2013 HOCKEY ARBITRATION COMPETITION OF CANADA

Transcription

1 HOCKEY ARBITRATION COMPETITION OF CANADA Mats Zuccarello v. New York Rangers Submission on Behalf of New York Rangers Midpoint: $1.15 million Submission by Team 22

2 2 I. INTRODUCTION This brief will analyze the past output and contribution of Mats Zuccarello (the Player or Mr. Zuccarello ). Mr. Zuccerello is a 5 7, left-handed forward, for the New York Rangers organization (the Club or the Rangers ). 1 Mr. Zuccarello was signed to a two year entry level Standard Player Contract (SPC) with the Rangers on May 26, He later re-joined the Rangers on a one year contract commencing March 26, Mr. Zuccarello was 23 years of age on September 15, 2010, and has acquired more than 2 years of professional playing experience. Mr. Zuccarello is therefore eligible for salary arbitration pursuant to section 12.1 of the National Hockey League Collective Bargaining Agreement (CBA). 2 As will be apparent from the evidence presented below, Mr. Zuccarello is an expendable asset for the Rangers organization with limited playing experience and a diminutive physical presence. Mr. Zuccarello has not demonstrated that he is entitled to a salary exceeding the $1.15 million midpoint. The Club respectfully requests that the panel find for an award of $1 million. The CBA states that evidence of the following nature may be considered in determining a player s salary arbitration award: Overall performance of the Player in all seasons; the length of service of the Player; the overall contribution to the competitive success of the Club in the preceding season; any special qualities of leadership or public appeal; the overall performance of players alleged to be comparable to the Player whose salary is in dispute; and the compensation of players alleged to be comparable to the Player whose salary is in dispute. 3 This brief will consider each of these factors in presenting a case for the Player s salary arbitration award. II. OVERALL PERFORMANCE OF THE PLAYER A. CAREER PERFORMANCE NHL Collective Bargaining Agreement (CBA), 2005, s. 12.1(a)-(c). 3 Ibid, s.12.9(g)(ii)(a)-(g).

3 3 Table 1: Career Statistics for Mats Zuccarello 4 SEASON GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% (0.14) 17 (0.40) 23 (0.55) (0.20) 1 (0.10) 3 (0.30) (0.20) 5 (0.33) 8 (0.53) CAREER (0.16) 23 (0.34) 34 (0.51) Mr. Zuccarello s NHL career is best characterized by what he lacks the most playing experience. He has played in less than a third (31.6%) of the Rangers regular season games since joining the Club in He has posted passable offensive numbers at times (e.g., Point per game (P/G) averages of 0.55, 0.30, and 0.53 over the three previous seasons). He has failed, however, to demonstrate that he is capable of goal production over the long term with a dismal career G/G average of 0.16 (See Table 1). Furthermore, Mr. Zuccarello, at 5 7 is significantly undersized, based on NHL standards. Although Mr. Zuccarello does not refrain from engaging in physical play, his lack of size and strength limit his ability to do so effectively. 5 B REGULAR SEASON PERFORMANCE Table 2: Regular Season Statistics for Mats Zuccarello 6 SEASON GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% (0.20) 5 (0.33) 8 (0.53) Mr. Zuccarello returned to the Rangers on March 30 from an extended stint in the KHL. 7 His P/G average over the remaining season was 0.53 (See Table 2). Notably, the brief period Mr. Zuccarello committed himself to the Rangers makes it difficult to draw conclusions about his ability to perform for the Club in the future. For instance, his 3 regular season goals were scored

4 4 over a period of only three days (April 16-19), thus emphasizing his inconsistency. 8 During his 12 playoff games, Mr. Zuccarello produced 7 points for an average P/G of III. NUMBER OF GAMES PLAYED AND HISTORY OF INJURIES Mr. Zuccarello has participated in a career total of 67 regular season NHL games and 13 playoff games. Prior to , Mr. Zuccarello had played an average of 26 games per season an underwhelming 31.6% of total possible games for the Club. Mr. Zuccarello played only 15 games of his platform season in and 12 games during the playoffs. 10 During the regular season, Mr. Zuccarello played a total of 42 regular season games and one playoff game with an average time on ice (TOI) of 14:10 minutes per game. 11 During the regular season, Mr. Zuccarello played a total of 10 games with an average TOI of 10: Mr. Zuccarello sustained an injury on March 24, This injury caused the him to miss the remaining 8 games of the season and 20 subsequent playoff games. 13 Though he was declared ready to play in the Rangers final playoff game (Game 6 vs. The New Jersey Devils), the team chose not to dress Mr. Zuccarello for a game of such importance. In the regular season, Mr. Zuccarello joined the Club on March 30 and played a total of 15 regular season games and 12 playoff games with an average TOI of 16: IV. LENGTH OF SERVICE Mr. Zuccarello was signed as an undrafted free agent by the New York Rangers on May 26, 2010 Mr. Zuccarello subsequently played his first professional season in He 8 Ibid Ibid Ibid (CBA), 2005, s. 12.1(a)-(c).

