oversight

Commercial Aviation: Information on Airline IT Outages

Published by the Government Accountability Office on 2019-06-12.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office
             Report to the Ranking Member,
             Committee on Commerce, Science, and
             Transportation, United States Senate



             COMMERCIAL
June 2019




             AVIATION

             Information on Airline
             IT Outages




GAO-19-514
                                              June 2019

                                              COMMERCIAL AVIATION
                                              Information on Airline IT Outages

Highlights of GAO-19-514, a report to the
Ranking Member, Committee on Commerce,
Science, and Transportation, United States
Senate




Why GAO Did This Study                        What GAO Found
In recent years, the airline industry         The Department of Transportation (DOT) and, within it, the Federal Aviation
experienced several well-publicized IT        Administration (FAA) have limited roles overseeing or addressing the effects of
system outages to reservation, check-         outages from information technology (IT) systems that airlines rely on to
in, flight planning, and other systems.       schedule and transport passengers (e.g., reservation or flight planning systems).
Such outages can result in widespread
disruption to air travel, inconveniencing     •   FAA’s operations and oversight. At an airline’s request, FAA may halt the
passengers, who may be delayed or                 operation of all or part of that airline’s flights during an outage and work with
face out-of-pocket costs, and can also            the airline to reintegrate flights upon recovery. FAA does not directly oversee
affect airlines’ revenue and operations.          airline IT systems but works with airlines to ensure that airline data interfaces
Airlines are responsible for operating            correctly with FAA’s operational systems.
and maintaining their IT systems.             •   DOT’s consumer protection. Airline IT outages are not specifically
GAO was asked to review airline IT                addressed in DOT’s consumer protections for passengers, although other
outages. GAO examined: (1) DOT’s                  protections may apply, such as restrictions on tarmac delays if a passenger
and FAA’s roles related to airline IT             is held on a flight during an outage. DOT oversees airlines’ adherence to
outages and (2) what is known about               their contracts with passengers. These may include specific provisions such
these outages and their effects on                as refund procedures and responsibility for delayed flights, among other
passengers. GAO identified relevant               things. DOT also receives consumer complaints and uses complaint data to
federal laws and responsibilities and             initiate investigations that may result in fines or enforcement actions.
interviewed DOT and FAA officials. In         •   DOT’s data collection. DOT requires large airlines to report information
the absence of DOT and FAA data to                about on-time performance to the Bureau of Transportation Statistics (BTS),
identify airline IT outages, GAO                  including the causes of flight delays and cancellations in several broad
identified outages using open source              categories (e.g., airline caused, weather, and late-arriving aircraft).
documents for the 12 airlines reporting
to BTS from 2015 through 2017 and             Using multiple sources, GAO identified 34 IT outages from 2015 through 2017,
validated these outages using a multi-        affecting 11 of 12 selected airlines. No government data were available to
step process with publicly available          identify IT outages or determine how many flights or passengers were affected
airline information, interviews with          by such outages. BTS data provide information to consumers about airline
airline representatives, and FAA and          performance broadly but are not designed to identify the effects of individual
DOT data. GAO also reviewed airlines’         events, such as the number of flight delays and cancellations resulting from IT
contracts of carriage, which are legally      outages. According to GAO’s validation of multiple sources, however, about 85
binding contracts between airlines and        percent of the identified outages resulted in some flight delays or cancellations.
passengers, to understand how airlines        Because of limited data, information about how passengers have been
accommodate passengers                        inconvenienced from outages is largely anecdotal (see figure for examples of
inconvenienced by IT outages, as well         inconveniences). Further, airlines vary in what they provide to these passengers
as 140 consumer complaints related to
                                              (e.g., food, hotel, or rebooking on another airline) when IT outages occur.
airline IT outages received by DOT
                                              Consumer complaints stemming from IT outages accounted for less than one
from 2015 through June 2018.
                                              percent of all complaints received by DOT from 2015 through June 2018, and
                                              according to agency officials, these complaints raised concerns similar to
                                              complaints resulting from other causes of flight disruption. Complaints reviewed
                                              by GAO included the lack of food, a hotel, or compensation, among other things.
                                              Potential Passenger Inconveniences from Outages in Airline Information Technology




View GAO-19-514. For more information,
contact Heather Krause at (202) 512-2834 or
KrauseH@gao.gov.



                                                                                         United States Government Accountability Office
Contents


Letter                                                                                    1
              Background                                                                  4
              FAA and DOT Have Limited Roles in Overseeing Airline IT
                 Systems and Addressing Effects from Outages on Passengers                8
              Information on Airline IT Outages and Their Effects Is Limited, but
                 Suggests That Outages Result in a Range of Passenger
                 Inconveniences                                                          13
              Agency Comments                                                            28

Appendix I    Objectives, Scope, and Methodology                                         30



Appendix II   GAO Contact and Staff Acknowledgments                                      35


Table
              Table 1: Examples of Accommodations to Be Provided to Airline
                      Passengers Affected by Cancellations or Delays
                      (Required Duration of Delay, if Applicable)                        23

Figures
              Figure 1: Examples of Airline Information Technology (IT)
                       Systems and Potential IT Outage Effects                            7
              Figure 2: Airline-Reported Causes of Flight Delays for Airline
                       Information Technology (IT) Outages Affecting over 800
                       Total Flights (2015–2017)                                         19




              Page i                                            GAO-19-514 Airline IT Outages
Abbreviations

BTS               Bureau of Transportation Statistics
DHS               Department of Homeland Security
DOT               Department of Transportation
FAA               Federal Aviation Administration
IT                information technology
NAS               National Airspace System
NTML              National Traffic Management Log
OPSNET            Operations Network
SEC               Securities and Exchange Commission



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Page ii                                                      GAO-19-514 Airline IT Outages
                       Letter




441 G St. N.W.
Washington, DC 20548




                       June 12, 2019

                       The Honorable Maria Cantwell
                       Ranking Member
                       Committee on Commerce, Science, and Transportation
                       United States Senate

                       Dear Senator Cantwell:

                       In recent years, several information technology (IT) system outages at
                       U.S. airlines have drawn public attention to the resulting widespread
                       disruption to air travel. For example, in June 2018, American Airline’s
                       subsidiary PSA Airlines experienced an IT issue that led to the
                       cancellation of about 3,000 flights over the following week and cost
                       American Airlines an estimated $35 million in pre-tax income, according
                       to financial filings made by American Airlines. 1 Likewise, in 2016 an
                       outage in the system that Delta Air Lines uses to check in and board
                       passengers resulted in the cancellation of 2,300 flights over 3 days and
                       cost the airline $150 million in lost revenue, according to statements and
                       financial filings made by the airline. 2

                       Airline IT systems can include those that are used for flight and crew
                       planning, passenger reservations or check-in, or for providing flight
                       information to the Federal Aviation Administration (FAA), among others.
                       As with any industry, airlines’ IT investment decisions—including
                       purchasing, maintaining, and operating these systems—are internal
                       business decisions. Yet when these systems fail, they can delay or cancel
                       flights and result in out-of-pocket expenses for passengers, who may
                       have to pay for alternative travel, food, or lodging, or a combination of the
                       three.

                       The Department of Transportation (DOT) has a role in ensuring that
                       airlines adhere to certain consumer protections for passengers, such as
                       providing timely refunds for canceled flights. 3 DOT also requires large
                       1
                        American Airlines, Inc., Investor Update (Securities and Exchange Commission (SEC)
                       Form 8-K) (July 11, 2018).
                       2
                       Delta Air Lines, Inc., Quarterly Report (SEC Form 10-Q) (Oct. 13, 2016).
                       3
                        For more information about DOT’s oversight of airline consumer protections, see GAO,
                       Airline Consumer Protections: Additional Actions Could Enhance DOT’s Compliance and
                       Education Efforts, GAO-19-76 (Washington, D.C.: Nov. 2018).




                       Page 1                                                     GAO-19-514 Airline IT Outages
airlines to report on their on-time performance to the Bureau of
Transportation Statistics (BTS) and shares this information with
consumers and others. Within DOT, FAA is responsible for ensuring the
safe, efficient operation of the National Airspace System (NAS), including
managing air traffic control. 4

You asked us to review issues related to airline IT outages. This report
addresses: (1) DOT’s and FAA’s roles in relation to such outages and
their effects; and (2) what is known about airline IT outages, including the
number of flights and passengers affected.

The scope of this report is focused on airline IT systems that affect
passenger experiences, including systems related to reservations and
check-in, as well as those used by airlines for flight planning and
dispatch. 5

To determine relevant DOT and FAA roles, we identified DOT and FAA
authorities and responsibilities vis-à-vis airline IT outages in several
areas, including operations, consumer protection, and critical
infrastructure protection, by reviewing relevant laws, regulations, policies,
and guidance, as well as our prior work. We interviewed DOT officials
with BTS and the Office of the Assistant General Counsel for Aviation
Enforcement and Proceedings, which oversees consumer protections and
receives consumer complaints, as well as officials with FAA’s Office of the
Chief Information Security Officer, which advises the agency on matters
relating to IT management and security. 6 We also interviewed FAA
officials with the Air Traffic Organization and its Systems Operations




4
 The NAS is a shared network of U.S. airspace; air navigation facilities, equipment, and
services; airports or landing areas; aeronautical charts, information, and services;
regulations and procedures; technical information; and manpower and material.
5
 Our scope excluded aircraft avionics (such as systems used by pilots for navigation);
systems for in-flight operations (such as passenger Wi-Fi networks); and internal
operations (such as company email systems).
6
 Through our review of relevant plans and an interview with DOT officials in the Office of
the Secretary, we determined that airline IT systems are not included in federal plans for
critical infrastructure protection; as a result, we excluded DOT’s roles in this area from our
review.




