Kurt Heidemann:
Today's SWAPA number is $70,000. That's roughly what SWAPA spends on an arbitration when we and the company can't settle a grievance before it gets that far. Arbitrations are a required part of the RLA process that we operate in as professional pilots. Today we're going to talk with Contract Admin Chair, Seth Kornblum about some of the work that he and his committee do to defend our CBA from violations and our pilots from potential discipline.
Amy Robinson:
I'm Amy Robinson.
Kurt Heidemann:
And I'm Kurt Heidemann. And here's our interview with Seth.
Amy Robinson:
So Seth, let's go ahead and start with... I think there's a little confusion on the difference between when people call contract admin and the Contract Admin Committee. Can you distinguish that just a little bit for our members who maybe don't know the answer to that?
Seth Kornblum:
Sure, absolutely Amy. There is a difference between the contract admin staff and the Contract Admin Committee. The staff are the ones that do the bulk of the work when it comes to handling day-to-day inquiries, your pay audits, your scheduling legality questions, those are handled by our full-time staff. We have eight full-time staff in the office, many of whom are former schedulers for the company or former training schedulers. And so they have a lot of expertise, a lot of behind-the-scenes knowledge in how the company's processes work. So they're the ones that handle the bulk of the daily inquiries.
So over on the committee side, there's three of us. There's myself, there's Dave Kudish and Rob Odom. And when an issue requires a little bit of a pilot touch to it, we'll get involved. And we are also the ones that take the bulk of the arguments to the company. Normally our staff exchanges issues with the company every day by email and phone call through the various departments at the company, whether it's scheduling, planning, training, payroll, what have you. The staff handles most of those day-to-Day inquiries. But when we run into issues that cannot be solved or there've been a couple back and forth volleys and it's still not solved, that's when your committee steps in and escalates those arguments to the company.
Kurt Heidemann:
Now Seth, at SWAPA, a lot of our committees run 24/7 or have access 24/7. Is that the case with contract admin?
Seth Kornblum:
Yes, contract admin is available 24/7 for time critical issues. We have one staff member who's designated as the on-call person at all times. And in the event that you have a truly time critical issue like a legality, like you're being sent to operate a flight and you think it might be illegal, something like that, something of a really time critical nature, that is what that number is for. We ask that you don't use that number after hours for non-time critical issues as we've only got one person on staff to handle those things. And when we've got a pilot who's got an urgent time critical matter, we want to make sure that our staff member is not tied up handling something that's more routine like a pay audit.
So again, while we are available 24/7, again, we ask that you only call the staff after hours for something that's truly time critical. When it's not time critical, we ask that you just leave a voicemail or you can always send an email to [email protected].
Kurt Heidemann:
Now Seth, my understanding is your committee is really split and has two paths. You focus on contract compliance and then you also focus on discipline. Is that pretty much how you split up your committee?
Seth Kornblum:
Yeah, I'd say they're really all related into contract compliance because frequently when we have a discipline issue, we have to make sure that the contractual provisions are followed in the way the company doles out that discipline. So that's why disciplinary issues do fall under the contract admin umbrella. But from a practical standpoint, as far as managing daily workload, yes we do have some folks that are more dedicated to working pilot investigation, discipline issues and other folks who are focused more on contract compliance issues.
Kurt Heidemann:
Let's talk about contract compliance than first. Let's talk about something that's near and dear to me, Contract 2020 rewrite. From your perspective, having to administer contract compliance, what's the rewrite mean to you?
Seth Kornblum:
The rewrite to us will be really life-changing. We've been tasked for years administering an agreement that is gray in so many areas. And no matter what you do, you'll never achieve perfect language that covers all scenarios, you won't. But we have the benefit of history and data informing what we supplied to the NC and the rest of the SWAPA team as far as areas we saw gaps in language, areas that needed to be clarified. So our new agreement will help dramatically fill in a lot of those gaps, if you will, and acknowledging that there always will be gaps.
One thing that is huge about how NC is handling the process, and I've been in the room to witness this on many occasions, is our note-taking is so much more advanced than it once was. So right now when we have to try to resolve a contractual dispute, you have to get into the bargaining history, bargaining notes, and the reality is right now when we're solving some of these contract problems of the current book, I've got one hand tied behind my back because the notes are lacking, they're handwritten and they're laughable in a lot of cases, very little information about who was even in the room.
