FAA To Southwest: Here, Hold My Beer


No sooner had my trickle of Southwest Airlines memes dried up then a whole new batch flooded in like a digital version of an atmospheric river from the sodden Pacific. This time, it was the failure of the NOTAMs system. Shocked was I to learn that (a) so many people didn’t know that it’s now Notices to Air Missions, not to Airman and (b) that a single misplaced 0 or 1 could take down the world’s most efficient and safe airspace system that (c) turns out to be neither. Well, OK, it’s safe at least. I was less shocked that no one sitting around the FAA table when Airmen became Missions didn’t say, “People, this is ^%$#*& stupid, we’re not doing it.” (And let’s just stop blaming ICAO for all this.)

Playing a round of my favorite memes here, I’m not surprised how derisively pilots treat both the basic concept of NOTAMs and the broken, all-but-useless system it has become. Former NTSB chairman Robert Sumwalt gained cheers in 2017 when he called NOTAMS “a bunch of garbage that no one pays attention to.” He was right, but thanks to statutory accretion, the airlines are wedded to them like white on rice and without access, they can’t dispatch. Or if they can dispatch, the FAA seems to think it can’t operate the National Airspace System with NOTAMs cratered.

One flyspeck detail that GA pilots may have missed is that under Part 91, we’re technically wedded to NOTAMs, too. In the Preflight Action section of 91.103 is this: “Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight,” then it lists the basic stuff you’re supposed to know. If the airlines don’t have it, they can’t dispatch and if GA pilots don’t have it, a defense that NOTAMs were down probably wouldn’t cut it if you, say, blundered into a TFR and caught a Blackhawk intercept. (TFRs have their own system, but you get the point.)

Angels and pinheads, maybe, but the whole system is badly designed and executed. It presents a gusher of useless information that you don’t need and obscures what you do need in reams of impenetrable government speak and statutorily approved abbreviations. That was the root of what Sumwalt was complaining about, following the July 2017 incident in which an Air Canada A320 nearly landed on a taxiway populated with waiting airliners at San Francisco International. NOTAMs were implicated because one describing the closed runway was buried in multiple pages of irrelevant blather. A potentially horrific accident was narrowly averted.     

“NOTAMs contain dozens of notices of varying importance, such as closed taxiways, wet runways, and small, unlit towers miles from the airport,” NTSB vice-chairman Bruce Landsberg said at the time.  “Information about closed runways, however, is critical. From a human factors perspective, we found that the presentation of information in the NOTAM the crew received did not effectively convey the information about the runway closure.”

The FAA is supposedly modernizing the NOTAMs system, but it’s not known if this week’s outage was related to that. One goal of this is more seamless machine-to-machine linking so users like airline companies can tap into the data river reliably. Any IT professional will tell you that there’s a certain amount of breath holding when system upgrades go live. As for the presentation of NOTAMs, I don’t know about you, but I haven’t noticed much difference. The only thing I look for are closed airports and runways. I don’t give a fig about an unlighted tower 2.6 miles north of the airport and I’ll deal with the closed taxiway after I land. And don’t get me started on all the crap that towers sometimes cram into ATIS broadcasts to no particular benefit to a lone pilot who’s just trying to see the airport and keep frequencies sorted out. The apps I’ve dealt with do a decent job of organizing NOTAMS, but there’s still just too much verbiage in them.

The larger issue is system resilience. During the Southwest debacle, we learned that the company’s business continuation plan was either nonexistent or utterly inadequate. This week, in a New York Times interview, Southwest CEO Bob Jordon admitted the company “messed up,” but he gave the impression that its crew scheduling system was using updated software from GE. The pilot and flight attendant unions beg to differ and insist the company simply refused to invest in upgraded technology. But it did spend $5.6 billion on stock buybacks. If you consider results not related to stock price, Jordan’s mea culpa clangs hollow like an empty steel drum. And the stock price ain’t all that good, either.  

I am old enough to remember the dawn of airline deregulation. I covered it early in my newspaper career. It would, proponents said, democratize air travel by promoting competition, lowering fares and encouraging innovation. This all turned out to be true, but it also ushered in the era of cattle car flying with gracefully eroding customer service. Don’t like 29-inch seat pitch and paying for use of overhead space? Thank deregulation, but at least you have fare competition and choices, even if many of them share the same lousy features.

