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By Allen Campbell, JD, MBA

“Season’s Greetings” to our readers and everyone else on our planet. This is the time of year when joy, goodwill and appreciation resonate in the hearts and minds of billions of people, and families and friends are reunited around the world.

This is peak travel season. Was it a coincidence that the United States Department of Transportation announced its headline-grabbing $140 million fine against Southwest Airlines on December 18th? Probably not.

In its press release, the DOT said the fine was for

“numerous violations of consumer protection laws during and after the operational failures that cancelled 16,900 flights and stranded over two million passengers over the 2022 Christmas holiday and into the New Year. This penalty is 30 times larger than any previous DOT penalty for consumer protection violations. The majority of the penalty will go towards compensating future Southwest passengers affected by cancellations or significant delays caused by the airline.”

The DOT went on:

“The penalty is in addition to the more than $600 million in refunds and reimbursements that DOT already ensured Southwest provide passengers who faced travel disruptions during the operational meltdown. In September 2022, at the urging of Secretary Buttigieg, Southwest Airlines made significant changes to its customer service plan that entitled passengers to reimbursements for expenses such as meals, hotels, and ground transportation if a flight is significantly delayed or cancelled due to an airline issue. As a result of DOT’s actions, Southwest was legally required to adhere to those commitments during the 2022 holiday travel meltdown.

“In total, Southwest will pay over $750 million for the holiday meltdown — with the vast majority going to passengers for refunds, reimbursements, rapid rewards, or future compensation — due to DOT’s actions.” (For the text of the entire announcement, see

There is a lesson here: In this era when computerized command, control and communications systems are essential to business – in fact, existential – risk management is ever more important. It is not just the threats of outside hackers that need attention, but also the fundamental need for system reliability. In our opinion, there is no greater risk to a business than systems failure or breach.

A personal note: Dallas is Southwest’s home, and many of us in the State of Texas have been blessed to have the company serving us since its founding in 1967. Southwest brought us cheap, reliable air travel, and it was often a fun experience. Who knew that flight attendants could have such a sense of humor? I once had a problem with a SW flight, and I wrote a letter of complaint to Herb Kelleher. Herb’s secretary wrote me back an apology, gave me a refund of my fare, and also gave me a free round trip ticket to a destination of my choosing. Wow! I made a conscious choice at that time to be a loyal customer for life, and I still am.

So, I’m feeling for you, guys. The last several months must have been tough on you. But your management have committed the company to system reliability, and I’m confident you will get it right. It’s been a great ride, and I expect it to be even better.

Happy holidays!