So the rewrite is huge because even if we were to have a situation where the language doesn't quite hit the mark, we've got much better notes going forward. We know who is there. We've got two note takers in the room really doing their best to keep a record of how the discussions progressed and we'll be able to fill in those gaps much more easily.
Kurt Heidemann:
I'd like to add to that actually. You said we have two note-takers and each day of negotiations, those two produce between 50 and a 100 pages of typewritten notes. So compare that to what you're describing. How many pages of notes do you have on any single issue?
Seth Kornblum:
And that's a great point. Sometimes we have one line about an issue or the issue is completely omitted from the notes.
Kurt Heidemann:
More than almost anything, the notes are going to be critical for your committee going forward.
Seth Kornblum:
Yeah, I agree.
Amy Robinson:
When you say that you have one line on notes, how do you actually resolve that type of dispute? If you have no history to go back on something, how do you actually resolve some of those issues?
Seth Kornblum:
Thanks for that question, Amy, and that really sheds a lot of light on why we have such a hard time settling some of these issues because we don't have a written record of the history and then we're left to try to figure out who was in the room and what their recollections were? It wasn't long ago, I had to call a long since retired SWAPA official and try and see what he remembered from 20 years ago, that's really not a great way to do business.
And so with our new emphasis on taking great notes and the fact that our note takers are taken between 50 and a 100 pages of notes a day and we always know who is in the room for the discussions, we'll have a much easier time going forward. And we'll also have basically a hard stop as far as how far back in time we have to go. Since we've covered every single page of the agreement in this new negotiating cycle, I shouldn't have to go back 20 years to find someone in a retirement home to ask what happened on this day. We're not having to go back any further than the time period of this negotiating cycle.
Amy Robinson:
I guess that leads me to ask how many open grievances do we currently have?
Seth Kornblum:
We are down, and that's crazy to even say down to this number, but we're down to a 140 in the process.
Amy Robinson:
And what happens to those grievances with this contract?
Seth Kornblum:
It's our expectation that all those 140 grievances get resolved before we ratify this new tentative agreement. The company does not just get a pass on the sins of the past, if you will, on the violations over the last few years. Now, clearly when you look back at some of the grievances, there are some that are stronger cases than others because of some of the challenges we've talked about as far as how we resolve some of these disagreements. Some of these grievances may be settled in exchange for new language that addresses the problem in the new agreement, so it won't be a problem in the future.
There are some that we expect monetary payouts to our members for sins of the past. And ultimately, as a product of negotiations, there may be some that go away because we don't have sufficient notes or other evidence that would meet the standard of being able to achieve a victory in arbitration.
Kurt Heidemann:
Get us from a guy says that there was a contract violation and then you take it to the company and the company says, "No, we don't see it that way." Then/ what happens? Walk us through that process
Seth Kornblum:
Sure, Kurt. So we've tried to be much more diligent about exhausting all avenues before filing a grievance and the company's been better about supplying us access to folks that have both expertise and authority during some of these discussions. It used to be really frustrating because when we would have a contractual dispute and we disagreed with what a member of middle management did, we would show up for the grievance hearing and then the only person the company would send is that very same middle manager that we felt was responsible for the violation in the first place.
Kurt Heidemann:
So that guy's deciding that he was wrong is what they're basically saying. He has to decide that.
Seth Kornblum:
Yeah, which is never going to happen. It made me feel like a teenager asking mom for the keys to the car. Mom said, "No," and then I'm asking mom again, "Can I have the keys to the car?" Well, the answer is still no, and it's no surprise. So as of late, the company is at least providing someone else, some other designee of the VP of flight ops. Still not satisfied that we're getting a full meaningful exercise in that process, but it has gotten better.
Either way, as I said, we've been trying to be very deliberate, very intentional about exhausting all avenues before we file the formal grievance and before we go down the road towards arbitration.
Kurt Heidemann:
After that meeting, is that when it's time to file a grievance or how does that play out?
Seth Kornblum:
So it really depends on the situation because one thing that's unfortunate is that the company has also used the timeline and the contract as a trip wire at times. So we always have to be cognizant of making sure we get a grievance filed within the timeline and we want to make sure there's no gray area as to when the timeline starts. The timeline is 65 days, spelled out in the contract, from the time we knew of the violation or should have known of the violation.