There’s painful cognitive dissonance here. Things were not always rosy during the regulated period. Airlines still went bankrupt, schedules slipped, bags got lost, crews were timed out or out of place, but at least you could get a decent lunch on board and you didn’t have to stare at someone’s butt crack because no one would think to wear a running suit to fly to Chicago. Overall, the regulated system was more civilized.

Was government more competent then? Maybe. But companies—not just airlines—weren’t as rapacious then as they are now; the age of the stockholder as king to the customer’s serf was still more than a decade away. If we didn’t like the government meddling in airline transportation, we at least accepted it for the benefits it bestowed.

Now, it has become an absolute fetish to decry any kind of government regulation or oversight of business. Of course, we get something for that, like an Apple or a Microsoft or a Tesla, but also an Enron, a Lehman Brothers, an FTX and yes, a Southwest Airlines. If they beach you for five days and lose your luggage or strip you of half your life savings, well, sorry about that. You signed the waiver.

Southwest’s board has evidently deemed it prudent to keep Bob Jordon on the job with a salary reported to be around $9 million, so if there was accountability for the Christmas meltdown, the C-suite so far has dodged it. But what about the FAA? The agency’s lack of a resilient NOTAMs system with a backup essentially shut down the $100-billion U.S. airline system for almost half a day.

Reason? The FAA blames personnel not following procedures but Laurie Garrow, a specialist in aviation at Georgia Tech, told USA Today that aging tech may be the smoking gun. “Similar to what Southwest saw last month with difficulties in using an antiquated system to handle a major weather disruption to the system, it’s highly likely that the FAA saw this problem exacerbated because they were running on older technologies,” Garrow said. If heads have rolled, they apparently missed the baskets because so far, we see no accountability there, either.

What’s to be done, the world wonders? Like it or not, the government has to stir the drink here. In my view, the Department of Transportation needs to enforce more aggressive rules on terms of carriage related to refunds and reimbursements and baggage handling. It has been reported that millions of dollars in refunds due to passengers have been delayed. DOT needs to enforce fines for these service refusals so there’s at least some accountability. And make the fines substantial. And somehow, some way, give the customer the choice of a voucher or cash.

Expecting the free enterprise system to magically correct this is sheer delusion. As long as companies like Southwest see stock buybacks as more important than infrastructure investment, they’ll continue to be a beat or two behind their customer’s needs. Delta, American and United recovered quickly, but one Delta pilot I know said they got lucky.

As for the NOTAMs fiasco, well, good luck to us all. Maybe the GAO can wade into it and make a fair determination of what really went wrong. If it was aging technology, I suspect the federal government’s byzantine acquisition regulations might somehow be involved. Getting congress on the case is almost too depressing to contemplate, but that’s what it might take.

Somehow loosening the coupling of NOTAMs distribution from airline dispatch might be another place to start. It’s no kept secret that Robert Sumwalt was right. Nobody pays attention to the damn things anyway, but their importance punches above their weight because of statutory stranglehold by international agreement. So change the rules. This is a persistent weakness in the internationally agreed-to rules regarding passenger carriage. If Europe invests in state of the art NOTAMs distribution and the U.S. limps along, the entire system is hobbled. And speaking of money, Delta’s CEO Ed Bastian thinks the FAA needs more of it to throw at fixing NOTAMs.

I’m beginning to wonder if the modern transportation grid has become just too complex, too chaotic and with too little reserve capacity and management expertise and with investment requirements totally out of balance with needs to avoid periodic collapses in the face of extreme weather events that are more normal now than novel.

Lately, a 100-knot Skyhawk is looking attractive again, even if it takes a week to get there. Or maybe Greyhound.

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  1. Part 91 operators wedded to NOTAMS? 91.103 requires all ‘available’ information to be known. System down = unavailable?
    Time for the FAA to be accountable for something….

    • Yep … if it’s good for the goose … it’s good for the gander, too !! The huge bureaucracy that’s holding pilots and other customers hostage for dotting the ‘I’s’ and crossing the ‘T’s’ need to be held accountable itself. That they’re now having to be forced by language in Amendments to lawmaking in order to do its job is borderline crimminal. And the pay of those people who are not doing the job needs to go down … they’re highly overpaid.

    • 18 months from now, after spending untold amounts of man hours and dollars, the FAA will fix that clause so that it absolves them of any responsibility in the process.

