Regulatory Alert: FAA Issues Emergency Order Restricting Air Carrier Operations at 40 Airports

November 6, 2025

This evening, the Federal Aviation Administration (FAA) issued an emergency order requiring air carriers to reduce their total daily scheduled domestic operations by 10 percent at 40 different “high impact airports.” The unprecedented directive will be implemented in phases, with carriers required to decrease their operations by 4 percent beginning tomorrow, 6 percent by November 11, 8 percent by November 13, and 10 percent by November 14. The order outlines the restrictions and a series of other requirements, which are discussed below, that apply to each Part 121 and commuter or scheduled Part 135 air carrier operating at any of the 40 airports.

Recognizing the growing impacts from the ongoing shutdown, earlier today, AAAE and a broad coalition of aviation stakeholders called on Congress to “end the shutdown without delay.” The statement, released by the Modern Skies Coalition, further stated: “This prolonged shutdown has strained the aviation system and its dedicated workforce to unacceptable levels of stress and disruption. The American flying public deserves nothing less than a fully operational aviation system. It’s time for Congress to act decisively.”

You can view FAA’s press release here and emergency order here. With the order taking effect tomorrow, we urge members to keep us informed of any impacts from the government shutdown and the new operational restrictions. We are in regular communication with Capitol Hill and FAA on the shutdown and the emergency order. It is important for us to understand any impacts that may be occurring at your facilities, as that will help us in our discussions and engagement with lawmakers and FAA officials.

Background and Justification. Yesterday, Secretary of Transportation Sean Duffy and FAA Administrator Bryan Bedford announced that effective tomorrow, the FAA will begin to reduce capacity at 40 “high traffic” airports unless a deal is reached to end the government shutdown. In the order released this evening, FAA laid out its justification for the emergency actions, arguing that the system is “stressed.” The order noted that with “continued delays and unpredictable staffing shortages, which are driving fatigue, risk is further increasing, and the FAA is concerned with the system’s ability to maintain the current volume of operations.”

Operational Restrictions and Requirements. FAA’s emergency order applies to each Part 121 and commuter or scheduled Part 135 air carrier operating at any of the 40 “high impact airports” listed in an appendix to the order. Each carrier must comply with the following requirements:

Phased-In Reduction Schedule: Carriers must reduce their total daily scheduled domestic operations between 6 a.m. and 10 p.m. local time at each airport according to the following schedule: (1) by 4 percent by 6 a.m. EST on November 7; (2) by 6 percent by 6 a.m. EST on November 11; (3) by 8 percent by 6 a.m. EST on November 13; and (4) by 10 percent by 6 a.m. EST on November 14.

Calculation of Reductions: Carriers must reduce their operational activity at the 40 airports using the total number of currently scheduled operations as a baseline. Reductions in operations must be calculated by marketing code, not operating certificate. However, the reductions for any single operating certificate “may not exceed 15 percent to prevent disproportionate reductions on regional routes.” It is important to note that the order does not require carriers to reduce international flights.

FAA Authority to Review Carrier Reductions: Carriers must notify and submit their list of reduced operations to FAA. While FAA will not approve the list, the agency “reserves the authority to reject or direct modifications to such lists to prevent unacceptable disproportionate impacts to flight availability including regional routes and Essential Air Service and to ensure even distribution of reductions throughout the day at each airport.”

Cooperation Among Carriers on Reductions: FAA directed carriers to ensure they are cooperating with one another to “achieve ratable and evenly distributed reductions throughout the day that do not have disproportionate impacts on communities or specific hours of the day.” The agency indicated that it would direct cancellations on a prescriptive basis if the carriers fail to achieve this goal. FAA also noted that the Department of Justice will not pursue an antitrust enforcement action against carrier actions taken to comply with the order.

Termination of ATC Services: FAA indicated that if an FAA-owned and operated air traffic control (ATC) facility does not have adequate staffing levels, ATC may elect not to provide any of the following: Radar Traffic Information Service; radar assistance to visual flight rule (VFR) aircraft; VFR traffic pattern operations; practice approaches to VFR aircraft; flight checks services to restore inoperable equipment and approaches; ATC services to parachute operations; or ATC services to certain special or unusual operations.

Applicability of Consumer Protection Requirements: The Department of Transportation is planning to issue a separate order to address consumer protection related issues. However, FAA’s press release indicates that carriers will be required to issue full refunds for passengers.

List of 40 Affected Airports. In the order released this evening, FAA included a list of the following 40 “high impact” airports where the operational restrictions apply (which is the same list we reported earlier today):

Anchorage International (ANC)
Baltimore/Washington International (BWI)
Boston Logan International (BOS)
Charlotte Douglas International (CLT)
Chicago Midway (MDW)
Chicago O`Hare International (ORD)
Cincinnati/Northern Kentucky International (CVG)
Dallas Love Field (DAL)
Dallas/Fort Worth International (DFW)
Denver International (DEN)
Detroit Metropolitan Wayne County (DTW)
Fort Lauderdale/Hollywood International (FLL)
George Bush Houston Intercontinental (IAH)
Harry Reid International (LAS)
Hartsfield-Jackson Atlanta International (ATL)
Honolulu International (HNL)
Indianapolis International (IND)
Los Angeles International (LAX)
Louisville International (SDF)
Memphis International (MEM)
Miami International (MIA)
Minneapolis/St. Paul International (MSP)
New York John F. Kennedy International (JFK)
New York LaGuardia (LGA)
Newark Liberty International (EWR)
Oakland International (OAK)
Ontario International (ONT)
Orlando International (MCO)
Philadelphia International (PHL)
Phoenix Sky Harbor International (PHX)
Portland International (PDX)
Ronald Reagan Washington National (DCA)
Salt Lake City International (SLC)
San Diego International (SAN)
San Francisco International (SFO)
Seattle/Tacoma International (SEA)
Tampa International (TPA)
Teterboro (TEB)
Washington Dulles International (IAD)
William P. Hobby Airport (HOU)