Jennifer M Nowak is an Associate in our
Washington DC office.
On Sept. 17, 2018, the U.S. Department of Transportation (DOT)
completed its rulemaking on air charter brokers, after it had been
pending for five years. The Final Rule, which becomes effective on Feb.
14, 2019, creates a new class of indirect air carrier able to hold
out and contract for planeload single-entity charters as a
principal. Thus, entities wishing to arrange for such
transportation have the ability to do so without worrying about
crossing the line into offering unauthorized air transportation.
This boundary had proved fraught for many carriers and resulted in
numerous civil penalties and consent orders.
Background
