The only reason I think there should be a cap to the number of facilities you can submit for is to protect the FAA only sending new/direct hires to facilities with no ERRs. If they agreed to only send new hires to facilities with no ERRs, one person could be a wise guy and submit for everything as a screw you to the FAA. Only allowing 5/8/10 SHOULD protect for that.
I wholeheartedly agree with the logic behind your proposal, but not so much the execution. Being at a smaller facility, it definitely sucks to sit around, uneligible to be released for years because each person is worth 5-10%. And when your one shot every few years finally comes along, the higher level facilities you want to ERR to aren't picking anyone up because they've been picking up half a dozen direct hires every year. I don't think there should be a problem with peppering the top 50 on the priority list as long as that person accepts the ERR once they're selected. It's a natural progression; the longer you are stuck, the more open you become to working at more facilities just to get out and move on. But the people ERR'ing and turning them down multiple times, that's some evil BS.
I think a simpler solution would be:
-Limit declining an ERR to once during a certain time period (two eligible panels in a row, two panels in a 12-month span, whatever)
-After declining the second ERR, no longer eligible to file an ERR for a certain time period (a year, two years, whatever)
-Place direct hires and academy graduates at facilities with no inbound ERR's submitted.
-Place direct hires and academy graduates at facilities with outbound ERR's, up to however many CPC's have ERR's in*.
-Once the direct hire or academy graduate walks in the door at a facility with an outbound ERR, the CPC is given a release date equal to the average training time*.
-If the trainee certifies in less time than the average training time, the CPC can move their date up to anytime between certification and their original release date.
-All facilities can accept ERR's up to 100% staffing number.
-*(Since trainee's in most instances do not equate to 1 CPC due to washouts, there will have to be more than one new hire sent to the facility per CPC with ERR's in. Basically multiply the new hire's by the success rate and round up obviously to get the number of trainees to send.)
There's easy movement so people won't be as desperate to get out. Blocking others by declining every panel will be taken out. CPC's leaving the lower level facilities and being back filled with new hires is mostly assumed, but the same thing works for downward movement. CPC's leaving lower level facilities would just be filled with CPC's ERR'ing down from higher level facilities first over the new hires. The only problem is it'll never be considered because nation wide staffing won't necessarily be helped short term with all the guaranteed movement. The system kind of assumes your present staffing now is ok which obviously isn't the case in a lot of places. In a perfect world, it would work great. In the real world, giving all 130 CPC's at N90 a 2.08 year release date just because they brought in 300 ERR's/new hires isn't going to fly. The FAA would have to hire thousands of people like right now.