Everything you say makes sense but I still don't believe operational stats coorelate well to FAA complaints. I don't think that is what causes people to compla8n to the FAA. However the FAA does not break down the nature of the complaints enough to even see what the complaints are really about.

Frontier has experianced a spike in complaints, however as far as I can tell their operational stats have hardly moved. In fact contrary to popular reports their on time performance has actully improved slightly. What has changed is their business model, their website, their staff in Denver and their customer service. This has affected the expectations of old customers who don't like the changes and new customers who don't understand them.

Southwest likely keeps complaints down by effectively dealing customer concerns, shortstoping complaints to DoT. Frontier does not appear to deal with those issues as effectively.