Draw every disability complaint out of the channel it arrived on, read each into the category 14 CFR 382.157 requires, and hold the annual report for the officer who certifies it.
A complaint arrives, and 14 CFR 382.157 reads it by disability type and by nature of complaint.
02
A complaint reaches three channels, and the annual report has to count it once, not once each.
Reason
03
A calendar year closes, and 14 CFR 382.157 falls due on the last Monday in January.
04
A tarmac event closes, and 14 CFR 259.4(g)(1) allows thirty days to describe it to the DOT.
05
A cause is written, and 14 CFR 259.4(g)(2) wants the precise cause of that delay.
Decide
06
A monthly file goes to BTS under 14 CFR 234.6, and Part 234 asks nobody to certify it.
07
A wheelchair is mishandled, and one event feeds the BTS count and the annual report.
Out
08
A record of action is created, and 14 CFR 382.157 keeps it for three years afterwards.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent normalises complaints and tracks both clocks. A named officer certifies the annual report; a named person signs each tarmac report under 14 CFR 259.4(g)(3).
Example workflow
One complaint, intake to certification
AgentHuman
1Complaint evidence receivedResolution official logs, written complaints, forwarded cases or ramp damage reports
2Complaint context assembledThe complaint, the channel it arrived on, the category it reads into and the year it falls in
3Report evidence draftedThe complaints categorised, the rationale on each borderline call, the gaps and completeness
4Controls appliedCategory checks, deduplication checks, deadline checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is assembling, and the compliance lane opens at the completeness gate.
5DecisionSplits at the completeness gate
Evidence sufficient
Goes to the certifying officer to sign.
Anything thin
Adds a compliance read first.
Compliance review
The report is held with its complaints, its categories and the rationale behind each one.
Certify · Append evidence · Send to compliance
Certified — by a named officer▼
6Complaint and case records updatedOnly where write access and records policy allow it
7Outcome evaluatedCategory accuracy, channel coverage, reviewer corrections and what the read found
Corrections
Each compliance correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying the annual report under 14 CFR 382.157.
Signing a tarmac report under 14 CFR 259.4(g)(3).
Deciding a contact was an enquiry, not a complaint.
Writing the precise cause of a tarmac delay.
Automation boundaryAgent acts unaided
✓Normalise each complaint out of whichever channel first received it.
✓Read each complaint into one type and one nature of it.
✓Reconcile the disability totals against the counts.
✓Track the January deadline and the thirty-day tarmac clock together.
Nothing is certified or filed except by a named person, inside the agreed boundaries.
Judging that a report is true, correct and complete.
Telling the DOT that a filing is in order.
Setting the category a complaint is counted under.
Changes to complaints, categories or report records.
Example output
One complaint, annotated
The officer affirms a report "prepared under my direction … true, correct, and complete"; this record is what one complaint carried into it.
Report evidence · single complaintIllustrative example
Complaint
Recorded as
Disability type
Evidence of record
Confidence
Held for
Mishandled device, Part 382
Categorised as a mishandled device, rationale recorded
Mobility disability
Resolution official log, 3 August 2026
Held uncertified
The officer who certifies the report
As receivedTaken from the resolution official log and the ramp damage report — it reaches as far as those sources do.
What the record holdsIntake log entryRamp damage reportWritten response
Why no certification hereWhether the report is true and complete is an act reserved to the officer.
ActionCertifyAppend evidenceSend to compliance
What the score decidesBelow the configured threshold the report picks up a compliance read before the officer.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every complaintFrom the channel that took it
03Evidence
Where the evidence is used
Our disruption and baggage agents answer what this passenger is owed; this page answers what the carrier must certify to the regulator about all of them, once a year.
01Approved path
Two reports, two clocks
14 CFR 382.157 falls due on the last Monday in January and is certified "true, correct, and complete"; 14 CFR 259.4(g)(1) runs thirty days per event and is signed "I, (Name) and (Title), of (Carrier Name)."
02Human review
What was checked, and not found
The 28 October 2024 compliance date was not confirmed verbatim; 14 CFR 382.151 and 382.155 returned server errors twice and were not read; the scope of RIN 2105-AF36 is unpublished; and the family seating proposal was found dormant.
04Build an evidence trail
The complaint, the category it was read into and the officer who certified stay on the report.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Complaint intakeAirport logs · web forms Email, phone and letters
Contact centreCRM · case management Forwarded consumer cases
Ground and rampDamage and handling reports Gate and station logs
Agent
Carrier reporting and certification
Reads the complaints Assembles both reports Holds for the officer
Operations and filingsACARS and gate times BTS monthly submissions
Integration availability depends on the client's existing systems and API access.
Agent controls
Six sweeps between the model and the officer
Six sweeps across one period, and none of them alike. What both reports keep is drawn in the map below.
L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeNarrow the agent to evidence assembly when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and category rules; §§ 382.125(e), 382.130(a), 382.132 and 382.141(a)(6) sit under enforcement delay to 31 December 2026 (90 FR 46751).Track
L4TraceabilityRecord each complaint, the channel it arrived on, the category it fed and every read of the report.Record
L3Officer releaseHold the report for the certifying officer; delay-compensation rulemaking was withdrawn on 17 November 2025, so nothing of that kind enters it.Gate
L2Scope guardrailsTest the evidence against 14 CFR 382.157 and 14 CFR 259.4(g) as configured; the wheelchair rule at 89 FR 102398 is under Fifth Circuit 25-60071, in abeyance since 23 June 2025.Restrict
L1Confidence thresholdsRoute a thin report to a compliance read first; the ancillary fee rule at 89 FR 34620 was vacated on 3 February 2026 and 91 FR 40368 restored the 2011 text.Require review
Model coreEvidence assembled — the complaints, the categories, the rationale and completeness
L1 – L2Test whether a report may stand
L3Puts the certification in a person's hands
L4 – L5Keep the complaint and the category behind it
L6Leaves the report uncertified when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the report evidence that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the report the DOT reads
Depth of coverage ▼
E1Final-output evaluationDid the evidence record what each complaint was actually read into?
