We appreciate the opportunity for Local 514 to assist in this complex and arduous question. We will attempt to be succinct in what we believe to be the correct application of the award issued by arbitrator Fredric Horowitz on August 5, 2013.
“The affected employees are those in Tulsa, AFW, and DWH working directly in support of 757 Airframe Overhaul Operations.”
Relying on the “Summary Opinion” and the above language from the “Award”, Local 514 submits this “Position Letter” to aid in clarifying Tulsa members who should be included in the distribution of 757 portion of equity.
With the above language there should be no dispute that all employees who were assigned to Tulsa docks that were performing Heavy-C maintenance on the 757 aircraft during the time of contracting out will be included. This obviously would include support personnel who directly supported these docks (MLS, QC, QA, OSM, AC Cleaner, TCC, Parts Washer, Plant Maintenance etc.).
Since the dollar value of the settlement on the 29-d grievance includes associated support shop work, any shops that were supplying parts and/or components to the 757 Heavy-C docks, were “working directly in support”. This also would have to include support personnel for these shops.
The next reasonable step would include all members and support personnel who were assigned to 757 Light-C, Mods and Mid-Check docks in Tulsa, These docks were already staffed with 757 qualified employees. These docks could have quickly been reconfigured to perform Heavy’s. To transition these docks to Heavy-C work would also involve support from Plant Maintenance. Thus, undoubtedly Plant Maintenance was affected by this outsourcing and should be included.
The 757 aircraft which were scheduled for Light-C, Mods and Mid-Checks would have been reallocated to AFW and DWH. This is in agreement with Local 567 submission to the arbitrator dated June 26, 2013 page 2; “…AFW-3 (767 Heavy check/Special visit line) had four months of downtime…”and “…DWH-2 had numerous gaps (white space) that could have accommodated off loads of mod work from Tulsa to create capacity there…”.
In turn, the increased volume of 757 Heavy-C work performed in Tulsa means there would be an increased demand for the support shops to return parts to the docks. Shops that would normally only support inventory would now be tasked with “direct support” of the 757 Heavy docks as well. Therefore, any shop that was tooled up and performing work on 757 parts and/or components will naturally be included. This will also include support personnel as mentioned above.
Gary Yingst, Vice President
John Hewitt