Page 2                                                         GAO-19-514 Airline IT Outages
Services, which administers traffic management initiatives such as ground
stops. 7

To determine what is known about airline IT outages, including the
number of flights and passengers affected, we assessed whether DOT
data, including BTS and FAA performance and operations data could be
used to identify such outages and their effects. We determined that these
data were not designed, and could not be used, to comprehensively
identify airline IT outages. However, these data provided some insight
into flight disruptions (i.e., flight delays or cancellations) and ground stops
caused by outages once we had identified outages through other sources
and could look at data for specific dates.

In the absence of DOT or FAA data to identify airline IT outages, we
validated a preliminary list of such outages that we developed using open
source material from 2015 through 2017 for the 12 airlines that were
required to report on-time performance information to BTS during this
time period and two leading third-party IT providers (Amadeus and Sabre)
that provide airlines with the types of IT services included in our scope. 8
This validation was done using publicly available airline information (e.g.,
on websites and in press releases) and interviews with representatives
from 11 of the 12 airlines, Amadeus, and Sabre. 9 We also further
corroborated some of these outages with FAA operations data and DOT
consumer complaints. Through this process, we are confident that our list
includes all airline IT outages large enough to garner national-level, multi-




7
 In general, when FAA initiates a ground stop, flights destined to arrive at the affected
airport(s) are held at their departure point. These stops can be applied to a specific airport
or affect an airline’s entire fleet.
8
 The 12 airlines are Alaska, American, Delta, ExpressJet, Frontier, Hawaiian, JetBlue,
SkyWest, Spirit, Southwest, United, and Virgin America. Because two carriers (Envoy and
US Airways) were required to report on-time performance information to BTS in 2015 but
not in 2016 or 2017, we excluded them from our scope.
9
 We requested interviews with all 12 selected airlines; 11 airlines agreed to be interviewed
or provide written responses. One airline declined to be interviewed, although airline
representatives provided context on the effects of airline IT outages on operations. Two
airlines in our scope merged with other carriers prior to our review, and we interviewed
representatives from the merged carrier (i.e., we interviewed SkyWest, which had merged
with ExpressJet, and Alaska, which had merged with Virgin America).




Page 3                                                         GAO-19-514 Airline IT Outages
             day media coverage and an official response from an airline executive. 10
             To identify trends, if any, in IT outages, their potential causes, and effects
             on passengers, we interviewed representatives of the 11 airlines
             mentioned above, as well as other stakeholders, including an IT risk
             expert, three industry associations, and representatives from one
             employee union.

             To understand how airlines accommodate inconvenienced passengers,
             we reviewed airline contracts of carriage for the nine airlines in our scope
             with applicable contracts. Airlines’ contracts of carriage are the legally
             binding contracts between carriers and passengers and may include
             specific provisions such as refund procedures and responsibility for
             delayed flights, among other things. We reviewed passenger complaints
             received by DOT from 2015 through June 2018 stemming from airline IT
             outages to provide insight into what adverse effects passengers may
             have experienced as a result. We also interviewed the industry
             associations noted above and three consumer and passenger advocacy
             groups to identify any concerns regarding consumers affected by airline
             IT outages. See appendix I for more information on our scope and
             methodology.

             We conducted this performance audit from February 2018 to June 2019
             in accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             In the U.S. commercial airline industry, passengers travel on network,
Background   low-cost, and regional airlines. With thousands of employees and
             hundreds of aircraft, network airlines support large, complex hub-and-
             spoke operations, which provide service at various fare levels to many
             destinations. Low-cost airlines generally operate under a low-cost
             business model, which typically includes providing point-to-point service

             10
               Our review (and validation process) was limited to airline IT outages occurring from
             2015 through 2017. To provide updated information, we corroborated information from an
             online catalog of airline IT outages for 9 additional outages that occurred from January
             2018 through January 2019 using publicly available airline or airport information or media
             coverage.




             Page 4                                                       GAO-19-514 Airline IT Outages
using fewer types of aircraft. 11 Regional airlines typically operate small
aircraft—turboprops or regional jets with up to 100 seats—and generally
provide service to smaller communities on behalf of network airlines.

Airlines rely on a wide variety of IT systems to schedule and transport
passengers; some of these IT systems interface with networks operated
by travel-booking sites, other airlines, and the FAA. These IT systems
touch all phases of a passenger’s travel experience, including booking,
check-in, boarding, and baggage, as well as airline operations behind the
scene, including flight planning, crew scheduling, and flight dispatch,
according to FAA. In addition, aviation stakeholders explained that airline
IT systems operate in a dynamic, data-intensive environment that
demands around-the-clock availability and real-time information. In recent
years, the introduction of new mobile applications and
telecommunications infrastructure has added to the myriad systems and
network connections now critical to an airline’s operations.

Airlines face challenges in maintaining or enhancing their IT systems. For
example, some airlines operate a web of IT systems that were developed
over many years as manual systems transitioned to electronic and
computer-processed functions. Replacing software and upgrading these
older systems, such as reservations and crew scheduling, can be
complicated undertakings as airlines serve millions of travelers and need
to keep data flowing across their networks. For example, in its financial
filings, Southwest pointed to the significant challenges and costs involved
in introducing new IT capabilities while managing existing systems.
Increasingly dependent on the use of IT systems to run its ongoing
operations, the company recently completed a multi-year initiative to
transition to a new third-party reservation system through Amadeus,
among other investments. 12

In addition, a wave of industry consolidation stemming from airline
bankruptcies in the late 2000s has affected airline IT systems, requiring
significant sustained focus among airlines on merging different IT
infrastructures necessary to support worldwide flight operations without
interruption. For instance, we previously found that United struggled to
11
  Our scope includes airlines defined by BTS as network carriers (Alaska, American,
Delta, and United); low-cost carriers (Frontier, JetBlue, Spirit, Southwest, and Virgin
America); and regional carriers (ExpressJet and SkyWest), as well as Hawaiian, which
operates in a niche market.
12
 See Southwest’s Annual Report (2019).




Page 5                                                       GAO-19-514 Airline IT Outages
integrate computer and reservation systems following its merger with
Continental in 2010, although the airline has subsequently completed this
transition, according to airline representatives. 13 Likewise, in 2015
American pointed to its reliance on technology when discussing principal
risks posed by the integration of its computer, communications, and other
technology systems with those of US Airways following the merger of the
two airlines. 14

Additionally, some airlines rely on regional partners or third-party IT
providers to help manage certain IT systems, such as reservations, crew
scheduling, and flight dispatch, further adding to the variety of systems
that airlines depend on to run their operations. 15 Moreover, the airline
industry is going through a transformation as it shifts to digital
merchandizing and retailing to better serve consumers, a process which
requires access to real-time information, according to an industry
stakeholder. 16 Finally, the speed of technology evolution has accelerated,
making it a constant and iterative process to keep systems refreshed and
operating in sync, a situation that poses additional challenges, according
to a stakeholder.

Passengers may be affected by an airline IT outage in different ways
depending, in part, on the type and severity of the outage—for example,
whether the outage stems from a software glitch or a hardware failure—
and the system affected. (See fig. 1.) 17 Effects can range from standing in
13
  GAO, Airline Mergers: Issues Raised by the Proposed Merger of American Airlines and
US Airways, GAO-13-403T (Washington, D.C.: Jun. 19, 2013). According to airline
representatives, as United completed various steps of its integration with Continental, the
complexity of the systems was reduced and reliability improved.
14
  American Airlines, Inc., Annual Report (SEC Form 10-K), Dec. 31, 2015. According to
airline representatives, American subsequently merged key systems, including those
involved in operations and crew management (i.e., for pilots and flight attendants).
15
  For examples of this reliance on other parties, see the financial disclosures mentioned
above for American Airlines and Southwest Airlines, as well as Delta Air Lines, Inc.,
Annual Report (SEC Form 10-K), Feb. 23, 2018 and United Continental, Inc., Annual
Report (SEC Form 10-K), Feb. 22, 2018.
16
  We have previously reported on industry efforts to develop new standards and
capabilities for optional services to be more widely available for purchase online, such as
early boarding, wireless internet access, and preferred seating with more legroom. See
GAO, Commercial Aviation: Information on Airline Fees for Optional Services,
GAO-17-756 (Washington, D.C.: Sept. 20, 2017).
17
  This list of IT systems was compiled from our review of the types of systems that were
affected by airline IT outages from 2015 through 2017.




Page 6                                                        GAO-19-514 Airline IT Outages
                                         line to be checked in by a ticket agent instead of using a mobile
                                         application to delayed and canceled flights if a hardware failure forces the
                                         airline to ground all of its flights until the system is back online. System
                                         failures may have cascading effects across other airline IT systems or
                                         operations, as well. For example, an outage in a flight dispatch system
                                         could cause hours-long delays for subsequent flights. Likewise, aviation
                                         stakeholders noted that crew positioning can hinder recovery from an
                                         outage as delayed flight crews “time out,” further extending the effects of
                                         an outage. 18 In addition to these effects, passengers and airlines can also
                                         face higher costs from delayed or canceled travel, including increased
                                         operational expenses facing airlines as crews and aircraft sit idle, as well
                                         as indirect costs, such as those faced by travelers as their itineraries are
                                         delayed or canceled.

