1. Purpose of This Notice. This notice introduces new reporting
requirements and procedures for suspected illegal charter investigations and
announces revisions to General Aviation (GA) Job Task Analysis (JTA) O1.2.3, Conduct Investigation of Suspected Illegal Charter.
2. Audience. The primary audience for this notice is responsible
Flight Standards offices (including Flight Standards District Offices (FSDO)
and certificate management offices (CMO)), International Field Offices (IFO), principal inspectors (PI), and aviation safety inspectors (ASI).
4. Background. H.R. 302, FAA Reauthorization Act of 2018, Section
540 directs the Office of the Secretary of Transportation (OST) to provide a
report to Congress on illegal charter operations. This includes, among other
obligations, how many illegal charter investigations are conducted. This Act
was subsequently signed into law as Public Law (PL) 115-254. In compliance with
Section 540, the FAA has amended JTA O1.2.3 and developed three activity codes
(1730, 3730, and 5730) in the Safety Assurance System (SAS) to clearly identify
data. Additionally, adding the discriminator “134” in the National Use field will allow efficient and accurate data retrieval.
5. Discussion. JTA O1.2.3 was developed and published in November
2019 to prevent uncertificated entities from providing commercial air transportation
for hire. Since that time, follow-on actions in support of this initiative, and revisions to the JTA, have been made, which include:
• Revision of on-the-job training (OJT) GA JTA O1.2.3 (OP), Conduct
Investigation of Suspected Illegal Charter.
• Replace SAS activity codes with those specifically created to
identify investigations connected to illegal charter.
• Development of FAA Training Course 27100294, Introduction to Illegal
Charter Operations, now available for assignment in the electronic Learning Management System (eLMS) at the discretion of office management.
• Stand up of the Uncertified Air Charter Working Group.
• Stand up of the Charter Safety Initiatives Group OJT Trainer.
Monthly meetings are open to interested General Aviation Safety Assurance (GASA)
office managers and their OJT trainers. Monthly case studies of illegal charter cases drawn from the participating offices.
• Development of a follow-on eLMS course (web-based training (WBT)
course) to support learning in preparation for an instructor-led classroom course
offered at the FAA Academy in Oklahoma City. This course is actively under development, and its projected deployment date is in early 2021.
• Development of a follow-on course for an Instructor-Led Training
(ILT) classroom course offered at the FAA Academy in Oklahoma City. This course
is actively under development, and its projected deployment date is in early 2021.
6. Action. Until further notice, offices initiating investigations
into suspected illegal charter operations must document the investigation using
the appropriate SAS activity code (1730, 3730, or 5730). In the event that the
investigation draws in multiple ASIs of different specialties, there is no need
to open more than one activity. The initiating inspector will enter “134” in
the National Use field of the activity. This action will provide a consistent path of visibility to current and past investigations.
a. When assigning this work in SAS, a manager will:
(1) Access the Office Workload List (OWL) for the office.
(2) Create a new task for assignment.
(a) When creating a new task, use the pull-down menu to select “Investigate Illegal Charter.”
(b) Select one of the SAS activity codes (1730, 3730, or 5730) appropriate to the specialty of the assigned inspector.
b. In the event that an ASI encounters a potential illegal charter
while engaged in routine work or in an ad hoc encounter, they may document that in their associated activity code in SAS.
(1) Record using the SAS activity code (1730, 3730, or 5730).
(2) Place the descriptor/search term “134” in the National Use field of the activity.
Note: A suspected illegal charter investigation will often begin as a result
of a complaint. That complaint should be documented separately from the illegal
charter investigation. If the resolution of the complaint is the initiation
of an illegal charter investigation; then the above procedures will allow the Safety Assurance (SA) office to document that.
7. Disposition. The information contained in this notice will
not be incorporated into Order 8900.1. Direct questions concerning the information in this notice to Greg Maury, Air Transportation Division, at 901‑350‑0596.
ORIGINAL SIGNED by
/s/ Robert C. Carty
Deputy Executive Director, Flight Standards Service
Appendix A. Task O1.2.3 Conduct Investigation of Suspected Illegal Charter
1.2 Enforcement Investigation
Air Transportation Division Job Series:
1825-Aviation Safety Inspector
Rating and Ranking:
SAS activity codes: 1730 3730 5730
SAS Elements: None
Regulatory and/or Statutory Requirement(s):
14 CFR Part
Clause Requirement in Leases and Conditional Sales Contracts
Relevant Guidance and Advisory Material (current editions):
FAA Compliance and Enforcement Program
Order 8900.1 Vol. 3,
Chap. 13, Lease and Interchange Agreements
Vol. 3, Chap. 25, Sec. 5, Safety Assurance System: Part
Locating Systems and Operating Rules
Vol. 6, Chap. 1, Sec. 1, Inspect
an Executive/Corporate Operator
Vol. 6, Chap. 1, Sec. 4, Conduct a Part
91 Ramp Inspection
Vol. 7, Chap. 5, Sec. 1, Background and Procedure
Vol. 14, Chap. 2, Sec. 2, Preparation
of Federal Aviation Administration Form 2150-5, Enforcement Investigative Report
Order 8900.1 Vol. 16, Unmanned Aircraft Systems
91-37B Truth in Leasing
Small Unmanned Aircraft Systems (sUAS)
Private Carriage Versus Common Carriage of Persons or Property
FAA Form 2150-5, Enforcement Investigative Report
Prerequisite Specialized Training:
Note: Ensure you have the most current information. Use the Flight Standards Information Management System (FSIMS) to obtain current guidance.
Job Task Performance Steps and Knowledge:
1 Receive notification of a possible violation or complaint.
2 Open the SAS activity code.
4 Determine if there is a basis for a violation.
2150.3, Chap. 4
5 Close the SAS activity code.
6 Prepare the office file.
Individual Office SOP/LTI