That IS my point. The company argues NOTHING.
Only APA and USAPA argue.
READ PARAGRAPH 10.(d)
My reference to the company having the Nicolau is only in respect to the validity of the award. The company accepted the award and has since never invalidated or rejected it. In fact, its still in court seeking guidance with regard to it. That doesn't sound like a dead document to me. The courts didn't invalidate it either and, in fact, stated that moving off of it required a LUP which I have yet to hear come from the union.
Leonidas sits on the sideline waiting for ripeness. That's not a secret to the company or the APA. The APA will submit their list using the Nicolau IMHO. It won't be long before I'm proven right or wrong.