Law Offices

ROLLER &BAUER, PLLC

Moffett B. Roller
Lee A. Bauer
Washington Dulles International Airport
45005 Aviation Drive; Suite 200
Dulles, VA 20166
Phone: 202-331-3300
Fax: 202-331-3322
airlaw@rollerbauer.com
May 2009
MEMORANDUM - eAPIS Requirements for Private Aircraft
Basic Information;
Effective May 18, 2009, U.S. Customs and Border Protection (CBP) is requiring eAPIS
reports for all private, i.e., non-commercial, flights to and from the United States.
Commercial flights are already required to file eAPIS reports, and there is no change to
that requirement. In this Memorandum we discuss how the new rule affects private
flights to and from Mexico, including how this requirement is similar to -- and different
from -- the existing requirement for commercial flights.
Mexican air taxis should enroll to make private eAPIS reports.
One result of the new rule is that eAPIS reports will be required for all flights both
commercial and private between Mexico and the United States. Because an air taxi
that normally operates commercial flights may also operate private flights occasionally,
air taxis should also enroll to make eAPIS reports for private flights. If you are uncertain
whether a particular flight is commercial or private for purposes of submitting the
correct eAPIS report, please contact us at 202-331-3300.
We recommend that you use this Memorandum as a guide as you go through the
steps (described below) to enroll, to enter crew information, and to prepare and
submit a private flight manifest on the CBP eAPIS website: http://eapis.cdp.dhs.gov
PART I -- ENROLLMENT & VALIDATION -- EAPIS REPORTS FOR PRIVATE FLIGHTS
Step 1 - Enrolling to create a private aviation account
A Mexican air taxi cannot use the Sender ID and password that it uses for
commercial eAPIS information to make private eAPIS reports. The air taxi must enroll
separately to make private eAPIS reports.
1. Go to the eAPIS web site: https://eapis.cbp.dhs.gov
2. Click on Enroll under (even though the air taxi is already O> New eAPIS Users
enrolled to make commercial eAPIS reports).
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Terms and Conditions
3. Read the End User Terms and Conditions on the next screen. To accept these
Terms and Conditions, click I agree and then click . NEXT
Enroll - Select Account Type
4. On the next screen, entitled Enroll Select Account Type, click Private Aviation
to indicate that the new account will be used for private aviation transactions and then
click . NEXT
Enroll - Private Aviation Account
5. On the next screen, entitled Enroll -- Private Aviation Account, enter information in
all of the fields marked with a red asterisk ( r ).The red asterisk means that an item of
information is required. If a field does not have an asterisk, you do not have to provide
it, but it is a good idea to provide this information if you can. (We use the word fields
to identify the white boxes where you enter information on the eAPIS website.)
Primary Point of Contact (POC) &
Alternate Point of Contact
The Primary Point of Contact (POC) is the person at your air taxi company whom CBP
should contact first about eAPIS matters. The Alternate Point of Contact is the person
whom CBP should contact about eAPIS matters if the Primary Point of Contact is not
available.
IMPORTANT The email address for the Primary Point of Contact is the email
address that CBP will use to send instructions for every private flight to or from
the United States. Someone at your company must be able to access the email
account during flight operations.
Create Your Password
Choose a password and enter it again in the boxes under Create Your Password.
Your password must be between eight and twelve characters in length. The first
character must be a number. The other characters can be numbers, capital letters,
small letters, and at least one of the following special characters:
~ ! # $ % ^ & * ( ) - _ + = { } [ ] | ; : . ? /
No character can be repeated consecutively more than two times. For example, your
password can include aa, but a password that includes aaa is NOT acceptable.
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Some examples of acceptable passwords are 123xa-abc, 1967lear60!, and
11aabbcc##.
Your password is case-sensitive. For example, if you choose a password with capital
letters and with small letters, you must always enter the same capital letters and small
letters when typing your password.
You must remember your password. You cannot retrieve it from eAPIS or from CBP.
You must renew your password at least every 90 days. You can change your password
by clicking on Reset your password on the Welcome screen.
Click . NEXT
Complete Enrollment
6. If you have entered your information correctly, the next screen will read Complete
Enrollment and state: You have completed all information necessary for enrollment.
This screen will list all of the information that you have just entered. You should make
sure that all of the information is correct.
TIP: If you have omitted some of the information that is not required, you will get
green warning messages on this screen. If you do not want to provide the
information that is not required, you can ignore the message or messages. If
you change your mind, click to return to the previous screen and enter BACK
the information. If you do not want to enter the information that is not required,
click and then the next screen will read Complete Enrollment. NEXT
If any of the information is not correct, click to return to the prior screen to BACK
correct the error.
If the information is correct, click COMPLETE ENROLLMENT
Part I - Step 2 - Validating the Account
7. CBP will send an email with enrollment information to the email address for the
Primary Point of Contact. This email will provide an APIS Sender ID for the carrier.
The APIS Sender ID will have eight characters: APGA and then four letters or numbers,
e.g., APGA123E. Do not expect to receive the enrollment email immediately, however,
as CBP is taking up to seven (7) days to confirm enrollments.
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This email will also provide an activation key. You must use the activation key to
activate your account the first time you log in to use your new eAPIS account for
private flights. You have seven days from the date of the email to activate your
account. If you do not activate your account within this seven-day period, you will have
to start over, that is, re-enroll with eAPIS and receive another email with a new
activation code.
8. a. To activate, go to https://eapis.cbp.dhs.gov
b. Under Log In under Enrolled Users, enter the APIS Sender ID that you
received from CBP, e.g., APGA1234.
c. Enter the password that you selected and click Log In O>
d. After you log in, you will see a screen that requests the activation code.
