Attached files
Exhibit
18.1
April 23,
2010
Ms. Laura
Wright
Senior
Vice President Finance & Chief Financial Officer
Southwest
Airlines Co.
P.O. Box
36611
Dallas,
TX 75235-1611
Dear
Ms. Wright:
Note 2 of
the Notes to the Condensed Consolidated Financial Statements of Southwest
Airlines Co. (the Company) included in its Form 10-Q for the three months ended
March 31, 2010 describes a change in the method of accounting for partially
earned awards under the Company’s frequent flyer program from a method of only
accruing the incremental cost for fully earned awards to a method of also
accruing the incremental cost of partially earned awards. There are
no authoritative criteria for determining a ‘preferable’ method for accounting
for partially earned awards under frequent flyer programs based on the
particular circumstances; however, we conclude that such change in the method of
accounting is to an acceptable alternative method which, based on your business
judgment to make this change and for the stated reasons, is preferable in your
circumstances. We have not conducted an audit in accordance with the standards
of the Public Company Accounting Oversight Board (United States) of any
financial statements of the Company as of any date or for any period subsequent
to December 31, 2009, and therefore we do not express any opinion on any
financial statements of Southwest Airlines Co. subsequent to that
date.
/s/Ernst
& Young LLP