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ASC Monthly Update

##Date##                                                                                                Volume 5 Issue 10


NATA Airline Services Council 

NATA formed the Airline Services Council (NATA ASC) to further the interests of companies that provide services to scheduled air carriers as their primary business. The primary goal of the NATA ASC is to provide a voice within the public policy arena, especially in terms of issues that impact their viability and profitability..



Upcoming Events

2010 FBO Leadership Conference - San Antonio, TX - 01/25/2010

FBO Success Seminar -Las Vegas, NV - 03/15/2010

Environmental Compliance Seminar -Las Vegas, NV - 03/15/2010

Line Service Supervisor Training -Las Vegas, NV - 03/15/2010

NATA Safety 1st Trainer -Las Vegas, NV - 03/15/2010

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Topics in this Volume:
Ø TSA Releases Interim Final Rule On Air Cargo Screening; Member Input Needed! 
Ø NATA Releases Results Of Survey On FAA Inconsistencies
Ø Security Directive Action Call – Contact Your Member Of Congress To Co-Sponsor H.R. 3678 Today!
Ø FAA Draft Guidance On Through-The-Fence Operations
Ø EPA Proposes Regulating Greenhouse Gas Emission From Large Sources
Ø Members Encouraged To Take Part In Action Call Opposing Foreign Repair Station Provision
Ø DHS Funding For Fiscal Year 2010 Approved
Ø NATA Releases Legislative Report On Draft Global Warming Legislation
Ø Prepare Your Team For A Winning Season
Ø Stay In Touch With NATA’s Social Media Sources
Ø Can Other Members Find Your Company’s Information?
Ø Useful References For NATA ASC Member Companies
Ø 2009 NATA Airline Services Council Brochure Now Available!
Ø New NATA ASC Logo Available For Member Use
Ø Download NATA’s New Fact Book Today!



TSA, Airport Industry Officials Address NATA ASC During Fall 2009 Meeting
The NATA Airline Services Council (NATA ASC) met earlier this week for its quarterly business meeting. The meeting included presentations from a number of high-level Transportation Security Administration (TSA) and industry participants on issues including cargo and airport security, commercial airport and airline industry perspectives, planning for 2010, tax and health care updates and presentations by vendors from the ground support equipment community.

Minutes from this meeting will be available on the NATA ASC web page next week.

As a result of the meeting, the NATA ASC now has a dedicated Web site for all of its issue white papers available for member review. Members may view this page by clicking here.

NATA ASC members not in attendance may also view the PowerPoint presentation provided by the TSA on the Certified Cargo Screening Program. That presentation may be viewed by clicking here.

For more information about this meeting, please contact Eric Byer.

TSA Releases Interim Final Rule On Air Cargo Screening; Member Input Needed!
On September 16, the Transportation Security Administration (TSA) released an Interim Final Rule (IFR) titled “Air Cargo Screening” to meet the requirements of section 1602 of the Implementing the Recommendations of the 9/11 Commission Act of 2007. The act requires that by February 3, 2009, at least 50% of cargo carried on commercial passenger aircraft must be screened and by August 3, 2010, 100% of cargo carried on commercial passenger aircraft must be screened.

The TSA has determined that the affected air carriers do not have the facilities to be able to meet these requirements without inflicting significant delays and backlogs of unscreened cargo. Therefore, this IFR creates the Certified Cargo Screening Program (CCSP) to allow firms, such as shippers, manufacturers, warehousing entities, distributors, third-party logistics companies, and Indirect Air Carriers (IACs), to become Certified Cargo Screening Facilities (CCSF).

Once certified, the CCSF must—

  • Implement the certified cargo screening standard security program that the TSA develops and any amendments to it;
  • Appoint security coordinators at the corporate and facility levels and alternates to be available 24 hours per day, 7 days per week;
  • Ensure that the following individuals successfully undergo a TSA-conducted security threat assessment:
    • Each employee and authorized representative who screens cargo or has unescorted access to screened cargo, and
    • each security coordinator and alternate, senior manager of the facility, and other individual who implements the cargo screening program;
  • Adhere to strict physical and access control measures for the storage, handling, and screening of cargo;
  • Screen cargo using TSA-approved methods;
  • Implement chain of custody requirements, including the use of tamper evident technology, which must begin when the cargo is screened and remain intact until the cargo is tendered to the aircraft operator for transport on a passenger aircraft; and
  • Apply for recertification, including a new examination by a TSA-approved validator, every 36 months.