Figure 1: Examples of Airline Information Technology (IT) Systems and Potential IT Outage Effects




                                         18
                                           FAA has promulgated regulations regarding required rest periods for flight crews,
                                         including pilots. Therefore, the members of a flight crew could be “timed out” if a flight
                                         disruption causes them to be on duty through their allowable flight time, which—for
                                         pilots—begins when they are required to report for duty and lasts 8 or 9 hours. (See RIN
                                         2120–AJ58 under 14 C.F.R. Parts 117, 119, and 121.)




                                         Page 7                                                       GAO-19-514 Airline IT Outages
FAA and DOT Have
Limited Roles in
Overseeing Airline IT
Systems and
Addressing Effects
from Outages on
Passengers
FAA’s Role Is Primarily   FAA plays a key, but limited, operational role in responding to airline IT
Initiating Traffic        outages. As previously noted, FAA is responsible for ensuring the safe,
                          efficient operation of the NAS. Agency officials we interviewed
Management Initiatives
                          emphasized that airline IT outages have a limited effect on FAA’s
Requested by Airlines     management of the NAS because such outages tend to affect the
                          demand for airspace, not its capacity. As a result, FAA officials explained
                          that if flights are delayed or canceled because of an airline IT outage, the
                          NAS is often less congested for those that remain flying.

                          However, in managing the air-traffic control system, FAA is responsible
                          for initiating and administering traffic management initiatives (such as a
                          ground stop) if requested by an airline experiencing an IT outage. 19 For
                          example, an airline might request that FAA initiate a ground stop if the
                          airline is unable to report flight dispatch information to the FAA, such as
                          the weight and balance of aircraft. FAA works with airlines to
                          accommodate flights back into the NAS when the outage is over. Once an
                          airline recovers from an outage, FAA may also need to initiate traffic
                          management initiatives if demand exceeds capacity in the system—
                          potentially causing delays both for the airline that experienced the outage,
                          as well as others.

                          FAA does not routinely collect data about airline IT outages—which fall
                          outside of its management of the NAS, according to agency officials—
                          although it does collect data on NAS operations, which could include
                          some information about these events. Specifically:



                          19
                            These traffic management initiatives are done at the request of airlines for outages that
                          result in significant effects on airlines’ schedules.




                          Page 8                                                        GAO-19-514 Airline IT Outages
•   The National Traffic Management Log (NTML)—the real-time
    narrative log of NAS traffic management initiatives kept by air traffic
    controllers—includes information about ground stops or other
    initiatives such as time the stop was put in place, affected airports,
    and when the initiative was lifted. Log entries may also include
    additional information about the outage, if such information is provided
    to air traffic control by the airline experiencing it.
•   The Operations Network (OPSNET) system, among others, collects
    operational data, including air traffic operations and delay data to
    analyze the performance of the FAA’s air traffic control facilities.
    However, according to agency officials, data on the effects of airline IT
    outages (including delay and cancellation data related to airline IT
    outages) are discarded because information about airline-caused
    flight disruptions do not provide instructive information to FAA about
    whether the agency is efficiently operating the NAS.

FAA does not directly oversee airline IT systems related to reservations,
check-in, baggage, and boarding or their use, according to agency
officials. These systems are managed by the airlines themselves. For
airline IT systems that interface with FAA’s operational systems, such as
automated systems used in air traffic control, FAA works with airlines to
ensure that any output (i.e., data feeds) interfaces correctly with the
agency’s systems. FAA may provide observations to the airline if its IT
systems are not providing accurate information, such as if crews are not
being correctly scheduled and tracked, fuel plans are not accurate, or
flight plans are not correctly calculated and observable.




Page 9                                             GAO-19-514 Airline IT Outages
For Passengers, DOT       DOT’s Office of the Assistant General Counsel for Aviation Enforcement
Helps Ensure Compliance   and Proceedings and its Aviation Consumer Protection Division are
                          responsible for helping ensure airlines’ compliance with passenger
with Consumer
                          protection requirements and educating passengers on their rights. Airline
Protections, Which May    IT outages are not specifically addressed by any of DOT’s consumer
Be Triggered by Certain   protection regulations. 20 Rather, when these outages occur, they may
Airline IT Outages        trigger broader consumer protections afforded passengers. 21 For
                          example, airlines are required by DOT’s interpretation of the statutory
                          prohibition on unfair and deceptive practices to provide refunds for flights
                          that are canceled or significantly delayed if a passenger declines any
                          rerouting that the airline may offer. 22 In the case of delay, however, what
                          amounts to a significant delay is not defined in this policy, and as
                          discussed below, individual airlines may or may not set their own
                          thresholds. 23 According to agency officials, DOT is currently conducting a
                          review of air carriers’ handling of involuntary changes to passengers’

                          20
                            However, the FAA Reauthorization Act of 2018 includes a requirement that in the event
                          of a widespread disruption, such as an airline IT outage, the affected airline provide
                          information on its website about whether and how the airline is arranging for
                          accommodations and amenities. Pub. L. No. 115-254, § 428 (2018).
                          21
                            While U.S. airlines’ business practices were largely deregulated following the Airline
                          Deregulation Act of 1978, a number of consumer protections for airline passengers (i.e.,
                          “consumer protections”) are in place at the federal level. Federal statutes have also
                          authorized DOT to regulate certain areas affecting passengers. For example, DOT has the
                          authority to stop airlines from engaging in unfair or deceptive practices, or unfair methods
                          of competition, and may promulgate consumer protection regulations under that authority.
                          (See 49 U.S.C. § 41712.) Some consumer protections are in federal statute, such as the
                          Air Carrier Access Act of 1986, as amended, which prohibits airlines from discriminating
                          against individuals based on a disability.
                          22
                             In response to comments by some airlines and airline associations in a 2011 rulemaking
                          proceeding, DOT rejected their assertions that carriers are not required to refund a
                          passenger’s fare when a flight is canceled if the carrier can accommodate the passenger
                          with other transportation options after the cancellation. 76 Fed. Reg. 23110, 23129 (April
                          25, 2011). DOT stated that it finds it to be manifestly unfair for a carrier to fail to provide
                          the transportation contracted for and then to refuse to provide a refund if the passenger
                          finds the offered rerouting unacceptable (e.g., greatly delayed or otherwise inconvenient)
                          and he or she no longer wishes to travel. Since at least the time of an Industry Letter of
                          July 15, 1996, DOT’s Office of the Assistant General Counsel for Aviation Enforcement
                          and Proceedings has advised carriers that refusing to refund a non-refundable fare when
                          a flight is canceled and the passenger wishes to cancel is a violation of 49 U.S.C. 41712
                          (unfair or deceptive practices) and would subject a carrier to enforcement action.
                          23
                            In the 2011 rulemaking proceeding, DOT stated that it had been persuaded by the
                          airline industry that there should not be a “significant delay” threshold because delay can
                          be influenced by many factors, a number of which may be beyond the airlines’ control. 76
                          Fed. Reg. 23110, 23129 (April 25, 2011). DOT further stated that it would continue to
                          monitor how carriers apply their non-refundability provision.




                          Page 10                                                        GAO-19-514 Airline IT Outages
travel itineraries. 24 DOT also regulates compliance through its tarmac
delay rule, which requires airlines to mitigate or avoid consumer harm in
the event of a lengthy tarmac delay. 25 In addition to these consumer
protection regulations and policies, DOT oversees airlines’ compliance
with obligations included in airline contracts of carriage or customer
service plans. 26 These contracts and plans must be publicly posted by
airlines on their websites.

As we have previously reported, DOT helps ensure airlines’ compliance
with its passenger protection requirements by educating airlines on new
regulations or clarifying existing regulations, responding to airlines’
questions, and reviewing airlines’ consumer service policies. 27 According
to DOT officials, the agency encourages proactive reporting of incidents
by airlines, such as airline IT outages, including a brief description of the
incident and any steps taken by the airline to provide accommodation to
affected consumers. DOT also receives and investigates complaints from
passengers and uses complaint data to identify which airlines to inspect
and whether to begin investigations that may result in fines or
enforcement actions. According to agency officials, DOT received 126
complaints that explicitly mentioned a domestic airline IT outage from



24
  This review is being carried out in consultation with the Aviation Consumer Protection
Advisory Committee (ACPAC) in response to a mandate in the FAA Reauthorization Act of
2018. Pub. L. No. 115-254, § 414 (2018).
25
  A major requirement of the tarmac delay rule is that the airline’s plan contain an
assurance that it will not permit an aircraft to remain on the tarmac for more than 3 hours
for a domestic flight, or 4 hours for an international flight, before allowing passengers to
deplane, subject to exceptions for safety, security, and direction from air traffic control.
See 14 C.F.R, § 259.4 and 49 U.S.C. § 42301.
26
  According to the DOT Inspector General, Congress, DOT, and the Air Transport
Association (ATA) in 1999 agreed that airlines should have an opportunity to improve their
customer service without legislation. Toward that end, ATA and its member airlines
committed to preparing customer service plans. See DOT Inspector General, Airline
Customer Service Commitment, CC-2001-090 (Washington D.C.: Feb. 13, 2001). These
plans include provisions that might provide consumer protections to passengers
inconvenienced by airline IT outages, such as requirements to notify passengers about
delays and cancellations, disclose cancellation policies, and identify services provided to
mitigate passenger inconveniences due to cancellations and missed connections. In 2011,
DOT required certain provisions to be included in airline customer service plans and
required airlines to adhere to their customer service plans. See 14 C.F.R. Part 259.
27
  According to DOT data, DOT inspected 12 to 14 U.S. airlines annually—most multiple
times—at 51 domestic airports from 2015 through 2017. See GAO-19-76.