And so that's the issue where we want to make sure that the company's never able to muddy things and claim that, "Well, we should have known by a certain date." We really want to make sure the facts of the case are going to be heard on its merits and that we're not going to get clobbered with some trip wire from timeliness that prevents the issue from even being heard.
So Kurt, back to your question as to when we file, it just depends on the case, how black and white is it as far as when the timeline starts, but we will try to exhaust every avenue. We'll start with whichever middle manager we have to, and then we'll go to their boss if need be, if it's appropriate depending on the topic, and we'll look for the next layer of management, again, depending on the situation. And at some point ultimately in there, a formal grievance is filed if we haven't been able to resolve the matter.
And once that formal grievance is filed, it takes us into Section 16 of our contract and there's what's known as a 16C and 16D process. And those processes are designed to get us, both sides to exchange information related to the dispute. And then the 16D portion of that is an actual meeting again with either the VP or his designee. It's always a designee. The VP never shows up these days.
Amy Robinson:
So at the end of the process of filing a grievance, what is the end result? What's the last final thing that you can do with a grievance?
Seth Kornblum:
Too often we are left to take the grievance process all the way to its end, which is to system board of adjustment, basically it's arbitration.
Amy Robinson:
Walk members through what the process is for an SBOA?
Seth Kornblum:
So if a grievance gets denied by the company, SWAPA has the option to appeal that decision to an arbitration board. And the way that looks is that it's a panel of five people. Two members of the board appointed by the union, two members of the system board appointed by the company and then a neutral arbitrator that will ultimately rule if the two members from the company and the two members from the union end up deadlocking.
Kurt Heidemann:
And just to clarify, because this always confused me, when you say SBOA, that's a system board of adjustments and that's another term for arbitration, we use those interchangeably?
Seth Kornblum:
Yeah, that's right. So a system board can take on a couple of different flavors. It can be just a four-person panel with two members of the company and two members of the union and no neutral arbitrator, but we don't bother using that anymore because they frequently just deadlock and it becomes a waste of time. So we do use system board of adjustment and arbitration interchangeably, but all of ours end up being heard with the neutral arbitrator in the mix.
Kurt Heidemann:
So then what is the arbitration process for? I've never been through one. Is it like a trial basically or is it just a mediated negotiation? What is it?
Seth Kornblum:
Well, the process starts back even before the day of the proceedings. It starts months and months in advance and even just deciding who the arbitrator's going to be. And so there used to be fights over as we would say, the shape of the table before we even sat down at the table. Although these days, that seems to be working much better between SWAPA and the company. So the first part of this process is we have to decide on the arbitrator and we do have a panel of arbitrators that we pick from. However, due to certain traits of a particular arbitrator, either the company or the union might object to a specific arbitrator for that particular case.
So either way, there's discussion over who the arbitrator's going to be and then we have to nail down the scheduling logistics of when the arbitrator's available and when the company and SWAPA can produce witnesses. So those are the first part of the process. Even just getting the whole proceeding calendared is a process in and of itself, but once we start the clock towards the actual proceedings, we get into section 17 of the CBA which covers that, and there are filings that have to be made with the arbitrator well in advance, basically just nailing down what the issue is that we're trying to arbitrate.
Kurt Heidemann:
So besides the issues on the table, what else is done prior to going into the arbitration?
Seth Kornblum:
So there's many things happening as we get closer and closer to the actual hearing date. Again, those filings with the arbitrator have to be made. We have to figure out what exactly the issue is that we're arguing over, which sometimes can be a little complicated because some of these issues are fairly nuanced. But during that process also, we're identifying witnesses that would be helpful to the case. We are trying to gather up all the evidence for the case, which in a contract case might be printouts of people's schedules. It might be statements from pilots of interactions they've had with scheduling. If it was a discipline case, it might be witness statements to an event, what have you. Depending on the case, we're collecting evidence that can be presented to the arbitrator at the hearing and entered as exhibits that will eventually be put into the record at the hearing.
So there's a lot of prep work before the arbitration actually takes place. A lot of working with the witnesses to make sure that we really do have a true understanding of what the situation was. And then when we get to actual hearing day, the hearings are usually held offsite from the company and offsite from SWAPA, basically neutral grounds. We usually use a hotel. We'll rent out a conference room in a hotel and they'll set up a giant U-shaped table. And on one long leg of the U will be SWAPA, SWAPA's attorneys, outside legal counsel, myself, and usually some SWAPA staffers as well.
