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Legal Opinions and Interpretations

The Office of the General Counsel interprets the statutes that the agency administers and the regulations that it promulgates.  A portion of these interpretations are provided below.  

Deputy General Counsel Letter re: Passenger Facility Charge Refunds3/30/2010
Assistant General Counsel Letter re: Whether Maryland Gross Receipts Tax Violates the Anti-Head Tax Act 1/29/2010
Assistant General Counse Letter re: Whether U.S. to Seoul to Saipan Consitutes Cabotage8/31/2009
General Counsel Opinion re: Preemption of Texas Law Affecting Air Ambulances11/3/2008
General Counsel Letter to Repesentative Kanjorski re: Nanticoke City Redevelopment5/27/2008
Hawaii Certificate of Need Program Requirements for Air Ambulance Operators4/23/2007
General Counsel Letter re: Whether a Los Angeles Contracting Ordinance is Compatible with DOT's "Full and Open Competition" Acquisition Requirements6/25/2004
General Counsel Letter re: Whether a 2001 Appropriations Restriction Mandates Advance Notice of Furnishing a Presidential Appointee's Office9/6/2002
Operation of Air Ambulance Service as a Direct Air Carrier or Indirect Air Carrier2/4/2002
General Counsel Letter re: Whether 49 U.S.C. 41720 Extends Beyond Domestic Carriers to Foreign Air Carriers12/28/1998
Use of International Air Service Route RIghts as Collateral for Long-Term Financing3/20/1992
Secretary's Conditional Finding That Hawaii Handling of Off-AIrport Duty-Free Revenes Complies with Section 511(g) of AIP Act4/11/1991
Possible Security Interest Created in International Air Service Route Rights9/18/1990
Secretary's Letter Advising Hawaii That Its Diversion of Off-Airport Duty-Free Revenues Violates Federal Grant Obligations Under Section 511(a)(12) of the AIP Act6/19/1989
Preemption of State Smoking Requirements on Air Carriers Operating in the State1/20/1988
General Counsel Letter to United AIrlines Stating That a Codeshare with a Foreign Air Carrier is a Wet Lease Requiring a Statement of Authorization12/18/1987
Views on Whether a City Subsidy of One Carrier but not Others Violates Federal Law11/16/1987
Preemption of State Entry Requirements on Indirect Air Carriers Operating in the State8/8/1986
Preemption of State Regulation of Emergency Air Ambulances Operating in the State6/16/1986
Applicability of Section 1113 of the FAA Act of 1958 to Local Taxation of Air Taxi Service12/18/1985
Civil Aeronautics Board General Counsel Opinion re: Whether CP Air Truck-Air Cargo Shipment to Honolulu via Vancouver (BC) Constitutes Cabotage2/7/1983
Civil Aeronautics Board General Counsel Opinion re: AVIANCA "Transhipment" of Cargo at Miami (to or from NYC) Between Valid Foreign Flights Constitutes Cabotage12/7/1982
Civil Aeronautics Board General Counsel Opinion re: Whether Japan Air Lines Requires Additional Authority to Conduct Certain Operations9/16/1960
Civil Aeronautics Board Opinion of Certain "Rights and Responsibilities" Related to Co-Terminal Points12/16/1949






Updated: Thursday, November 13, 2014