NATA staff have evaluated this IFR and produced a comprehensive white paper for members to review by clicking here. This IFR becomes effective on November 16, 2009, and is also open for public comment until November 16, 2009. NATA ASC members are strongly encourage to review this IFR and submit comments to Eric Byer on the NATA staff no later than the close of business on Friday, November 6.

NATA Releases Results Of Survey On FAA Inconsistencies
A survey conducted by the NATA to gather data on the significance and predominance of inconsistent FAA regulatory interpretations has yielded troubling, yet expected, results. 

"This survey clearly demonstrates the high, unnecessary costs, delays and obstacles aviation businesses suffer due to the FAA's inconsistent interpretation of the federal aviation regulations," said NATA President James K. Coyne. "The FAA absolutely must find a way to provide consistent regulatory guidance and interpretation."

The Government Accountability Office (GAO) has been commissioned by Congress to conduct a study on how inconsistent regulatory interpretations are costing the FAA and the aviation industry millions of dollars in resources and raising serious concerns about unified safety standards.

NATA conducted its survey in response to numerous members' reports of having experienced varying interpretations of federal aviation regulations (FARs) by the agency's Regional, Aircraft Certification (ACOs) and Flight Standards District Offices (FSDOs) and to be able to provide specific information to the GAO as it conducts its study.

According to survey respondents, many affected companies continue to be challenged by regulatory interpretations that vary from one inspector within one FSDO or ACO, to another. These varying interpretations of how to achieve or demonstrate compliance with the FARs are estimated by the respondents to cost general aviation businesses hundreds of millions of dollars annually when previously approved actions are subjected to "re-interpretation." The results of the survey showed:

•87% of respondents stated that their businesses have experienced problems due to inconsistent or incorrect interpretations by local FAA inspectors.
•57% believe that an inconsistent or incorrect local FAA position had safety consequences for their business. Members rated the safety significance as very serious (17%); serious (40%); somewhat serious (35%); and not too serious (8%).
•85% stated they have experienced delays in FAA response that have interrupted their ability to do business.
•75% believe that the delay or denial for a new safety program was related to an incorrect or inconsistent interpretation. In resolving discrepancies, 23% said it took up to 90 days; 20% said up to 120 days; 19% said more than 121 days; and 36% said their issue still is unresolved. 

"Inconsistent compliance interpretations of the FARs are not only costly for the industry, they also demonstrate a shortcoming in the FAA's ability to coordinate its workforce and ensure that the decision-making abilities vested in inspectors are respected across all divisions of the agency," said Coyne.

A compilation of the survey results is available by clicking here.

Security Directive Action Call – Contact Your Member Of Congress To Co-Sponsor H.R. 3678 Today!
Representatives John Mica (R-FL), Thomas Petri (R-WI), Vernon Ehlers (R-MI), Sam Graves (R-MO) and Allen Boyd (D-FL) introduced legislation, H.R. 3678, to modify the authority of the Transportation Security Administration (TSA) assistant secretary to issue regulations and security directives using emergency procedures.

H.R. 3678 was introduced in response to Security Directive (SD) 1542-04-08G (SD-8G) issued last year that required pilots based at airports serving commercial air carriers to get a badge in order to have unescorted access to the airport. While SD-8G has been troublesome for many airports throughout the country, one of the major concerns was the use of an SD to promulgate regulations where no imminent threat existed. 

To view NATA’s Legislative Report on H.R. 3678, please click here.
NATA is pleased that this legislation was introduced as a stand-alone piece of legislation. It’s imperative that additional Members of Congress co-sign the legislation for the bill to move forward. Please write to your Member of Congress today and urge their support on this important legislation.
To view NATA’s Action Call, please click here.

To view a copy of the legislation, please click here.

Please contact Kristen Moore, for more information.

FAA Draft Guidance On Through-The-Fence Operations
NATA staff are currently reviewing an FAA draft Compliance Guidance Letter to Airport Compliance Office staff, Regional and Airports District Managers and Compliance Specialists that addresses through-the-fence (TTF) operations at federally obligated airports. In the letter, the FAA stated, “As a general principle, FAA does not support agreements that grant (through-the-fence) access.”  The draft letter divides possible TTF operations into three categories and addresses each individually.
  • Non-Residential Compatible TTF Access – This type of access would include activities for which space requirements surpass the airport’s ability to offer an on-airport site or the need would absorb so much airport property that it would limit future development for aeronautical activities. The FAA does not encourage this type of access, but a properly structured agreement may be acceptable
  • FBO or other Aeronautical Service Providers TTF Access – The FAA does not support this type of agreement.
  • Residential TTF Access“There are no acceptable forms of residential TTF agreements.”