On the other long leg of the U will be the company's attorneys, their outside counsel, their corporate representative, and other staffers from their side. And then on the short leg of the U, the middle if you will, will be the neutral arbitrator in the middle and he's flanked by the two company panelists and the two union panelists. And in the middle of the U, there's a court reporter taking a stenographic record and a table for the witness and it looks like a miniature court proceeding.
Kurt Heidemann:
And so then you basically have a court proceeding like you said, and then days or weeks later, they'll issue a judgment or a ruling. I guess it's not a judgment.
Seth Kornblum:
It can be called an award, an order, a judgment. I'm not a lawyer, but I've heard those terms used fairly interchangeably for that. So the way it works is that the hearing itself will last anywhere from one day to four days if you can believe that. They can be quite lengthy. So several days of actual testimony. And then about a month later, the court reporter will have generated a written record, a transcript rather of all the testimony. And then using that transcript, the attorneys on both sides will spend weeks or months putting together a post-hearing brief for the arbitrator to consider. And those briefs are turned into the arbitrator on the same day. And then the arbitrator will take his time to deliberate on the matter and finally issue his order. And it can take months. There's no set timeline for when the arbitrator has to answer. So it is a very lengthy process at times.
Amy Robinson:
So when an arbitrator makes a ruling, is that ruling binding? Because we talk about in the RLA process that they offer a binding arbitration, is the same thing applicable here in an SBOA?
Seth Kornblum:
So yeah, the ruling of the arbitrator is binding in the grievance venue, yes.
Amy Robinson:
So you said that sometimes it can take a long time to get those rulings. So when we get those rulings, are they always in favor of us or sometimes are they things that we would not necessarily... We didn't really love the ruling?
Seth Kornblum:
Frequently the rulings are not in our favor as of late.
Amy Robinson:
What would you attribute that to?
Seth Kornblum:
The company does basically a cost-benefit analysis on their side, I believe. And some of these issues that we've had to talk about from the 2017 2018 timeframe, like online reassignment or IRAPs, as I mentioned before, there are not great notes going back in time. And when the company's able to find one old negotiator who's able to support their position verbally, who will show up for $500 a day and testify in their favor, they'll see if they can go ahead and prevail. Because remember, and this is a key point in a contractual interpretation case, the burden of proof falls upon SWAPA not the company.
So when the company has been applying the contract a certain way, and we take issue with that, if the language is ambiguous and we don't have great notes, the company figures they've got better odds at the arbitration than we do. And that's true because again, the burden of proof is on the union in those contractual interpretation cases. So when there are no notes and you've got ambiguous language and you've got an old SWAPA negotiator that's willing to testify for the company, that does present certain challenges for us.
But when the company is trampling on our contract, we really don't have anything to lose except the time and effort and the money that goes into the hearing. The union's most important job is to negotiate and defend its contract. So we're going to do that at every opportunity. And even though the odds are stacked against us, we're still going to attempt to defend the CBA to the best that we can.
Amy Robinson:
Okay. So one thing that I think our listeners would like to hear, or what are some SBOAs that you have won and what did that do for our membership?
Seth Kornblum:
Yeah, I guess before we go there, it's important to remember that a lot of the settlements we achieve only come about because we have the arbitration actually scheduled. So there are some cases that produce victories and we settle them so to speak on the courthouse steps if you will, before we even get there. So even though an arbitrator has not necessarily had to rule, we've still produced a victory for our pilot group through a favorable settlement just by having the case scheduled.
And the way that works is because a lot of times when the company has denied a grievance of ours, whoever in middle management has dug in their heels on the issue, and then it's put up on a shelf, we appeal it to arbitration and nothing much happens with it. But then starting with maybe two months out, three months out, the company hires outside counsel to represent them in the matter, then it gets eyes on the case once again. And so that's why we frequently find ourselves being able to achieve good settlements for our guys. As the arbitration gets closer, there's more pressure and the company is more apt to settle at that point.
Kurt Heidemann:
But Seth, if it's something that we're going to win, if they're outside counsels looking at it and going, "Southwest, you probably want to settle on this because it looks bad for us," why don't we just stay on the offensive and just take them all the way to arbitration and get that ruling? Why settle?
