Sounds to me like an excellent set of talking points. I still can't believe they do something as sensitive/critical as child custody/visitation using arbitration! If any situation calls for the court's "big guns" this is it.
I'd just go easy on stuff like "recovery looks like recovery"--that's great for us, but not necessarily helpful for the arbitrator. Try to stick to the facts, which are damning enough, and try to avoid commentary on what a recovery programs should look like, or what progress in recovery should look like. The bottom line is he is engaging in repetitive behavior that has NOT resulted in serious physical harm thanks only to dumb luck.
You got this.