Dismayed with the inability to secure a combined contract, and dissatisfied with past ALPA representation, certain East pilots formed an independent union, USAPA, to challenge ALPA as the pilots’ collective bargaining agent. USAPA campaigned on a platform of overcoming the negotiating impasse by constructing a new seniority integration proposal that would effectively preserve for East and West pilots the job opportunities generated by their respective operations. ((6ER1236:18-23) (4ER771-772)). In furtherance of this platform, USAPA adopted a constitution which established an “objective†of seniority integration based on date-of-hire principles modified by “conditions and restrictions†that would protect junior West pilots from displacement by preserving “each pilot’s unmerged career expectations.†(5ER930 § 8.D). The goal, as stated by USAPA founder Captain Scott Theuer, was preserving jobs so that “one year after the complete integration of this merger, no pilot, East or West, would be able to tell, based on his or her working conditions and status, that a merger had taken place.†((6ER1238:5-8) (6ER1245:8-12) (4ER772)).