Seth Kornblum:
If it was black and white, clear as day and absolutely undisputed, we would come out as the victors. We wouldn't have a dispute in the first place. And so many of these things that look like they would be a win really are uncertain once it falls into an arbitrator's lap. You never know what an arbitrator's really going to do. And as pilots, we want to keep our hands on the controls the whole way through the process. It doesn't make sense to turn the controls over to someone else. And a big reason for that is in a settlement, we have our hands on the controls, if you will, and are able to negotiate a settlement with the company that works for us.
The problem is sometimes if things go all the way to an arbitrator's ruling, there are times where the arbitrator can declare that we are in fact victorious that we were correct, but sometimes it's about all the arbitrator can do if the situation's a little unclear. The arbitrator cannot do what's known as, "Gap filling." In other words, if there's not specific language to cover the situation, the arbitrator cannot insert new language or make the company abide by new language. So frequently, working out a settlement is a better way to go.
Amy Robinson:
Go ahead and give us an example of that?
Seth Kornblum:
Sure, Amy. So several years ago we saw issues where we felt like the company was playing fast and loose with the duty day limits in section five delta of the contract. And the way they were doing that was by using ridiculous connection times during reassignments to make the day appear to fit within the confines of the duty day limits, even though you could clearly see that it would never work. For instance, let's say the 5D limit was... I'm just going to pull numbers out of the air. Let's just say it was a 14-hour day that was going to be allowed by those limits and the company reassigned somebody into a 14-hour day, but they did it using negative connection times in-between one of those legs. Well, that time's got to be accounted for somewhere. And clearly, what's happened there is that they've used the crowbar, if you will, to fit the day into the limits prescribed in 5D.
Now, if we had gone all the way to the ruling with the arbitrator there, the arbitrator could say, "Yes, SWAPA, you are correct." And that's the way it was heading during the arbitration, we felt. We were willing to stop the arbitration proceedings to write out a settlement instead. And in that settlement, we were able to say that when the company computes their duty day limits, that they have to apply at least a 20-minute connection time in-between legs.
Now, I'm not saying 20 minutes is sufficient in our current operation, but it is something that we were able to work out and an arbitrator would not have been able to give us any time limit. All he would've been able to do is agree with us that the company's behavior was violative, but he would not have been able to prescribe any particular connection time. And so that's a perfect example there of why a settlement sometimes makes more sense than going all the way to an arbitrator's ruling.
Kurt Heidemann:
I'll add that those minimum connect times, and it's more than just 20 minutes, it depends on the type of connection. We took those from that settlement and applied them and have codified them in Contract 2020. So you can see that the association is building on prior agreements or positive outcomes from these arbitrations.
Amy Robinson:
So we've talked a lot about contract compliance. Let's talk a little bit about discipline. What exactly is the process where a discipline case is concerned?
Seth Kornblum:
Discipline cases do look a little differently. Those usually start at the rep level, the domicile rep level, with a member being called in for a 15D meeting, which is a fact-finding meeting basically. And the reps are there with the pilot in question, and that's the start of the process. And contract admin is supposed to be brought along every step of the way with the representatives, and so we can advise the reps on other similar issues that have occurred and both contract admin and legal, our in-house legal team actually takes the majority of this work. They take on prepping the members when need be before these meetings.
First of all, we want to make sure that they're being honest. We never want to go along for the ride if someone's being dishonest. We don't want to waste member resources if there's a case of integrity that's in question. So we want to make sure to do our own diligence, make sure that we understand the facts and that the member does not incriminate themselves unnecessarily, but our legal team does a great job prepping them and there's a contract admin member always on the calls helping with that prep process as well.
Kurt Heidemann:
Seth, I've got a question. Is there a difference either contractually or practically between an investigation by your chief pilot or flight ops or an investigation from corporate security or an investigation from employer relations or some other company organization?
Seth Kornblum:
So they do look different to the pilot, when you've got an employer relations meeting, when they're investigating an allegation of some sort of a discrimination or if corporate security is investigating the matter. But ultimately, both those departments merely provide their recommendations to flight ops. So when a pilot is having one of those fact-findings through employee relations or corporate security, sometimes it stops right there because if they find that the claim is unsubstantiated against the pilot, they'll make a recommendation to flight ops just to go ahead and drop that matter. However, if the issue is substantiated or deemed substantiated by them, then they'll make their recommendations... They'll present their findings rather to flight ops, and then it will result in the 15D process that a pilot normally sees. And that starts there and the Chief is then armed with the information provided by ER corporate security.