      Who wants to bet the NOTAM system will still not separate the deadly from the inane?

    • I agree completely in spirit. And, if the FAA were a company you were fighting in court for breach of contract, I’d say you had a good, fighting chance.

      But, here, it’s different. The FAA makes the rules, selects terms and assign definitions to those used in the rules, and interpret all of it when (and how) it best serves them (or the politicians controlling them). My point being, on any given day the NOTAM system probably won’t matter to a lowly Part 91 guy (like me). But, manage to foul up in a way that gets the FAA’s attention while it is down and I don’t think the fig leaf of “available” will cover you much.

  2. My experience with computers is that the f#$&ups occur during the update/upgrade process. I’ll bet making the old Notam system compatible with newer insufficient tested software with no backup caused the problem. The FAA grounding everything because of this is inexcusable. The Canadians were able to work around their Notam issue without shutting down their airspace. Granted Canada does not have the traffic the US does, but they do take search and rescue rules much more seriously.

    • I have always heard it said… (and will paraphrase as young eyes may be watching)… “To Error is Human”: “To really ‘Screw’ Up requires the use of a Computer” – there is a lot of truth to that…

      I am surprised they have not changed the Tower and ATC Controllers to ‘AI’ to save money! I mean really… What could go wrong with a plan like that… 🙂

    • My experience tells me the support contracts involved with the old hardware and software were very likely so expensive that they were losing money by not upgrading sooner.
      The problem is less about how much money is available, and more about the byzantine rules and managing it. And, if you like your government job, you don’t point out how the folks at the top never seem to do anything to really fix the system which everyone agrees is broken.

  3. As far as the Southwest issue is concerned, as long as the airlines sell tickets months ahead of time and then at the last minute cannot fly for whatever reason, it is difficult to have any sympathy for that airline. Have to be careful on the updated software issue. I have seen and had to deal with updated software that worked certain crews and airplanes to the legal limit while other crews sit for extended time doing nothing. On the other hand if passengers are dumb enough to play the advanced ticket purchase game, you get what you pay for. On those now extremely rare occasions I airline on my own dime, I do purchase the better seats or go first class.

  4. Pre deregulation flying was much more expensive than today. If you want the old time experience buy a first class ticket. It will cost you what an economy ticket used to cost and give you pretty much the same seat pitch, and complementary meals and drinks as what used to be economy.

    Airline flying is the very definition of you get what you pay for.

  5. What hear from the headlines is “the system has been running reliably for decades. How do we fix it?” It’s similar to the complaints of the general public makes after an incredibly rare aircraft accident. I agree that the actual NOTAM data is broken, but instead of asking “how do we fix the software?,” I think it’s more interesting to ask “how did the original engineers design a system that ran reliably for so long until now?” and “how can we make any new system as reliable?” I suspect the right answer is to keep it simple. In fact, that applies to both the system and the data.

    BTW, I am apparently the only person who actually does read NOTAMs on my long flights. We’ll, OK, I “scan” them.

  6. It’s interesting to compare and contrast the administration’s response to these two fiascos. When Southwest blew a gasket, stranding its customers all over the country, the response was swift and unflinching. “Southwest Airlines failed its customers. Point blank. The Department of Transportation will hold them accountable to their commitments to make their customers whole,” said the WH Press Sec. When the NOTAM system went down, stranding ALL passengers all over the country, she said the FAA had imposed a ground hold to “save” all those poor people from the catastrophe of flying without “critical” safety information contained in the NOTAMs. Get that? Southwest “failed,” while the FAA “saved.” There was no mention, of course, about who will make whole all the customers “saved” by the FAA.

    This highlights the difference between corporation/customer relationships and government/citizen relationships. Both represent an imbalance of power–the individual is far overshadowed by the goliath–but at least in a competitive market customers have choices. We can simply choose to fly on a different airline that doesn’t fall apart every time the weather turns sour.

    What is the alternative to the FAA?

    Well, we can write to our representative and complain. And if they don’t do anything we can vote them out. Of course, you’ll have to do some research and make sure the person you vote for supports changes to the FAA you agree with. That’s assuming, of course, that you can find someone who hasn’t been influenced by people with more money than you who want something entirely different. Then there’s this: What exactly IS the change? How do you even impart that knowledge to a congresscritter who likely knows absolutely nothing about flying to begin with? And then, assuming you are somehow able to get your congresscritter to understand the issue, they become a single voice among 435, all of whom are beholden to some constituency or other that may or may not agree with your desired changes.