E2Step-level evaluationDid the agent read the right channel, the right year and the live complaint record?
E3Tool evaluationDid it read and write the correct complaint and the correct category?
E4Confidence calibrationDo low-confidence reports actually attract more compliance corrections?
E5Slice evaluationHow does performance change across specific complaint categories?
E6Business outcomeHow many reports needed a correction before the officer certified?
Floor — the report the carrier answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each placed at the stage where it starts.
Agent lifecycleDirection of processing →
01 · Retrieval1 mode
JZ-03
Stale complaint read
The case read is not the one now on the file.
Stage gathersThe contacts, the channels, the years and the dates
02 · Reasoning2 modes
JZ-04
Category asserted, not shown
A complaint is placed in a category with no rationale.
JZ-06
Vacated rule read as live
The ancillary fee rule is worked as though it stands.
Stage proposesContacts, their categories and completeness
03 · Tool / write2 modes
JZ-02
Thin report passed forward
A report moves on without the compliance read.
JZ-05
Counted twice across channels
One contact is logged as two separate complaints.
Stage writesOnly where write access and approval policy allow it
04 · Output1 mode
JZ-01
Certified, rationale unrecorded
The report shows a certification but not what supported it.
Stage returnsThe report an officer certifies and the DOT reads
05 · Change / Version1 mode
JZ-07
Silent category regression
A configuration change moves the category, not the report.
Stage tracksModel, prompt, category rules and report fields
Sev-1 · a report certified on no evidenceSev-2 · wrong evidence reaches the reportSev-3 · source fails, report holds uncertified
A category-level classification-agreement figure can read clean while mishandled mobility devices carry most of the rework. Nestack reports the correction rate by category, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Mishandled mobility devices
9.4%
3.6×
Review
Failure to provide assistance
6.7%
2.6×
Review
Seating accommodation
4.2%
1.6×
Watch
Service animal cases
2.5%
1.0×
Normal
Bar: correction-rate lift vs. service-animal baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a missed category costs
The loop shuts when the miscategorised complaint is a regression case. That suite is what the next report closed is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on mishandled mobility devices.
02Diagnose
The complaint that reached three channels and was counted in none of them is read back until one cause remains.
03Improve
Any change goes out numbered, with the complaints that caused it attached.
04Verify
One complaint case still failing is enough to hold the release back.
05Learn
One case joins the suite, one line joins the certification record.
Learn → DetectThe return edge. The next reporting year is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, report assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Complaint-category discovery and boundary work.
02Intake, contact and ramp sources.
03Complaint-to-category and deadline-clock mapping.
04Complaint and channel ingestion.
05Complaint, category and record binding.
06Completeness scoring and review routing.
07Certifying officer signing workflow.
08Contact and case-system integration.
09Categorisation and period cases.
10Guardrails and certification controls.
11Complaint-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne carrier, one yearProductionProduction reporting workflowAdvancedMultiple carriers / entities
Introduced at Pilot
Report assembly to your complaints✓✓✓
Certifying officer release✓✓✓
Complaint-channel baseline✓✓✓
Introduced at Production
Reporting by category—✓✓
Certification workflow in your systems—✓✓
Approved write-back—✓✓
Contact-channel integration—✓✓
Introduced at Advanced
Multi-carrier groups——✓
Cross-year evidence packs——✓
Large complaint registers——✓
Multi-report deadline controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, complaint volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your intake channels and the complaints on each→Channel inventory mapping and evidence captureWeek 1
02Representative complaint, intake and ramp records→Record binding, category logic and the report baselineWeek 2
03Your category rules under 14 CFR 382.157→Complaint mapping, category binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Intake, case and ramp-source assessment, then integration setupWeek 2
05Reports you would not want certified→Category cases and failure-mode testingWeek 4
06What no annual report may settle→Completeness scoring, review routing, guardrails and release controlsWeek 3
07A named officer to certify the report→Certification workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Read every bar as working weeks rather than as drawn space, which is why the fifth of them doubles up.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Reporting workflow discovery, category mapping and the automation boundaryW2Source integration and the complaint-channel baselineW3Report assembly, category logic and release controlsW4Evaluation suite, category cases and failure-mode testingW5Case integration, pilot reports and targeted correctionsW6One reporting year run under the certifying officer, then Agent Care handover
Reading the bandA bar spans only the weeks the work under it is named for, and the fifth doubles because two phases land there.
At the end of W6Once the reporting record validates, Agent Care assumes the agent.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Travel & Hospitality AI agent
Build a reporting agent around the two filings a named officer has to sign.
Show us one complaint and the category it was read into. Which filings here does a person actually sign — only 14 CFR 382.157 once a year and 14 CFR 259.4(g)(3) per event, while Part 234 asks for none. Part 260 refund mechanics sit on the disruption page.