5 5 has accumulated 3 years of professional experience during his tenure with the Rangers though he has not played for more than 51.2% of any given season. 16 V. OVERALL CONTRIBUTION TO COMPETITIVE SUCCESS OF CLUB In , the Rangers finished sixth overall in the Eastern Conference with a point total of 56 and a record of This is the third playoff berth the Rangers have secured since Mr. Zuccarello joined the organization. In , the Rangers finished first overall with a point total of 109 and a record of In , the Rangers finished in eighth place overall with a record of The Rangers decision to re-sign Mr. Zuccarello in stemmed primarily from a lack of offensive depth on the team. 20 It is unlikely that a player of Mr. Zuccarello s caliber would have received the same opportunity for playing time on a club with greater depth. From a performance standpoint, he does not have the skill to contribute in such a role, nor the playing experience to have earned a regular spot on a professional roster. While Mr. Zuccarello did exhibit a brief flash of offensive talent in his Platform year, it was brief (April 16-19) and occurred at a time when the Rangers were well-positioned in the playoff race. It would be an exaggeration to state that Mr. Zuccarello was an important factor in achieving a playoff berth in the season. In fact, Mr. Zuccarello has been a non-factor in the Rangers more successful seasons. In , the Rangers finished first in the Eastern Conference with Mr. Zuccarello sidelined by an injury. 21 His absence had no effect on the strong finish and although he declared himself ready to play, he was not dressed for the Club s final playoff game

6 6 VI. SPECIAL QUALITIES OF LEADERSHIP OR PUBLIC APPEAL At this point in his professional NHL career, Mr. Zuccarello has yet to demonstrate any significant qualities of leadership. While this may in part be due to lack of playing experience, Mr. Zuccarello will need to develop above average playmaking abilities to compensate for his small size. Competing at the professional level over the course of an entire season is another step Mr. Zuccarello will have to take to demonstrate that he is a valuable member of the Club. VII. COMPARABLE PLAYERS In order to adduce an arbitration award, it is necessary to determine comparable players to examine established salary benchmarks for players of similar skill. The following comparables described below were arbitration-eligible at the end of either the or seasons. The criteria deemed most appropriate for determining a comparable players is based on a combination of age, position, length of service, career statistics, and platform year statistics. 23 Accordingly, Cam Atkinson, Mathieu Perreault, and Nick Spaling function as the most accurate and valid comparable players for Mr. Zuccarello. For the purposes of comparison, salary will be discussed in terms of Average Annual Value (AAV). Table 3: Contractual Background of Comparable Players 24 Player Age Team Signing Date AAV of New Contract/Award ($) Mats Zuccarello 26 New York Rangers TBD TBD Cam Atkinson 24 Columbus Blue Jackets ,150,000 Mathieu Perreault 24 Anaheim Ducks ,050,000 Nick Spaling 24 Nashville Predators ,500, CBA s.12.9(g)(ii)(a)-(g). 24 All player salary information was obtained from:

