playing a majority of his games against weaker teams. Cory did have an impressive save percentage of 0.937 in his platform year, which was the second best in the NHL.

However, when he faced top tier opponents, Cory’s save percentage dropped to 0.909, a large deviation from his platform year average. When compared to Cory, Ondrej’s statistics are less inflated based on his opponents. When facing top tier opponents,

Ondrej experienced only a slight deviance in save percentage from his platform year average of 0.906.

5 Career

Exhibit 8 – Ondrej Pavelec VS Cory Schneider Career Statistics Player Seasons GP W L OT GAA SV% SA SA/G MIN Ondrej Pavelec 5 187 70 79 25 2.99 0.907 5585 29.9 10421 Cory Schneider 4 68 38 17 4 2.24 0.928 1880 27.6 3639

Exhibit 9 - Ondrej Pavelec VS Cory Schneider Goal Support Per Game Ondrej Pavelec Cory Schneider GP Goal Support Per Game GP Goal Support per Game 2011-12 66 2.89 36 2.94 2010-11 57 2.75 30 3.03 2009-10 42 3.02 2 3.00 2008-09 12 2.73 8 3.00 2007-08 7 3.50 - - Total 184 2.89 76 2.99

Throughout their careers, Cory outperforms Ondrej in almost every statistical category. However, Cory had the benefit of playing behind a much better team – the

Vancouver Canucks. The Canucks finished with the most points in the league over the past two regular seasons, while the Jets have finished 22nd and 25th after the 2011-12 and

2010-11 regular seasons. In addition to facing lower quality teams, Cory’s total wins numbers benefited from the fact that he received more goal support per game throughout his career than Ondrej.

6 Contract

Exhibit 10 - Ondrej Pavelec VS Cory Schneider Contract ($) Cap Hit 2011-12 2012-13 2013-14 Ondrej Pavelec 4,000,000* 4,000,000* Cory Schneider 4,000,000 3,500,000 4,000,000 4,500,000 *Requested Contract Value

Ondrej Pavelec is requesting a one year, $4,000,000 contract from the Winnipeg

Jets. Despite Cory outperforming Ondrej overall, Cory has never participated in a full

NHL season as a starting goaltender. Moreover, Cory had the benefit of facing worse opponents throughout his platform year. This number takes into consideration a premium that must be paid for a bona-fide and proven starting goaltender.

Comparable Player: Devon Dubnyk

Platform Year

Exhibit 11 – Ondrej Pavelec VS Platform Year Statistics Player GP W L OT GAA SV% SA SA/G MIN Ondrej Pavelec 68 29 28 9 2.91 0.906 2036 29.9 3932 Devan Dubnyk 47 20 20 3 2.67 0.914 1380 29.4 2653

Devon had slightly better statistics that Ondrej in his platform year. While facing approximately the same amount of shots against per game, Devan posted better goals against average and save percentage than Ondrej. However, the key difference between

Ondrej and Devan is that Ondrej has proven to be a reliable starting goaltender.

Throughout the 2011-2012 NHL season, Devan split time with .

Therefore, it is unclear how Devan would handle the workload of a starting goaltender in the NHL.

7 Career

Exhibit 12 – Ondrej Pavelec VS Devan Dubnyk Career Statistics Player Seasons GP W L OT GAA SV% SA SA/G MIN Ondrej Pavelec 5 187 70 79 25 2.99 0.907 5585 29.9 10421 Devan Dubnyk 3 47 20 20 3 2.67 0.914 1380 29.4 2653

When analyzed over the entirety of both Ondrej and Devan’s career, the same conclusions can be made as in their platform years. The stark difference between both players is that, despite being one year younger, Pavelev has significantly more NHL experience than Dubnyk, and has been a starter for two NHL seasons.

Contract

Exhibit 13 – Ondrej Pavelec VS Devan Dubnyk Contract ($) Cap Hit 2011-2012 2012-2013 Ondrej Pavelec 4,000,000* 4,000,000* Devan Dubnyk 3,500,000 3,250,000 3,750,000 *Requested contract value

Ondrej Pavelec is requesting a one year, $4,000,000 contract from the Winnipeg

Jets. While Devan is slightly better than Ondrej on a statistical level, Ondrej has much more experience than Devan. This number takes into consideration a premium that must be paid for a proven starting goaltender.

Conclusion

Throughout Ondrej Pavelec’s career, he has proven to be a consistent goaltender.

Moreover, Ondrej has evolved into a bona-fide starting goalie in the NHL, as shown by an increase in games played every year of Ondrej’s career. In Ondrej’s platform year, he was one of most utilized goalies in the NHL, as he played in the fifth most games among all goaltenders. Furthermore, Ondrej faced the fifth most shots against in the NHL during his platform year, further cementing his importance to the Winnipeg Jets.

8 With respect to comparable players, Ondrej is asking to be compensated as an equal to Cory Schneider. Although Cory has better career statistics that Ondrej, Cory has been sheltered by the , starting a majority of his games against bottom tier NHL teams. Moreover, Cory has never been a starter in the NHL, and it is unknown how he will perform with the added workload and pressure.

Even though Ondrej has similar statistics to Devan Dubnyk, Ondrej has a lot more

NHL experience. Since Devan has never been an NHL starter, Ondrej deserves a premium of $500,000 on the average annual value of his contract since Ondrej has proven to be able to perform as a starting goaltender.

Based on Ondrej’s consistent performance, his importance to the Winnipeg Jets, and his emergence as a bona-fide starting goaltender in the NHL, Ondrej Pavelec is asking for a contract worth $4,000,000 over one year.

September 17, 2012 All of Which Is Respectfully Submitted,

On behalf of the Winnipeg Jets Hockey Club

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