Kurt Heidemann:
And as a pilot, if I get a phone call that says I'm one of those groups, it doesn't matter whether it's ER or corporate security or the chief pilot, do I need SWAPA representation for those? Should I answer those calls? Do I have to answer those calls?
Seth Kornblum:
You should absolutely contact your reps for assistance. If you have any difficulty reaching your reps, you can feel free to contact us here at contract admin or at SWAPA legal as well. But your reps are the correct starting point.
Kurt Heidemann:
Does that include even if they're contacting me as a witness?
Seth Kornblum:
You should absolutely still contact SWAPA in those situations as well. Frequently those issues have tentacles and we don't know where those tentacles go, so you should absolutely contact SWAPA in those situations as well.
Amy Robinson:
You suggested that our members call SWAPA no matter what. So what are some things that are being investigated discipline? What are those things that you're seeing most frequently as of late?
Seth Kornblum:
So it used to be that most of the discipline type issues were related to an incident involving operation of the aircraft or some other aspect of how you conducted the operation. These days though, it seems like it's usually more about hurt feelings. If you've said something that causes hurt feelings or offense to another employee, that's when you'll find yourself the subject of these kind of phone calls from the company. So the majority are things that occur on the airplane, some sort of interpersonal communication that rubs somebody the wrong way.
Amy Robinson:
And those usually happen in the aircraft?
Seth Kornblum:
Usually they're happening during the workday, whether it's on the aircraft or in an exchange between yourself and ground operations employees, whether it's on the inner phone with the ramp crew or just the face-to-face interaction with CSAs, ops agents, that sort of thing. That's where we see some of these conflicts occur most. We also see investigations related to social media posts. Remember that anytime you post something on social media, the company feels that that's within their purview if a clear nexus to the company can be drawn between you and the company.
Kurt Heidemann:
Seth, when you're talking about interpersonal problems, I think the elephant in the room can be the issues on overnights and crew hotels. Is that really an issue for us that you see?
Seth Kornblum:
While that has happened, statistically, that's just not the norm of what we see. Issues at the hotel are few and far between. The majority of issues happen during the operational workday or are issues caused by social media posts that aren't well-thought-out.
Amy Robinson:
So Seth, is there anything else that you would like our membership to know about your committee or about contract admin that maybe we didn't cover on this podcast? Because I do feel like you guys do cover a wide range of things, so I want to make sure we've covered everything that would be needed.
Seth Kornblum:
Sure, Amy, thanks for that. Yeah. One thing that people forget is that contract admin isn't just about administering the contract, it's also about educating you on the contract. So there are no stupid questions. If you have any contract related question, we always invite you to reach out to us at [email protected], or feel free to call into the office and ask our staffers anytime.
And on that note, actually, we also recommend that rather than reaching out to the committee pilots directly for typical daily issues like pay audits and daily legalities and that sort of thing, that you reach out to the staff rather than us because you'll get a faster response. Whereas your committee pilots may be in meetings with the company that can become extended or we may be out flying, what have you, we've always got good coverage on our staff email and our staff phone numbers. So always feel free, ask a question. There are no stupid questions.
And the other thing I'll say is to use the cliche here of if you see something, say something, because sometimes you might be the first person to discover some violative behavior. In fact, a couple of years back, we had a probationary pilot and she was just about to get off probation and she uncovered an issue, which turns out had been happening for years, but until this one lone probationary pilot had the courage to call it out to us, we never knew that violation was occurring. And it turns out it had been occurring for a long time.
So again, remember, we're here to educate you as well, but also, if you get a sneaking suspicion that there's a violation at all, please reach out to us. If it's nothing, we'll tell you it's nothing, but you might be the one to discover a very large CBA violation.
Amy Robinson:
Thank you to Seth for being on the show today. We know he's busy and we appreciate him taking the time to chat with us.
Kurt Heidemann:
As always, we'd like any feedback that you have for us. Please drop us a line at [email protected]. We really do want to hear from you.
Amy Robinson:
And finally, today's bonus number is zero. That's the goal for open grievances when we ratify Contract 2020. Both Southwest Airlines and SWAPA need to start with a clean slate, and then with cleaner and clearer language in the rewrite, we expect we'll have significantly fewer disagreements going forward.