7 7 Table 4: Career Statistics up to Platform Year 25 Player GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% Mats Zuccarello (0.16) 23 (0.34) 34 (0.51) Cam Atkinson (0.25) 16 (0.25) 32 (0.51) Mathieu Perreault (0.23) 26 (0.22) 53 (0.44) Nick Spaling (0.10) 21 (0.12) 39 (0.22) A. CAM ATKINSON Table 5: Platform Year Statistical Comparison 26 Player GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% Mats Zuccarello 15 3 (0.20) 5 (0.33) 8 (0.53) Cam Atkinson 35 9 (0.26) 9 (0.26) 18 (0.51) Cam Atkinson functions as a effective comparable player for Mr. Zuccarello. Both players are forwards of similar size and Cam Atkinson will be paid a salary of $1,150,000 per year (the same as the midpoint in the present case) beginning next season. Atkinson therefore provides a strong evidence for awarding Mr. Zuccarello an amount below the midpoint figure because he outperforms Mr. Zuccarello in several important ways. Atkinson is younger but has participated in more games than Mr. Zuccarello during his Platform season (See Table 5). Both players have played a similar number of career NHL games, though Atkinson has accumulated his playing time over a shorter period. Atkinson has also been judged to have high potential upside and a playing style that belies his smaller stature. 27 Atkinson and Mr. Zuccarello also generated similar P/G averages in their platform years at 0.51 and 0.53, respectively. Atkinson, however, has exhibited greater goal-scoring ability during his brief career (See Table 5). Overall, he has demonstrated offensive talent and hockey sense earlier, and more consistently, than Mr. Zuccarello. Taking Atkinson s performance as a benchmark for an award of $1,150,000, it would follow that based on Mr. Zuccarello s relative deficiency, an award of $1,000, 000 is justifiable. 25 All player statistics were cited from 26 Ibid. 27

8 8 B. MATHIEU PERREAULT Table 6: Platform Year Statistical Comparison 28 Player GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% Mats Zuccarello 15 3 (0.20) 5 (0.33) 8 (0.53) Mathieu Perreault (0.25) 14 (0.22) 30 (0.47) Mathieu Perreault also functions as an important benchmark for comparison. Mr. Zuccarello and Perreault had similar P/G averages in their platform years: 0.53 and 0. 47, respectively. Perreault, however, achieved this with deadly efficiency, at a shooting percentage of 26.7% more than doubling Mr. Zuccarello (11.1%). Mathieu Perreault also has the advantage of being younger and having played in 120 professional games compared to 67 for Mr. Zuccarello. Although Perreault is also physically undersized by NHL standards, he is still significantly larger than Mr. Zuccarello, standing at 5 10, 185 lbs. 29 This enables him to compete at a higher level physically, as evidenced by his superior career PIM 0.42 per game versus 0.27 per game (See Table 6). Mathieu Perreault therefore presents similar offensive statistics but greater size and a consistent track record despite young his young age. It follows that not only should Mr. Zuccarello be awarded a salary that falls below the proposed midpoint of $1,150,000, but his award should justifiably fall below Perreault s salary of $1,050,000 per season. Again, an award of $1,000,000 is justifiable in light of this comparable player analysis. C. NICK SPALING Table 7: Platform Year Statistical Comparison 30 Player GP G (G/G) A (A/G) P (P/G) +/- PIM PPG S S% Mats Zuccarello 15 3 (0.20) 5 (0.33) 8 (0.53) Nick Spaling 47 9 (0.19) 4 (0.09) 13 (0.28) Although Nick Spaling has played more total games than Mr. Zuccarello, he has only been in the NHL for one season longer. 31 Both players had similar goal-scoring numbers during 28 All player statistics were cited from All player statistics were cited from

9 9 their platform years Spaling had a G/G average of 0.19 while Mr. Zuccarello had an average of 0.20 goals per game (See Table 7). Spaling is also younger and has the potential to develop significant offensive talent. Moreover, Spaling kills penalties and has a very effective two way game both of these aspects of his game are partially because of his size at 6 1, 201lbs. 32 Therefore, while both players are currently similar in terms of offensive output, Spaling has the potential to eclipse Mr. Zuccarello in this respect. Where Mr. Zuccarello is primarily an offensive player, Spaling also has the ability and size to contribute as a two-way forward and a regular on the penalty kill line. Therefore, not only does Spaling match Zuccarello offensively in many ways, he also adds an entire dimension that Mr. Zuccarello is lacking. On this basis, Spaling s salary of $1,500,000 is understandable and appropriate. Since, Mr. Zuccarello cannot compete with respect to Spaling s physicality and defensive play, a proposed award of $1,000,000 is appropriate. VIII. CONCLUSION The Rangers respectfully submit that Mr. Zuccarello, based on past performance and comparable player analysis, merits an award less than the midpoint salary of $1,150,000. Mr. Zuccarello has not played or demonstrated that he is capable of playing an entire NHL season. As a primarily offensive forward he has not shown the requisite consistency to be compensated in line with comparable players. Finally, there are players who offer similar offensive numbers that are able to contribute defensively and in other ways that Mr. Zuccarello is not. We therefore submit that an award of $1,000,000 is appropriate