The draft guidance letter also strongly encourages airport sponsors to submit any TTF agreement to their Airports District or Regional Office prior to approval to ensure compliance with federal grant assurances. The draft includes a list of TTF access agreements the FAA will not approve and general procedures for establishing TTF access. Upon completion of its review, NATA will submit comments to the FAA on the contents of the letter.

EPA Proposes Regulating Greenhouse Gas Emission From Large Sources
Earlier this month, the U.S. Environmental Protection Agency (EPA) released a notice of proposed rulemaking (NPRM) that would require large emitters of greenhouse gasses (GHGs) to obtain permits and employ the best available technology to reduce emissions. These proposed rules would come into effect when entities such as power plants, factories and oil refineries are built or when existing facilities are substantially modified. The rules would only apply to facilities emitting more than 25,000 tons of GHGs annually. While the provisions would not affect aircraft operators, FBOs or airports, aviation fuel producers could face substantially increased cost when building new production facilities or upgrading current facilities.

The full text of the NPRM is available from the EPA Web site.

Members Encouraged To Take Part In Action Call Opposing Foreign Repair Station Provision
NATA and the Aircraft Electronics Association (AEA) are seeking member participation in contacting Members of Congress in opposition to the foreign repair station provisions in both the U.S. House of Representatives and U.S. Senate versions of FAA Reauthorization legislation.

Conference negotiations between the House and the Senate on H.R. 915/S.1451, the Federal Aviation Administration Reauthorization Act of 2009 are likely before the end of the year. Each bill contains a provision requiring additional FAA oversight of foreign repair stations. H.R. 915, which passed the House on May 21, 2009, includes a provision requiring the FAA to certify that all Part 145 certificated foreign repair stations are inspected at least twice a year and requires those organizations to introduce mandatory drug and alcohol testing if they maintain aircraft operated by U.S. airlines. S. 1451, which has not yet been voted on in the Senate, contains similar language regarding repair station inspections but makes an exception if "a bilateral aviation safety agreement is in place that allows for comparable inspection by local authorities."  

The proposed regulation would eliminate a reciprocal audit provision of the U.S.-European Community Bilateral Aviation Safety Agreement, or “BASA,” and would unnecessarily raise costs for EU-based repair stations. The potential job loss to U.S. repair stations is high if the companies holding a U.S.-based European Aviation Safety Agency (EASA) Part 145 repair station certificate lose the reciprocal audit capabilities between the FAA and EASA.

Contact your Members of Congress by visiting NATA’s Legislative Action Center. NATA’s Legislative Action Center provides association members with a quick and easy way to email letters directly to Members of Congress in their state. 

Click here to view a form letter that may be used to contact Members of Congress or their staff.

DHS Funding For Fiscal Year 2010 Approved
Congress recently approved a final $42.8 billion fiscal year (FY) 2010 Homeland Security spending bill that provides funding for aviation security programs under the jurisdiction of the Transportation Security Administration.

To view NATA’s comprehensive legislative report on the FY 2010 Homeland Security spending bill, please click here.

NATA Releases Legislative Report On Draft Global Warming Legislation
On September 30, Senator John Kerry (D-MA), Chairman of the U.S. Senate Committee on Foreign Affairs, and Senator Barbara Boxer (D-CA), chairwoman of the Senate Committee on Environment, released a draft version of legislation designed to curb the effects of climate change by capping greenhouse gas (GHG) emissions nationwide. The draft legislation is similar to the American Clean Energy and Security Act of 2009 (ACESA), passed by the U.S. House of Representatives in June. Much like the ACESA, this draft would create a “cap and trade” program that would institute a cap on GHG emissions and require emitters to purchase or trade emission credits.

NATA staff have reviewed the draft legislation and prepared a legislative report that is available to members for download here.

Prepare Your Team For A Winning Season
NATA’s 2010 Spring Training Week
We are pleased to host our second annual Spring Training Week in conjunction with the Aviation Industry Expo on March 15-17, 2010, in Las Vegas. NATA’s Spring Training consists of several major league seminars designed to answer questions about the business climate, advance the skills of FBO owners, general managers, line service specialists and supervisors, and enhance the success of their operation in any economic environment.

The 2010 Line Up:

  • FBO Success Seminar
  • NATA Safety 1st Trainer Seminar (Train the Trainer)
  • Environmental Compliance Seminar
  • Line Service Supervisor Training Seminar (LSST)

For more information and to register for the seminars, please go to,, or search for National Air Transportation Association on Facebook.

