Ross Aimer, the aviation consultant who assessed the Miami crash cockpit voice recorder as the worst crew performance he had seen in 60 years of aviation, also asked a specific structural question: ‘Why is it that a major company, a very rich company like Amazon Prime, is contracting its flying to several of what I would call fly-by-night operations like 21 Air?’

WHAT FLY-BY-NIGHT MEANS IN AVIATION  

The term ‘fly-by-night’ in aviation refers to smaller cargo carriers that:

▸  Operate with minimal staff and lean management structures that reduce oversight capacity

▸  Face financial pressure that can create incentives to reduce maintenance costs and safety investments

▸  Have less institutional capacity to create and maintain robust safety cultures compared to major carriers

▸  May have limited ability to resist operational pressure from contract clients (like Amazon) to maintain schedules even when safety concerns arise

AMAZON’S RESPONSE  

Amazon vigorously disputed characterizations of 21 Air’s safety culture as inadequate. Amazon’s position: the company operates a rigorous safety oversight program for its contracted carriers. The specific accountability question: whether Amazon’s oversight program caught or responded to the safety concerns Karl Seuring raised in 2022 before being fired.

THE STRUCTURAL QUESTION  

The structural accountability question that Aimer’s question raises: Amazon is one of the world’s largest companies by market capitalization. It operates a massive air cargo network that ships millions of packages daily. It has chosen to operate that network through contracts with smaller carriers rather than by operating its own airline. The specific choice produces: reduced capital requirements (Amazon does not bear the cost of owning and maintaining aircraft); flexibility (Amazon can add or remove carriers from its network); and reduced direct regulatory exposure (the carrier, not Amazon, holds the FAA operating certificate).

Whether that structural choice also reduces Amazon’s incentive to invest in the safety culture of its contracted carriers is the specific question the Miami crash investigation will address.

Why does a company with Amazon’s resources contract its flying to operations an expert calls fly-by-night? The structural answer is: it reduces costs, increases flexibility, and limits direct regulatory exposure. Whether it also limits the safety culture of the carriers doing the flying is what five dead workers have made into a federal investigation.

WHAT HAPPENS NEXT  

▸  NTSB investigation — whether Amazon’s contracting practices are specifically examined

▸  FAA review — whether Amazon’s safety oversight program for contracted carriers faces regulatory scrutiny

▸  21 Air — whether the carrier faces additional FAA enforcement action

CONFIDENCE: HIGH

Ross Aimer: fly-by-night Amazon Prime Air 21 Air question; Amazon disputed characterizations; former employees’ safety concerns from NPR confirmed reporting.

SOURCES

▸  NPR — Amazon 21 Air fly-by-night cargo contracting safety September 13, 2026