Page 11                                                       GAO-19-514 Airline IT Outages
2015 through 2017. 28 These complaints involved five such outages. For
comparison, in all, the agency received between 17,000 and 21,000
complaints per calendar year during that timeframe, according to DOT’s
Air Travel Consumer Report. 29 According to DOT officials, complaints that
explicitly mentioned an airline IT outage largely mirror in substance those
received for other causes of flight disruptions. (These complaints are
discussed in more detail below.)

According to DOT officials, no investigations have been carried out
focusing solely on airline IT outages, but DOT investigations have
included airline IT outages that contributed to violations of DOT’s
consumer protection regulations. For example, DOT found that an IT
outage affecting Delta’s operational systems, including gate management
and flight dispatch systems, caused significant surface congestion and
resulted in a violation of tarmac delay regulations. This violation was
among those included in enforcement proceedings resulting in a civil
penalty and consent order to the airline. 30

Finally, to monitor airline on-time performance and baggage handling and
to provide information to consumers, DOT requires certain airlines to
report data to BTS monthly, including the causes of flight delays and
cancellations. 31 However, the causes are grouped into broad categories
and do not specify IT outages as a cause. BTS, which is an independent
statistical agency within DOT, publishes summary data from reporting air
carriers on the number of domestic on-time, delayed, canceled, and
diverted flights on its website. DOT’s Office of Aviation Enforcement and
Proceedings also publishes a monthly Air Travel Consumer Report with
this information. We discuss these data in greater detail below.



28
  DOT also received 14 complaints stemming from a domestic airline IT outage in June
2018.
29
 See DOT, Air Travel Consumer Report (Feb. 2016, Feb. 2017, and Feb. 2018).
30
  See U.S. Department of Transportation, Delta Air Lines Order 2019-2-22, Docket OST-
2019-0001 (February 28, 2019).
31
  BTS has tracked on-time performance data on selected domestic flights operated by air
carriers since 1987; in 2003, it also began collecting information on the causes of flight
delays and cancellations. Beginning in 2018, the threshold for reporting carriers was
lowered from those with at least 1.0 percent of scheduled service domestic passenger
revenues to those with at least 0.5 percent, causing the number of carriers reporting
carriers to rise from 12 to 18. 81 Fed. Reg. 76800, 76826 (Nov. 3, 2016).




Page 12                                                      GAO-19-514 Airline IT Outages
Information on Airline
IT Outages and Their
Effects Is Limited, but
Suggests That
Outages Result in a
Range of Passenger
Inconveniences
We Identified 34 IT         Using a variety of information sources, we identified 34 airline IT outages
Outages Affecting Almost    from 2015 through 2017 affecting 11 of the 12 airlines in our review. 32 No
Every Domestic Airline in   government data, academic literature, or other information source could
                            be used to determine a comprehensive count of airline IT outages, and
Our Review                  information is also limited regarding the types, causes, and effects of
                            these incidents. Additionally, airlines do not regularly share detailed data
                            about their IT outages publicly, such as the number of flights or
                            passengers affected or the technical cause of the outage, although
                            general information about these incidents is sometimes provided on their
                            websites and social media accounts or to the press. 33

                            To identify airline IT outages in the absence of other sources of
                            information, we validated a preliminary list of outages developed through
                            a review of open source information, including media coverage. This
                            preliminary list was validated through a combination of interviews with the
                            airlines and third-party IT providers and a review of publicly available
                            airline information, FAA NTML log entries, and DOT consumer
                            complaints. Through our validation process, airline representatives and
                            others identified additional airline IT outages that had not been reported
                            or acknowledged publicly by airlines or third-party IT providers, reflecting
                            the variation in quantity or quality of information available regarding these


                            32
                              Airline outages have continued to occur as illustrated by an online catalog of airline IT
                            outages, which identified 11 additional outages that occurred from January 2018 through
                            January 2019. While outside our scope, we were able to validate 9 of these outages using
                            publicly available airline or airport information or media coverage. We did not carry out a
                            thorough analysis to develop a full list of outages occurring during this timeframe.
                            33
                              Some airline representatives stated they considered information related to the cause,
                            duration, and system associated with an IT outage proprietary.




                            Page 13                                                      GAO-19-514 Airline IT Outages
events. 34 For example, we found more information about IT outages that
had nationwide or multi-day consumer or operational effects because
these incidents garnered more coverage—and often an official airline
response—as compared to those that were of shorter duration or affected
a regional carrier or smaller number of flights, passengers, or airports.
Additionally, we found less or incomplete information on outages at third-
party IT providers and regional carriers because their effects were
dispersed across multiple airlines.

We found that the number and severity of flight disruptions associated
with the airline IT outages we identified varied widely. About 85 percent
(29 of 34) of our identified outages resulted in some flight disruptions,
including 5 outages we identified that caused over 800 delays or
cancellations. 35 However, we were unable to verify the exact number of
disrupted flights caused by each outage. At least 14 outages resulted in a
ground stop, some of which lasted for several hours, according to a
review of FAA’s NTML logs. 36 We identified seven outages that had no
associated flight disruptions, although they inconvenienced customers in
other ways. For example, during these incidents customers experienced
problems buying tickets online, checking into flights on an airline’s
website, or using frequent flier benefits.

Because no comprehensive data are available on airline IT outages and
their related effects, we could not compare these incidents with the
effects on flights caused by other disruptive events, such as severe
weather like hurricanes or snowstorms. However, FAA analysis of two of
the IT outages that caused over 800 flight disruptions found that the

34
   For example, one airline shared information on more than 20 additional outages not
previously identified in our review, most of which lasted less than 2 hours or resulted in no
flight delays or cancellations.
35
   We lack detailed information that would allow us to compare the number of flight
disruptions resulting from airline IT outages with overall airline performance. We found
that airlines operated over 17 million flights from 2015 through 2017, of which 19 percent
were delayed or canceled based on a review of BTS data. However, we lack information
on the exact number of delays and cancellations resulting from airline IT outages for the
reasons discussed in the next section. In addition, we lack a baseline by which to compare
flight disruptions resulting from airline IT outages because we did not catalog all of the
incidents that led to delays and cancellations in our review, such as severe weather or
airport-related problems.
36
  NTML logs, which are not publicly available, may refer to an airline IT outage in the
narrative if the airline shares this information with FAA during the event and the controller
includes this information in the log, as mentioned above.




Page 14                                                        GAO-19-514 Airline IT Outages
number of delays or cancellations resulting from these outages was on
par with or worse than those caused by severe weather in the same
months the outages occurred. 37 Likewise, representatives from one airline
stated that operational effects from airline IT outages are comparable to
severe weather events, although outages occur much less frequently. An
aviation industry representative noted that these events are typically
unexpected, hindering the ability of airlines to react and recover. By
contrast, disruptions from weather may be forecast ahead of time,
allowing airlines to prepare for predicted disruptions, including
accommodating customers, adjusting flight crews and schedules, and
pre-positioning aircraft, according to the same representative.

The airline IT outages we identified were caused by a range of IT and
infrastructure issues, according to airline representatives we interviewed
and official press statements. 38 These issues included hardware failures,
software outages or slowdowns, power or telecommunications failures,
and network connectivity issues, among others. In several instances, an
IT issue in one airline system had cascading effects across other systems
not affected by the initial outage. For example, a large volume of online
traffic shut down an airline’s website and subsequently disrupted the
airline’s reservations and check-in systems. Representatives from six
airlines, an IT expert, and four other aviation industry stakeholders
pointed to a variety of factors that could contribute to an outage or
magnify the effect of an IT disruption. These factors ranged from
underinvestment in IT systems after years of poor airline profitability,
increasing requirements on aging systems or systems not designed to
work together, and the introduction of new customer-oriented platforms
and services.

Representatives from airlines we interviewed also described some of their
IT system investments and risk mitigation efforts undertaken in response
to an outage or to address potential disruptions, such as investing in new



37
  FAA conducted this analysis at our request for 3 of the 34 airline IT outages we
identified. Since there is no source of FAA data that can identify an airline IT outage, we
selected 3 outages with a range of flight disruptions for comparative analysis. FAA noted
that it was not possible to definitively assess the effects of these outages.
38
  We requested from the selected airlines after-incident reports or other technical
accounts that may provide details on the specific cause of the IT outages we identified,
but the airlines did not provide these reports and deemed them proprietary.




Page 15                                                       GAO-19-514 Airline IT Outages
                           backup systems or technologies. 39 For example, five airlines have sought
                           to reduce vulnerability by expanding IT operations beyond a single data
                           center or moving them to the cloud, which allows for the delivery of
                           computing services through the Internet. Likewise, two airlines described
                           efforts to ensure connectivity and reduce the effects of IT disruptions by
                           using multiple telecommunications network providers. Several airline
                           representatives and an IT expert said that these airline IT investments are
                           aimed at enhancing overall system functionality as well as revenue.
                           However, the IT risk expert we spoke with noted that carrying out major
                           upgrades to their IT systems can be challenging because these systems
                           are always in use. Additionally, according to stakeholders we interviewed,
                           airlines employ a variety of contingency planning and recovery strategies
                           to respond to unforeseen technical issues, including IT outages. For
                           example, one airline described incorporating routine system testing,
                           artificial intelligence, and outage drills into planning for system disruptions
                           to avoid outages or speed recovery. Airline efforts to increase the
                           resiliency of their IT systems, such as those described above, could
                           prevent or lessen the impact of such outages.