    Yeah, we definitely need to get congress involved in “fixing” Southwests’ problems. Definitely.

    • Well put. Amazing how no one seems to ever link many of today’s issues with members of the House voting to stop the growth of their own numbers due to them feeling crowded. Now, you chance of seriously speaking to your Congressman has become virtually nil.
      Paul’s excellently written and titled piece makes the common, bipartisan mistake of assuming time would not have made a worse mess of the contra factual. Without deregulation, we might have AmAir to go along with AmTrak.
      Any serious discussion on how to get airlines to compete on service again would be appreciated, though I want a rule where any discussion about “deregulation” has to note there is still massive regulation which is bound to cause similarities in the services.

  7. Thank you for citing 91.103. Since the stoppage, that “all available information” has been rattling around in my head, but I hadn’t pulled out the FARs yet. I’d like to have back the hours I spent reading about construction cranes operating somewhat near an airport with runways too short for me to use anyway, etc. I suspect that is motivated by the FAA wanting to shift any possible blame to pilot, so tons of mostly marginal information ends up in the system. Well, humans have finite usable memory and thus prioritize information. Those who load the NOTAM system may be in a better position to prioritize than someone who might be copying a clearance while weather is coming in.
    I do want to point out that stock buybacks are not likely to go away no matter how many people flog the idea. Sure, stock buybacks help mostly those at the top and are responsible for much of the compensation difference between those who make the system work and those who carry the royal scepter and were the mechanism to create many of the billionaires who became wealthy in the last 30 years or so BUT this class of people knows how to spread money (and sometimes business insight) to the right campaigns. That is an old story.

  8. “One flyspeck detail that GA pilots may have missed is that under Part 91, we’re technically wedded to NOTAMs, too. In the Preflight Action section of 91.103 is this: “Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight,” then it lists the basic stuff you’re supposed to know. If the airlines don’t have it, they can’t dispatch and if GA pilots don’t have it, a defense that NOTAMs were down probably wouldn’t cut it if you, say, blundered into a TFR and caught a Blackhawk intercept. ”

    Would be interesting to see that one play out. I suspect the whole case would hinge on the word “available”.

  9. “And speaking of money, Delta’s CEO Ed Bastian thinks the FAA needs more of it to throw at fixing NOTAMs.” I agree with the Delta CEO except for one small detail. I don’t think they need more money to spend on fixing NOTAMs; I think they need to spend more of the money they ALREADY HAVE fixing NOTAMS.

    As an (increasingly ashamed) government drone myself, I can (with confidence) say that updating everything to change “Airmen” to “Air Missions” (among other related changes) cost plenty in terms of both time and money. And, since we are being honest here, can we all admit that no one (mentally-stable enough to be flying) cares (much less states) what NOTAM stands for outside of an FAA written or oral? I’m pretty sure most of us would choose a better NOTAM system over a more progressive NOTAM definition 9 times out of 10.

  10. Yeah, well, Southwest needed to update their crew tracking and comms systems, but the same people complaining about stock buybacks and CEO pay while pining for the good old days could not afford to fly pre-deregulation. The real changes in fares didn’t take hold until the early 1990’s when Bob Crandall’s Value Pricing was blown up by Northwest, and fares dropped and aircraft filled up.

    The reason airlines don’t have spares everywhere and redundancies is that everything about airline operations- from capital expenditures, fuel, labor, financing, fees, regulatatory hurdles, is enormously expensive. Airline operational profit margins are minimal in the best of times, so the Woke “Greed” screeds ring hollow.

    Bottom line is that there is a massive difference between what customers say they went, and what they are willing to pay for.

  11. Agree with how difficult it is to sort through the junk to get what you really need. One of my favorites is on flights from Phoenix to Long Beach the FAA finds it important for me to know about the restrictions for activity at White Sands Missile Range – 300nm behind me as I take off going to SoCal. Worthless, timewasting and causes skimming the list hoping you will see anything that really matters for your specific flight.

  12. Coming from an en route ATC background, our system ran on two channels. Channel B, and A as a backup, and each channel had two back up computers to run the channel. At some point, I recall we went to one back up per channel to, of course, save money.