Stay In Touch With NATA’s Social Media Sources
As the voice of business aviation, NATA is committed to keeping our members armed with the most current information on issues that affect their businesses. We have joined many other industry professionals in providing this information in the quickest way possible – through social media. NATA is making use of our Twitter and Facebook accounts to provide you with up-to-the-minute safety, regulatory and legislative resources. Stay informed on recent developments and NATA’s latest actions to help ensure a secure future.

If you haven’t already, we encourage you to follow NATAaero on Twitter and become a fan of the National Air Transportation Association on Facebook for an immediate pulse on association news and events, and access to special offers and resources as well as information about product and service launches, member news and other news of interest.

Reaching out to our members in a new way - James K. Coyne and Eric R. Byer are now hosting blogs. Coyne's monthly blog, NATA President's Capitol View, provides commentary on the current state and future prospects for the aviation business industry. View the inaugural post, "Can't We All Just Get Along?," regarding the USA Today article attacking general aviation and the fundamental change of strategy on the part of the airlines that this article represents. Byer's weekly Inside Washington View blog explores the latest aviation business developments in Washington and provides guidance to help navigate the rocky political landscape. The first post, "Light At The End Of The Tarmac?," tackles the brutal effect the economy has had on our members, but offers a ray of hope for the future...maybe nearer than we dared hope.

For more information on NATA’s Social Media Sources, please click here or contact NATA at (703) 845-9000.

Can Other Members Find Your Company’s Information?
One of the services that NATA offers to members is the Aviation Resource Book And Membership Directory that is published annually. The directory lists members alphabetically, geographically, and by the products and services provided. Unfortunately, information changes frequently make the printed directory inaccurate.

That makes the online member directory on the Web site a very valuable tool. The directory is searchable by company name, contact name, location or products. The directory can be accessed on the Web site under the NATA tab, by clicking membership and then member directory or by clicking here.

Need to change your email address or phone number? Need to add or remove employees from your company contact list or update your company profile information for the business directory? Company primary contacts can view and change all information for the company, including updating address and demographic information, adding and removing employees, and checking the products and services listings for your company that will be included in the directory. All members can view and change their individual information.

NATA encourages you to ensure that all key personnel are listed as member contacts so you can get the most out of your NATA membership.

To learn more, visit, login and click on Update Your Profile or contact Linda Pylant for additional information.

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Useful References For NATA ASC Member Companies
The association has compiled a list of useful Web sites that NATA ASC member companies are encouraged to access for the latest information affecting the airline services industry. These references are frequently updated and provide valuable information on a wide array of topics and issues confronting NATA ASC member companies.

Bureau of Transportation Statistics Airline Data:

DOT’s Small Community Air Service Development Program:

EPA’s Transportation Sector Web Page:

OSHA’s Compliance Assistance Web Page:

TSA’s Air Cargo Web Page:

TSA’s Commercial Airlines Web Page:

TSA’s Commercial Airports Web Page:

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2009 NATA Airline Services Council Brochure Now Available!
The 2009 NATA Airline Services Council marketing brochure is available for members to download.

Click here to download the brochure today!

If you have questions about the brochure, please contact Eric Byer.

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New NATA ASC Logo Available For Member Use
NATA has created a new NATA ASC logo that members can use on company stationery, publications and their Web site. The association recently provided members with two types of logos that members can utilize as appropriate. Members wishing to secure the new logo may do so by contacting Eric Byer.

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Download NATA’s New Fact Book Today!
NATA has updated its popular fact book titled General Aviation in the United States. This publication was produced by the association for its members, including airline services companies, as a tool to help illustrate the importance of aviation businesses to the U.S. transportation system and economy.

General Aviation in the United States provides an in-depth review of the NATA membership segments as well as other important components of the general aviation and airline services industry. This handy reference also contains information on a number of U.S. government agencies that affect the day-to-day operation of aviation businesses, and features several charts containing vital general aviation and business aviation statistics on fuel consumption, fractional ownership companies, active pilots, airports, and much more.

"NATA's fact book is one of the many helpful resources available to aid our members in educating community and government leaders about the value of our industry as a critical component to the American economy," NATA President James K. Coyne stated.

Click here to download your free copy of General Aviation in the United States now!

Members who have questions regarding this publication may contact Linda Pylant or Shannon Chambers.

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Phone: (800)808-6282
Fax: (703)845-0396