BTS Data Broadly Capture   BTS data capture the causes of flight delays and cancellations in several
Flight Delays and          broad categories, which do not isolate flight disruptions resulting from
                           airline IT outages and do not reflect the root cause of flight disruptions. As
Cancellations
                           previously mentioned, BTS collects on-time performance data from the
                           airlines, including the causes of flight delays and cancellations. 40 On a
                           monthly basis, certain airlines are required to report at least one cause of
                           delay (in minutes) for each flight delayed 15 minutes or more from the
                           following five categories: air carrier, extreme weather, NAS, security, and
                           late arriving aircraft. 41 Similarly, for each flight that was canceled, airlines
                           are required to report the cause from one of four categories: air carrier,
                           extreme weather, NAS, and security. BTS guidance instructs airlines to
                           report flight delays that are within the control of the airlines in the air-
                           carrier category. Also included in the air-carrier category, according to the
                           guidance, are more than 40 other potential causes of delays or
                           cancellations, such as aircraft maintenance, baggage, terminal
                           operations, and crew matters. As a result, flight disruptions from IT
                           39
                             We interviewed or received written responses to our questions from 11 of the 12 airlines
                           in our scope.
                           40
                            14 C.F.R. § 234.1.
                           41
                            14 C.F.R. § 234.4.




                           Page 16                                                     GAO-19-514 Airline IT Outages
outages are indistinguishable from other airline-caused issues within this
category.

Additionally, delays caused by airline IT outages may be captured in a
category other than air carrier because of how airlines can report the
causes of flight delays based on BTS guidance. For example:

•    Multiple causes for a delay. Airlines have the option to report either
     just the main cause or all the causes for a flight delay as long as the
     airline consistently applies the same method in its monthly report to
     BTS. Also, if there is more than one cause for a flight delay that starts
     at the same time, airlines are required to report the cause that lasted
     the longest. As a result, delays caused by an airline IT outage may be
     attributed to other categories if they happen at the same time as other
     issues affecting an airline’s operations, such as poor weather or
     airport conditions.
•    Late arriving aircraft delays. Airlines can report a flight delay in the
     late arriving aircraft category if the previous flight arrived late and
     caused the next flight (on the same aircraft) to depart late. Airlines are
     not required to provide additional information on the cause of the
     delay for the previous flight (air carrier, NAS, security, or extreme
     weather). As a result, delays from incidents that can cause ripple
     effects on an airline’s operations, such as an IT outage or severe
     thunderstorms, may be attributed to the late arriving aircraft category.
•    NAS delays. Airlines can report delays in the control of the FAA,
     airport operators, or state and local officials in the NAS category,
     which includes ground stops, flight volume delays, and air traffic
     control issues, among others. However, BTS guidance does not
     specify how airlines should report delays caused by ground stops
     requested by the airlines, including after an IT outage. As a result,
     these delays may be captured in the NAS category.

BTS data are collected to provide general information on the quality of
airline performance to consumers and to improve airline scheduling,
rather than detailed information about specific flights or events. 42
42
  In a 2002 rulemaking, DOT considered some additional information reporting
requirements but concluded that reporting the initial causes of flight delays captured in the
late arriving aircraft category are not critical to data users and reporting the initial causes
of delay could be confusing. 67 Fed. Reg. 70535 (Nov. 25, 2002). With regard to
scheduling, DOT officials noted that airlines had previously used BTS data to enhance
operations and to track flight disruptions, but currently rely on other sources of data for this
purpose.




Page 17                                                         GAO-19-514 Airline IT Outages
Consequently, these data provide limited insight into the effects of
individual events, including airline IT outages, both because flight
disruptions may be captured in more than one category and because the
data do not allow for the isolation of effects for affected flights. 43

We reviewed BTS data for most of the airline IT outages we identified and
found, for example, that for 3 outages, airlines reported the largest total
number of flight delays in the NAS causal category on the day that the
airline requested a ground stop because of the outage—rather than in the
air-carrier category. In addition, we reviewed BTS data for the 5 outages
we identified where the airline involved delayed or canceled at least 800
total flights and found that airlines spread the causes of flight delays and
cancellations across several categories, primarily air carrier, late arriving
aircraft, and NAS for the first day of these outages. 44 For example, we
found that airlines attributed 44 percent of all reported flight delays to late
arriving aircraft for these days. 45 (See fig. 4).




43
  For our analysis, we reviewed airline IT outages that airline representatives or other
airline sources confirmed to have resulted in flight delays or cancellations. For IT outages
that affected flights over several days, we reviewed data on the first day in which the
outage occurred. We excluded outages at third-party IT providers because their effects
are dispersed among multiple airlines.
44
  Flight disruptions for these outages ranged from about 800 to about 8,000, according to
press reports and airline-provided information.
45
  We previously reported that BTS information on the causes of flight delays provided
consumers with an incomplete picture of the underlying causes of flight delays. We
reported that in 2007 the largest source of system-wide delay—late arriving aircraft—
masked the original source of these delays, which could have included severe weather,
the airline, security, or the NAS, or a combination of one or more of these sources. See
GAO, National Airspace System: DOT and FAA Actions Will Likely Have a Limited Effect
on Reducing Delays during Summer 2008 Travel Season, GAO-08-934T (Washington,
D.C.: July 15, 2008).




Page 18                                                       GAO-19-514 Airline IT Outages
Figure 2: Airline-Reported Causes of Flight Delays for Airline Information
Technology (IT) Outages Affecting over 800 Total Flights (2015–2017)




DOT officials did not see a need for additional reporting requirements on
flight delays and cancellations caused by airline IT outages given the
effects of such events are not unique when compared to other causes of
flight delay and because these incidents involve a small portion of
consumer complaints received by DOT. Aviation stakeholders we spoke
to told us that airlines track flight disruptions for internal purposes such as
managing operations and scheduling. For example, representatives from
one airline said that the airline tracks delays and cancellations associated
with IT outages and other issues internally to identify patterns and
reoccurring issues that need improvement, such as scheduling, staffing,
and maintenance. DOT officials noted that obtaining more detailed
information on the causes of flight delays and cancellations would require



Page 19                                                  GAO-19-514 Airline IT Outages
                             a cost and benefit analysis to determine whether the benefit from
                             collecting the data would exceed the airlines’ cost to report the data.
                             Officials also noted that the agency has undertaken efforts to provide
                             additional information to consumers. 46 Notably, to provide more insight
                             into the underlying causes of delay attributed to late arriving aircraft, BTS
                             began calculating the original causes of delays in the late arriving aircraft
                             category and providing these data on its website in response to a
                             recommendation made by the DOT Inspector General in 2013. 47


Information on the Effects   No data are publicly available to quantify with any degree of precision the
on Passengers Is Largely     number of passengers affected by airline IT outages, and only one airline
                             provided this type of information to us. 48 Airline contracts of carriage set
Anecdotal and Illustrates
                             the minimum accommodations passengers are entitled to when their
Varied Passenger             flights are delayed or canceled, which could include refunds, rebooking,
Experiences                  or other amenities, such as food or meals. However, there is no
                             comprehensive information about the accommodations that were actually
                             received by passengers, and available information is largely anecdotal.

                             Even with respect to the same IT outage, different people may be
                             affected differently. For example, passengers may be affected by the
                             complexity of the NAS and their individual circumstances. According to an
                             airline representative we spoke with, an airline may be able to quickly
                             rebook affected passengers on a different airline for one destination, for
                             example, but may have difficulty rebooking passengers for another
                             destination if other flights are full. Further, while network airlines have
                             hub-and-spoke networks that include a number of route options or
                             frequent service between cities, others—particularly point-to-point or low-

                             46
                               The FAA Reauthorization Act of 2018 includes a provision for DOT to review the
                             categorization of delays and cancellations in response to adverse weather conditions by
                             September 2019. Pub. L. No. 115-254, § 413 (2018).
                             47
                               These data are based on BTS calculations that proportionally assign delay minutes
                             reported by the airlines in the other causal categories (air carrier, NAS, security, and
                             weather). As a result, the original cause identified is not based on reporting, but rather a
                             calculation. See DOT OIG, More Comprehensive Data Are Needed To Better Understand
                             The Nation’s Flight Delays and Their Causes, AV-2014-016 (Washington, D.C.: Dec. 18,
                             2013).
                             48
                               This airline provided information on the numbers of their passengers on delayed or
                             canceled flights for five outages—one of which occurred in their own IT system(s)
                             affecting nearly 8,000 passengers and four other outages at a regional partner and third-
                             party IT providers, respectively, affecting between nearly 1,000 and nearly 12,000 of the
                             airline’s passengers.




                             Page 20                                                       GAO-19-514 Airline IT Outages
cost carriers—may have more limited service, further constraining the
ability to rebook individual passengers. Finally, passengers travel for
different reasons and their tolerance for disruption can differ, as well,
according to DOT officials. Thus, someone flying to visit a friend may
have a different tolerance for delay than someone traveling for a job
interview, they noted.

Airlines are required by DOT to provide refunds for canceled—and
significantly delayed—flights if a passenger chooses to cancel his or her
trip. 49 Beyond these requirements, however, airlines are not obligated to
provide accommodations for flight disruptions such as cancellations and
delays unless specified in an airline’s contract of carriage, according to
DOT. 50 These contracts govern what, if anything, a passenger is entitled
to, although airlines may offer additional accommodations to
inconvenienced passengers. 51 Generally accommodations received by
inconvenienced passengers could include rebooking on the same airline
or alternate travel; refunds or compensation in the form of money or other
benefits (e.g., credit for later travel); and amenities such as hotel stays
and food, according to their contracts of carriage. Airlines can—and in
some cases do—go above and beyond the obligations set forth in their
contracts of carriage, as illustrated by some examples below.