    It wasn’t uncommon back in the day to have the system taken down overnight for an update, be told that it’ll be back at 3am, then 4am, then 5am, then 6am and finally we’d get a “We’re reverting to the old system” because the East Coast was starting to gear up headed West.

    Time moves too quickly for the FAA. Too many plugs into one outlet.

  13. Another example of a government failure (NOTAM) that now insists on more money. You’d think $18B would be enough, nothing another few billion wouldn’t fix.

  14. The problem started when the FAA dropped classification of NOTAMS as Local, Distance or FDC.

    My employer has sorted NOTAMs into categories on the flight plan paperwork. Definitely helps finding pertinent info.

    How do other countries present NOTAMs?

  15. “One flyspeck detail that GA pilots may have missed is that under Part 91, we’re technically wedded to NOTAMs, too. In the Preflight Action section of 91.103 is this: “Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight,” then it lists the basic stuff you’re supposed to know.

    For us 91 folks, I think the keyword in the above is “available”. If NOTAMS are not available, then how do you become familiar with them?

    • I think you would have a hard time explaining if you landed at at closed airport (for instance) because the NOTAM system was down, just as you would have a hard time explaining why you got stuck above a cloud layer because you couldn’t get current weather data.

  16. I suspect that the FAA, under the current legal environment, would be very careful about busting anyone taking a VFR flight without NOTAMS. SCOTUS is suddenly less impressed with autocratic bureaucracies. “This is how we have always done it” and “We made it a rule”, are now not an automatic win against a claim of unreasonable and one sided systems.
    I suspect the new plan to protect the agencies is avoiding cases that would normally be won using Chevron.

  17. I’m always amazed by Bertorelli’s bon mots in his writing. Example: “What’s to be done, the world wonders?” The “world wonders” phrase was “padding” in an encrypted message from Adm. Nimitz to Adm. Halsey during WW II–“Padding” was simply extra language inserted into a message to confuse enemy code-breakers. Halsey saw the unencrypted message, and took it as a rebuke from Nimitz–and in rushing to make up time and distance, ran his escort ships out of fuel.

    Bertorelli didn’t have to put this obscure phrase into the article–though famous then, few would recognize it today. By casually tossing out this phrase, Bertorelli is letting us know that HE is aware of something much of the world does not. It is one of the reasons I admire Paul’s writings. That’s why this column appears in “AvWeb INSIDER.”

    • Yeah but ‘breaking the code” is part of the fun, Jim. He’s probably got a book of those ideas somewhere in his cave?

  18. Regarding the meme about “unlit small towers located miles from an airport”–just how high must an unlit tower be, and how proximate to an airport before a NOTAM is required? We have a field of about 25 wind towers, located 6 miles from the airport–if ONE of them has a light out, is there a requirement for a NOTAM? I certainly HOPE NOT!

  19. I think everyone here has missed the point. The fundamental problem that needs to be addressed is to determine who was responsible for the FAA’s failure to send a NOTAM advising that the NOTAM system was down.

  20. A few years ago (about the time they screwed all the students in ATC college courses) the FAA announced that they would no longer weight technical education and experience as heavily as they used to. Instead they would look for ‘people skills’ and ‘diversity’.

    With the FAA now run by a Diversity Hire Poster Boy (To be fair to Mayor Pete, I don’t think he steals luggage, and I’ve read that ‘White Cis Gay Men’ are almost as evil as just plain white men) you know the hiring situation as deteriorated since then.

    I suggest making Elon Musk the head of the FAA. With full power to hire and fire as he sees fit.

    The FAA doesn’t need more money. It needs to ensure it hires people qualified to run safety systems and it doesn’t need mangers for managers of managers and enough power points to line up and reach to the moon. Any CRT training needs to cover cathode ray tubes, not organizing a victim hierarchy.

    • Jim, your comment directly ties into the ‘WHY?’ that the NTSB/FAA are pushing the Safety Management System (SMS). The SMS is not designed to train and protect the qualified self-motivated but, focus on the ones that best fit the politically correct job description. No one gets fired, just moved around inside the company until they are positioned into their comfortable safe place. Or, promoted to the position of the highest responsibility.

  21. Notams? NOTAMS? We don’t need no stinkin’ Notams! Just imagine if the airmail pilots in the 20’s had to explain to the Post Office that “sorry, one of the enroute beacons was notamed out of service and I had to layover in Topeka until sunrise.” Paul, your assessment in your second to last paragraph is spot on: a true blivet.