49
   As mentioned earlier, DOT considers an airline failure to provide a refund for a canceled
flight to be a violation of 49 U.S.C. § 41712 (DOT’s general authority prohibiting unfair or
deceptive practices). Accordingly, passengers are entitled to such refunds, according to
DOT, if the flight is canceled and the passenger choses to cancel the trip.
50
  By contrast, there are consumer protections addressing passengers who are denied
boarding involuntarily (i.e., they are “bumped”) or those affected by long tarmac delays,
when passengers do not have an opportunity to get off an airplane on the ground at an
airport. For example, an airline must provide compensation to passengers who are
bumped, with the amount varying based on the type of flight (e.g., foreign or domestic)
and availability of alternate transportation. See 14 C.F.R. § § 250.5 and 259.4,
respectively.
51
  We found that airlines’ customer service plans did not provide passengers with greater
protections or the right to more amenities than were included in airline contracts of
carriage vis-à-vis airline IT outages.




Page 21                                                      GAO-19-514 Airline IT Outages
Accommodations Included in        To better understand the accommodations that passengers may have
Airlines’ Contracts of Carriage   received as the result of airline IT outages, we reviewed airlines’ contracts
Vary                              of carriage for the airlines in our scope with applicable contracts. 52 None
                                  of these contracts addressed IT outages directly, but flight disruptions
                                  caused by outages would be covered under the broader contract terms
                                  addressing cancellations and delays. We found that the contracts vary in
                                  terms of what accommodations are provided for, as well as the extent to
                                  which airlines have discretion in providing them. For example, while
                                  several airline contracts include provisions to provide hotel vouchers,
                                  transportation to the hotel, or meals, other airlines—notably several low-
                                  cost carriers—do not. Likewise, some airlines establish set time
                                  thresholds for when they are obligated to provide a certain
                                  accommodation (e.g., after a delay of at least 4 hours), while others do
                                  not. Specific accommodations we identified in our review of airline
                                  contracts of carriage are discussed below, and table 1 further details
                                  some of the variation that we found.




                                  52
                                    This analysis included 9 of the 12 airlines required to report to BTS from 2015 through
                                  2017. We excluded 2 regional airlines (ExpressJet and SkyWest) that operate under the
                                  contracts of carriage of their mainline partners, as well as Virgin America, which merged
                                  with Alaska in 2018 and no longer has a separate contract of carriage.




                                  Page 22                                                      GAO-19-514 Airline IT Outages
Table 1: Examples of Accommodations to Be Provided to Airline Passengers Affected by Cancellations or Delays (Required
Duration of Delay, if Applicable)
           a
 Airline                                     Alternate travel                                  Refund of unused portion of                     Amenities
                                                                                                          ticket
                             Rebooking on a              Other                          Flight               Flight delay      Hotel stay             Food
                             different airline           transportation                 cancellation
                                                         (e.g., rail)
                                                                                                                                                      b
 Alaska                      Yes,                        Yes, discretionary             Yes                  Yes (2 hours)     Yes (4 hours)
                             discretionary
                                  c                                                                                                                   b
 American                    No                          No                             Yes                  Yes (1 hour)      Yes
                                                                                                                                                      b
 Delta                       Yes,                        Yes, discretionary             Yes                  Yes (90 minutes) Yes (4 hours)
                             discretionary
                                                         b                                     d                   d           b                      b
 Frontier                    No                                                         Yes                  Yes
                             b                           b                                     d                   d
 Hawaiian                                                                               Yes                  Yes               Yes (4 hours)          Yes (4 hours)
                             b
 JetBlue                                                 No                             Yes                  Yes (1 hour)      Yes (6 hours)          Yes (6 hours)
                             b                                                                                                 b                      b
 Southwest                                               No                             Yes                  Yes
                                                         b                                                                                            b
 Spirit                      No                                                         Yes (2 hours)        Yes (2 hours)     Yes
                                                                                               d                   d                           e
 United                      Yes,                        Yes, discretionary             Yes                  Yes               Yes (4 hours)          Yes (“extensive”)
                             discretionary
Source: GAO analysis of selected airline contracts of carriage (February 2019). | GAO-19-514
                                                                  a
                                                                   No airline provided for monetary compensation to passengers affected by cancellations or delays for
                                                                  domestic flights in its contract of carriage, although Alaska and JetBlue provided for travel vouchers
                                                                  for such passengers in some circumstances.
                                                                  b
                                                                      Accommodation was not addressed in the contract of carriage.
                                                                  c
                                                                   However, American will rebook a passenger on a different airline or provide for ground transportation
                                                                  if he or she is diverted to a different airport than the passenger’s original origin or destination,
                                                                  according to the airline’s contract of carriage.
                                                                  d
                                                                   Frontier, Hawaiian, and United consider certain groups of cities identified in their contracts of
                                                                  carriage to be the same point (e.g., Chicago and Milwaukee, San Francisco and Oakland, Colorado
                                                                  Springs and Denver). Their contracts of carriage do not provide for refunds if the airlines are able to
                                                                  provide transportation to the specified alternative city.
                                                                  e
                                                                   United’s contract of carriage does not provide for hotel stays to passengers who are diverted to
                                                                  airports within certain city groups (e.g., Burbank, Los Angeles, Ontario, or Orange County), among
                                                                  other exceptions.


                                                                  •       Alternate transportation. All nine airlines in our analysis provide for
                                                                          rebooking on their own airline in the event of a flight delay or
                                                                          cancellation such as might be caused by an airline IT outage,
                                                                          although Frontier includes certain airports near a passenger’s original
                                                                          destination as acceptable alternatives in its contract of carriage.
                                                                          Under this exception, for example, Frontier could rebook a passenger
                                                                          on a flight to Tampa if he or she had originally planned to travel to
                                                                          Orlando, or vice versa, in the event of a flight disruption. Three of the
                                                                          airline contracts of carriage we reviewed provide for travel on a
                                                                          different airline—or the use of alternate ground transportation—



                                                                  Page 23                                                               GAO-19-514 Airline IT Outages
     typically at their discretion, and a fourth airline provides for alternate
     transportation if a passenger’s flight has been diverted to a different
     airport. Airline representatives with two low-cost carriers described
     their unsuccessful efforts to develop agreements with network airlines
     to facilitate the rebooking of passengers on another airline.
•    Refunds for cancellations. If a flight is canceled and no alternative is
     available—or if available flights are not acceptable to the passenger—
     all nine airlines in our analysis provide for refunds, although three
     airlines may instead reroute passengers to nearby cities. Under their
     contracts of carriage, airlines typically provide refunds for the unused
     portion of a ticket in the event of flight disruptions. If, for example,
     passengers have already completed the outbound portion of a
     roundtrip ticket, they would receive a partial refund for the unused,
     return portion, rather than the entire ticket. Finally, three airlines
     (Hawaiian, Southwest, and United) offer passengers the option of
     travel credits in lieu of a refund in their contracts of carriage.
•    Refunds for delays. The majority of airlines in our review provides
     refunds or flight credit for flight delays, although refunds in some
     cases could be contingent on the absence of an acceptable
     alternative, such as being rebooked on a subsequent flight or to an
     alternate airport. As mentioned above, DOT requires airlines to
     provide refunds for flights that are “significantly delayed” but does not
     define how long such a delay is and instead relies on a case-by-case
     determination. Four of the contracts we reviewed establish a specific
     timeframe for the delay after which a passenger is entitled to a refund,
     while the others do not establish such a threshold. For example, a
     passenger flying on Alaska Airlines could request and receive a
     refund for a flight disruption lasting at least 2 hours, and passengers
     on Delta are entitled to a refund, if requested, after a 90 minute delay.
     By contrast, airlines without a defined threshold for a delayed flight
     have discretion for when passengers would be eligible for refunds,
     particularly with regard to nonrefundable tickets. 53
•    Hotel stay. The majority of airlines in our review provide for hotel
     stays in their contracts of carriage (and ground transportation to the
     hotel), to varying degrees, although two low-cost carriers (Frontier and
     Southwest) do not. The contracts of carriage for seven airlines include

53
  Passengers may travel using cheaper, nonrefundable tickets, rather than paying the fully
refundable fare. If these passengers wish to change or cancel their flight reservations,
they may be charged fees to do so. In 2017 we found that these fees ranged from $0 to
$200 (each way). See GAO-17-756.




Page 24                                                     GAO-19-514 Airline IT Outages
     a hotel stay for passengers inconvenienced by flight disruptions, and
     of these
     •    four stipulate that passengers have to be away from home or from
          their points of origin or destination;
     •    five require that the flight disruption span certain hours (e.g., 10pm
          to 6am); and
     •    one includes credit for a long-distance phone call.

     Four of the contracts we reviewed include additional provisions for
     hotel stays (or other accommodations) to passengers with disabilities
     or other needs. For example, under its contract of carriage, American
     will provide amenities to maintain the safety and welfare of certain
     passengers if they are delayed (e.g., customers with disabilities,
     unaccompanied children, the elderly, or others with special needs or
     circumstances).

•    Food. Three airlines in our review provide for meals for passengers
     inconvenienced by flight disruptions in their contracts of carriage. For
     example, JetBlue’s contract of carriage provides for meal vouchers or
     pizza for flight delays of 6 or more hours. 54 In addition, airlines may
     deliver meals or offer other amenities to passengers waiting for
     delayed or canceled flights, even in the absence of the promise of
     food in the contract of carriage. In these cases, additional
     accommodations may be publicly announced on airline websites, by
     social media accounts, or through statements to the press, or they
     may be provided directly to individual flights or passengers at the
     airport. For example, in response to severe thunderstorms in 2017,
     Delta had pizza delivered to passengers waiting in airports across the
     Southeast.
•    Monetary compensation or travel credit. Inconvenienced
     passengers are not entitled to monetary compensation in the case of
     a flight delay or cancellation in the United States, and none of the
     airlines in our review includes such compensation in their contracts of




54
  Contracts of carriage for both Hawaiian and United also provide for meals after a 4-hour
or “extensive” delay, respectively.




Page 25                                                     GAO-19-514 Airline IT Outages
                                carriage. 55 Nevertheless, two airline contracts of carriage include
                                provisions for travel credit—above and beyond a refund—for flight
                                disruptions. JetBlue’s contract of carriage provides for travel credit for
                                canceled or delayed flights with several tiers, depending on the timing
                                of the cancellation or length of the delay. 56 For example, passengers
                                delayed over 6 hours are entitled to $250 credit for future travel on
                                JetBlue. Likewise, Alaska’s contract provides for a discount code for
                                future travel (and a letter of apology) for passengers delayed longer
                                than 2 hours. Although not included in Delta’s contract of carriage, the
                                airline provided $200 in travel vouchers to all customers with flight
                                disruptions lasting at least 3 hours for two of the IT outages we
                                identified, according to airline representatives.

Consumer Concerns          As mentioned above, collecting and analyzing passenger complaints is
Stemming from Airline IT   one way DOT helps ensure that an airline fulfills its obligations included in
Outages                    its contract of carriage and customer service plan, as well as any
                           additional accommodations that may be publicly offered. Our review of
                           passenger complaints filed with DOT stemming from airline IT outages
                           found that they included complaints related to the lack of monetary
                           compensation for delayed or canceled flights and refusals to refund other
                           expenses, such as rental cars or missed hotel or cruise reservations,
                           among other concerns. 57 For example, complaints related to a Southwest
                           outage in 2016 included several related to lack of compensation or other
                           amenities, such as food or hotel stays offered by the airline. As noted
                           above, Southwest’s contract of carriage does not provide for
                           compensation, food, or hotel stays in the event of a delay or cancellation.
                           Complaints filed after the Delta outage of 2016 acknowledged receipt of a
                           $200 travel voucher in compensation or a hotel voucher, but pointed to


                           55
                             By contrast, in the European Union, airlines are required to provide a set amount of
                           compensation when a flight is canceled, delayed, or when passengers are denied
                           boarding against their will. The amount of compensation depends on the length of the
                           delay and the distance to be traveled. See Regulation (EC) No 261/2004 of the European
                           Parliament and of the Council of 11 February 2004.
                           56
                             According to JetBlue’s contract of carriage, for cancellations where alternate
                           transportation is not available within one hour, passengers receive compensation in the
                           form of travel credits, ranging from $50 to $100 depending on when the flight was
                           canceled. Likewise, credits for delays range from $75 to $250, depending on the length of
                           the delay.
                           57
                             We reviewed airline IT outage-related passenger complaints received by DOT for six
                           domestic outages from January 2015 through June 2018.




                           Page 26                                                     GAO-19-514 Airline IT Outages
other non-refunded expenses incurred or difficulties in redeeming these
vouchers.

The three consumer or passenger advocacy groups with whom we spoke
raised several concerns with regard to passengers inconvenienced by
airline IT outages. Stakeholders we spoke with responded to these
concerns and addressed how airlines respond to IT outages.

•    Passengers may not receive the same accommodations. In the
     absence of requirements for accommodations or compensation,
     passengers are dependent on whether or not the affected airline
     chooses to be generous, according to the consumer advocates we
     interviewed. They also noted that mileage plan or first class
     passengers may receive more accommodations than others, even
     when passengers are affected by the same underlying outage, as
     may be true in other circumstances, as well. Representatives from
     one airline told us that they attempt to promptly address the needs of
     all of their passengers but acknowledged that accommodations may
     vary depending on passenger circumstances, including passenger
     status (e.g., frequent-flyer program members or VIP travelers).
•    Airline obligations toward affected passengers may be confusing for
     passengers. According to consumer advocates we spoke with, even if
     a passenger understands that an airline’s contract of carriage lays out
     its obligations to passengers affected by an IT outage, these contracts
     are often lengthy and difficult to understand. As noted above, our
     review of DOT complaints stemming from airline IT outages found that
     many passengers expected to receive compensation or other
     accommodations in response to these events, although such
     accommodations were not included in contracts of carriage. We
     reported in 2017 that airlines committed to reviewing their contracts of
     carriage to see if they could be simplified. 58
•    Contracts of carriage may not clearly exclude IT outages from force
     majeure events, according to consumer advocates. Flight disruptions
     caused by extreme weather, terrorism, and other events that are seen
     as being beyond the control of the airline are typically treated as
     special situations in airline contracts of carriage, and as a result,
     inconvenienced passengers may not receive accommodations that

58
  In 2017 we reported that airlines had committed to reviewing their contracts of carriage
to see if they could be simplified to improve transparency, according to a representative
from an airline advocacy group. See GAO-17-756.




Page 27                                                      GAO-19-514 Airline IT Outages
                       they otherwise might. 59 Consumer advocates voiced concerns that
                       airline IT outages might be treated as events outside the airline’s
                       control (i.e., Acts of God or force majeure events) given ambiguity in
                       how these exceptions are defined. We found that IT outages were not
                       explicitly included among the force majeure events identified in the
                       contracts of carriage we reviewed. In interviews and written
                       statements, representatives with four of the airlines in our review
                       varied in the extent to which they characterized airline IT outages as
                       incidents in the control of the airline, but generally indicated that
                       passengers would be accommodated as if the outages were.

                  We provided the Department of Transportation (DOT) with a draft of this
Agency Comments   report for review and comment. DOT responded by email and provided
                  technical clarifications, which we incorporated into the report as
                  appropriate.


                  We are sending copies of this report to the appropriate congressional
                  committees, the Secretary of the Department of Transportation, and other
                  interested parties. In addition, the report is available at no charge on the
                  GAO website at http://www.gao.gov.




                  59
                    To assist passengers in understanding the regulations that govern air travel, DOT
                  explains common terminology on its aviation consumer protection website. It includes
                  force majeure event, explaining that such events are those outside of the carrier’s control
                  that can alter a carrier’s schedule resulting in flight delays, schedule changes, and flight
                  cancellations. Usually these events include weather conditions, acts of God, or any other
                  event not reasonably foreseeable by the carrier and not within the airline’s control. DOT
                  reminds consumers that each airline has its own contract of carriage with its own terms
                  and definitions. For more information, see DOT, Common Terms in Air Travel,
                  https://www.transportation.gov/airconsumer/common-terms-air-travel.




                  Page 28                                                       GAO-19-514 Airline IT Outages
If you or your staff have any questions about this report, please contact
me at (202) 512-2834 or KrauseH@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to this
report are listed in appendix II.

Sincerely yours,




Heather Krause
Director, Physical Infrastructure Issues




Page 29                                           GAO-19-514 Airline IT Outages
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives for this report were to: identify (1) the Department of
              Transportation’s (DOT) and Federal Aviation Administration’s (FAA) roles,
              if any, in relation to airline IT outages and their effects and (2) what is
              known about these outages, including the number of flights and
              passengers affected.

              The scope of this report focuses on those airline IT systems that affect
              passenger experiences, including systems related to reservations and
              check-in, as well as those used by airlines for flight planning and
              dispatch. Our scope excluded IT systems involved in avionics (such as
              aircraft navigation systems); in-flight operations (such as passenger WiFi
              networks); and internal operations (such as company email systems). Our
              analysis included the 12 airlines that were required to report on-time
              performance information to DOT’s Bureau of Transportation Statistics
              (BTS) from 2015 through 2017, 1 including network carriers (Alaska,
              American, Delta, and United); low-cost carriers (Frontier, JetBlue, Spirit,
              Southwest, and Virgin America); regional carriers that provide service for
              partner airlines (ExpressJet and SkyWest); and Hawaiian, which provides
              a niche service. 2 Given the role of third-party IT providers, we also
              included Amadeus and Sabre in our scope.

              To identify relevant DOT and FAA authorities and responsibilities vis-à-vis
              airline IT outages in several areas, including operations, oversight, and
              data-collection, we reviewed relevant laws, regulations, policies, and
              guidance, as well as prior GAO work addressing agency roles. 3 We
              interviewed DOT officials with

              1
               Two carriers (Envoy and US Airways) were required to report performance information to
              BTS in 2015 but not in 2016 or 2017. We excluded them from our scope.
              2
               According to BTS, network airlines operate a significant portion of their flights using at
              least one hub where connections are made for flights to down-line destinations or spoke
              cities. Low-cost airlines operate under a low-cost business model, with infrastructure and
              aircraft operating costs below the overall industry average. Regional carriers typically
              provide service from small cities, using primarily regional jets to support the network
              carriers’ hub and spoke systems.
              3
               Prior GAO reports include National Airspace System: DOT and FAA Actions Will Likely
              Have a Limited Effect on Reducing Delays during Summer 2008 Travel Season,
              GAO-08-934T (Washington, D.C.: July 15, 2008); Airline Passenger Protections: More
              Data and Analysis Needed to Understand Effects of Flight Delays, GAO-11-733
              (Washington, D.C.: Sept. 7, 2011); Commercial Aviation: Information on Airline Fees for
              Optional Services, GAO-17-756 (Washington, D.C.: Sept. 20, 2017); and Airline
              Consumer Protections: Additional Actions Could Enhance DOT’s Compliance and
              Education Efforts, GAO-19-76 (Washington, D.C.: Nov. 20, 2018).




              Page 30                                                       GAO-19-514 Airline IT Outages
Appendix I: Objectives, Scope, and
Methodology




•   BTS, which collects data on airline on-time performance, and
•   the Office of the Assistant General Counsel for Aviation Enforcement
    and Proceedings and its Aviation Consumer Protection Division,
    which oversee consumer protections and receive consumer
    complaints. 4

We also interviewed FAA officials with the Office of the Chief Information
Security Officer, which advises the agency on matters relating to IT
management and security. Within FAA’s Air Traffic Organization, we
interviewed officials with Systems Operations Services, which administers
traffic management initiatives including ground stops, and its National
Airspace System (NAS) Operations and Office of Performance Analysis. 5
These two offices are responsible for programs related to air traffic control
systems and assessing the performance of the NAS, respectively.

Through our review of relevant plans and an interview with officials in
DOT’s Office of the Secretary, we determined that airline IT systems are
not included in federal plans for critical infrastructure protection.
According to DOT officials, outages in these systems do not have the
potential to reach established thresholds for potential casualties or
damages. 6 By contrast, air traffic control systems and airports are
included in sector-specific plans addressing critical infrastructure




4
 DOT has the authority to stop airlines from engaging in unfair or deceptive practices, or
unfair methods of competition, and may promulgate consumer protection regulations
under that authority. See 49 U.S.C. § 41712. For more information about DOT’s oversight
of airline consumer protection, see GAO-19-76.
5
 In general, ground stops occur when flights destined to arrive at the affected airport(s)
are held at their departure point. These can be applied to a specific airport or affect an
airline’s entire fleet.
6
 Critical infrastructure are those systems and assets, whether physical or virtual, so vital
to the United States that their incapacity or destruction would have a debilitating effect on
security, national economic security, national public health or safety, or any combination of
those matters. USA Patriot Act of 2001, Pub. L. No. 107-56, §1016(e), 115 Stat. 272, 401
(codified at 42 U.S.C. § 5195c(e)).




Page 31                                                       GAO-19-514 Airline IT Outages
Appendix I: Objectives, Scope, and
Methodology




protection in the case of a terrorist attack or other natural or manmade
disaster. 7

To determine what is known about airline IT outages, we reviewed DOT
data sources, including BTS and FAA performance and operations data, 8
as well as passenger complaints received by DOT in response to airline
IT outages from 2015 through August 2018. We also conducted
interviews with or received written responses from 11 (of 12) airlines in
our scope, 9 and interviewed other stakeholders, including third-party IT
system providers Amadeus and Sabre; an IT risk expert (Robert
Charette); industry associations, including Airlines for American (A4A),
the Regional Airline Association (RAA), and Airports Council International
(ACI); and employee union representatives with the Air Line Pilots
Association (ALPA).

We determined that DOT and FAA data were not designed, and could not
be used, to comprehensively identify airline IT outages. To identify airline
IT outages in the absence of detailed DOT or FAA data, academic
literature, or internal (proprietary) airline data on these incidents, we
validated a preliminary list of such outages developed using open source
material that included media coverage and publicly available airline
sources for outages from 2015 through 2017. Specifically, we

•   searched GAO subscription databases (e.g., ProQuest, Nexis, and
    EBSCO) to create a preliminary list of 37 airline IT outages from
    media coverage;
•   performed additional searches of articles and official airline websites
    to collect more information on and corroborate incidents identified;
7
 The Presidential Policy Directive/PPD-21—Critical Infrastructure Security and Resilience
(Washington, D.C.: Feb. 12, 2013); the Department of Homeland Security’s (DHS),
National Infrastructure Protection Plan (NIPP) 2013: Partnering for Critical Infrastructure
Security and Resilience (Washington, D.C.: 2013); and DHS and DOT, Transportation
Systems Sector-Specific Plan (Washington, D.C.: 2015) establish DOT’s role in protecting
critical infrastructure.
8
 We assessed the extent to which airline IT outages could be identified—or their effects
measured—in several sets of operational data including, FAA’s Aviation System
Performance Metrics (ASPM), Operations Network (OPSNET), National Traffic
Management Log (NTML), and Airline Service Quality Performance (ASQP).
9
 Two (of 12) airlines in our scope merged with other carriers prior to our interviews, so did
not respond separately: ExpressJet with SkyWest and Virgin America with Alaska. One
airline declined to be interviewed, although airline representatives provided context on the
effects of airline IT outages on operations.




Page 32                                                       GAO-19-514 Airline IT Outages
Appendix I: Objectives, Scope, and
Methodology




•    provided our list of identified IT outages to the 12 airlines in our scope
     and two third-party IT providers (Amadeus and Sabre) for
     confirmation; and
•    corroborated 20 of the identified IT outages with FAA’s National
     Traffic Management Log’s (NTML) log entries and DOT’s consumer
     complaint data.

Through this process, we were able to corroborate 34 airline IT outages
from 2015 through 2017, and we are confident that our list of outages
includes all of the outages large enough to garner national-level, multi-
day media coverage and an official response from an airline executive. 10
While accurate, our list is not comprehensive because three airlines and a
third-party IT provider identified additional outages that we did not find in
our preliminary search, including one airline that shared information on
more than 20 additional outages. We did not include these additional
outages in our count to ensure that our methodology was consistent.

To account for outages that may have occurred subsequent to our review,
we identified an online listing of airline IT outages and validated 9 of 11 of
the outages included from 2018 through January 2019 using publicly
available airline or airport information or coverage in at least 3 media
sources. 11 This list and our validation process provides evidence that
airline IT outages continued to occur during this timeframe, but does not
match the rigor applied to the identification of outages we identified from
2015 through 2017. As a result, we are not confident that this list
identified all of the outages large enough to garner national-level, multi-
day media coverage and an official response from an airline executive.

Once we had identified airline IT outages through other sources and
could look at data for specific dates, we were able to use DOT and FAA
data to provide additional insight into flight disruptions (i.e., flight delays or
cancellations) and ground stops caused by outages. For example, we
10
  We excluded three outages we identified initially from media reporting because these
outages fell outside the scope of our review based on additional information provided
during interviews or by airline representatives about the outage cause or IT system
affected. Additionally, one airline opted to verify only the IT outages that resulted in 100 or
more delayed flights or 25 or more canceled flights.
11
  The catalog of outages is presented by Sungard, an IT service provider. See Sungard
Availability Services, Airline Outages Timeline, 2007–Present,
https://www.sungardas.com/en/industry/airline-outages-timelines/ (accessed Mar. 8,
2019).




Page 33                                                         GAO-19-514 Airline IT Outages
Appendix I: Objectives, Scope, and
Methodology




requested that FAA conduct analysis on 3 of the 34 outages we had
identified to determine what FAA operational data could reveal about the
effects of these outages. We selected these 3 outages to reflect a range
of flight disruptions for comparative analysis, including variations in size
and cause of the outage. We also assessed the extent to which the
effects on passengers could be seen in the BTS on-time performance
data reported by airlines. For these data, we sought to determine the
cause and magnitude of delays and cancellations for each outage. We
also reviewed NTML log entries for the dates of known outages to further
identify potential information, including incidents of ground stops. Finally,
to obtain more information about the potential effects on passengers
resulting from these events, we reviewed consumer complaints to DOT
stemming from airline IT outages. These complaints were provided to us
by DOT’s Aviation Consumer Protection Division and include reference to
the associated outage.

To understand how airlines accommodate inconvenienced passengers,
we reviewed airline contracts of carriage for 9 of the 12 the airlines in our
scope. These contracts are the legally binding contracts between carriers
and passengers and may include specific provisions such as refund
procedures and responsibility for delayed flights, among other things. We
excluded two regional airlines (ExpressJet and SkyWest) that operate
under the contracts of carriage of their mainline partners and Virgin
America, which merged with Alaska in 2018 and no longer has a separate
contract of carriage. In addition to the stakeholders mentioned above, we
also interviewed consumer or passenger advocacy groups, including
representatives with the Consumers Union, the National Consumers
League, and Travelers United to identify any concerns regarding
consumers affected by airline IT outages.

We conducted this performance audit from February 2018 to June 2019
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




Page 34                                            GAO-19-514 Airline IT Outages
Appendix II: GAO Contact and Staff
                  Appendix II: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Heather Krause, (202) 512-2834 or KrauseH@gao.gov.
GAO Contact
                  In addition to the individual named above, other key contributors to this
Staff             report were Jonathan Carver, Assistant Director; Molly Laster, Analyst-in-
Acknowledgments   Charge; Neha Bhatt; David Hooper; Rich Hung; Delwen Jones; SaraAnn
                  Moessbauer; Emily Mussey; Josh Ormond; Corinne Quinones; Pamela
                  Snedden; James Sweetman, Jr.; and Elizabeth Wood.




(102607)
                  Page 35                                           GAO-19-514 Airline IT Outages
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