Because the activation code is long, you may want to copy the activation
code from your email and paste it into the space for the activation code.
Click Activate. If you have successfully enrolled, you will then go to a
screen entitled Private Aviation - Manifest Options where you can begin
the steps necessary to enter crew member data and to create and submit
the information for a private flight manifest.
PART II -- Using eAPIS to Submit Reports for Private Flights:
The procedure for using eAPIS to make reports for private flights is very similar but
not identical to the procedure for making reports for commercial flights. Mexican air
taxis that have been making commercial eAPIS reports should be generally familiar with
the steps that are outlined below.
Deadline for Submitting eAPIS reports for Private Flights
Inbound & Outbound Flights. eAPIS Notices of Arrival for flights inbound to the U.S.
and Notices of Departure for flights outbound from the U.S. can be submitted as far in
advance as you wish, but they must be submitted no later than 60 minutes prior to
departure for both inbound and outbound flights. As explained below, you cannot take
off until you receive an email from CBP and comply with all of the instructions in the
email.
Continuance Flights -- Not Applicable. You do not need to file an eAPIS report for a
private flight between two points in the United States, i.e., a continuance flight.
(Commercial flights by air taxis must file crew data, but not passenger data, for
continuance flights.)
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Overflights -- Not Applicable. You do not need to file an eAPIS report for private flight
that passes through U.S. airspace but does not take off or land in the U.S., i.e., an
overflight. (Note: Commercial flights must file crew data, but not passenger data, for
overflights through U.S. airspace.)
Part II, Step 1 - Entering Crew and Pilot Information
Before you can submit eAPIS reports for private flights operated by a Mexican air taxi,
you will need to log on to the eAPIS web site and enter the data for the crew members
who will be operating the aircraft on private flights.
1. Go to https://eapis.cbp.dhs.gov
2. On the Welcome screen, enter your Sender ID, e.g., APGA1234, and password
under Log In. Click Log In O>
3. The next screen will be the Terms and Conditions screen. Click I agree and
then click . NEXT
4. The next screen is entitled Private Aviation - Manifest Options. Under
click Update or Create Crew and Pilot Information.
NOTE: Use to change your passport or to update information for
the account holder. You should not use because this option
requires the preparation of a flight manifest in a special format.
5. The next screen is entitled Crew Maintenance. Click ADD CREW under Add
Crew Information:
6. The next screen is entitled Add New Crew Member. Enter the information for your
first crew member. You should enter information in every field. You must enter
information in fields that are marked with a red asterisk ( r ). If you do not, eAPIS will
not add the crew member to your list. Even though eAPIS will accept (with a warning)
crew information that omits data in fields that do not have a red asterisk, it is not
advisable to omit any information. Some of these information fields are required when
you make eAPIS reports even though they are not marked with a red asterisk.
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For Country of Residence & Country of Citizenship, the code for Mexico is MEX.
Under Document Information, for Document 1 enter the passport information for the
crew member. Again, for Mexican citizens the code for Country of Issuance will be
MEX. Although eAPIS does not require that you enter information for Document 2,"
you should enter the Pilots License information for Document 2 for every crew
member who is a pilot. Later, when you create a flight manifest, eAPIS does require
pilot license information for the crew member who is listed as the pilot for the flight.
7. After you enter all of the information for a crewmember, click . ADD CREW
8. You will then return to the screen where you will see, under the
heading Crew List: the name and date of birth (DOB) of the crew member that you
have just entered.
Updates or Corrections: To the right of the name and DOB of the crew member is a red caret
( v ) under the heading Update Information. If you need to change any of the information for
a crew member, click on the red caret and you will go to a screen entitled Update Crew
Member that contains the information that you previously entered for this crew member.
Update or correct this information as necessary.
9. Add additional crew members until your Crew List is complete. If you do not need to
file an eAPIS manifest for a private flight at this time, click Log out [X] at the top of the
screen. The information for the crew members will be automatically saved in the eAPIS
website for use in a future eAPIS manifest.
If you do need to file an eAPIS manifest for a private flight, click MANIFEST OPTIONS
to return to the initial screen, where you can then
submit a Notice of Departure or a Notice of Arrival for a private flight.
Part II, Step 2 - Submitting an eAPIS Report for Private Flights
Take the following steps to create an eAPIS report for a private flight that is arriving in,
or departing from, the United States,:
1. Go to https://eapis.cbp.dhs.gov At the Log In screen, enter your Sender ID and
Password that you created pursuant to the steps in Part I above.
2. Click I agree to accept the Terms and Conditions and then click . NEXT
3. The next screen is entitled Private Aviation - Manifest Options.
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IMPORTANT NOTE: The second paragraph on this screen contains an email
address in bold print. This is the email address of the Primary Point of Contact.
CBP will use this email address to send instructions regarding a manifest that
you have submitted. Someone must be able to access the email from CBP. It is
against CBP regulations to take off before you receive this email.
4. Under
Click Submit Notice of Departure for a flight departing the United States for a point
outside of the United States, or
Click Submit Notice of Departure for a flight arriving in the United States from a
point outside of the United States.
The remaining steps summarize the procedure for submitting a Notice of Arrival. The
steps for submitting a Notice of Departure are similar.
5. The next screen is entitled Notice of Arrival for _________, where your Sender ID
appears in the blank space, e.g., Notice of Arrival for APGA1234."
Aircraft Information
Under Aircraft Information, enter the tail number for the aircraft. Use only letters and
numbers. Do not use a dash. For example, XA123 would be acceptable, but XA-123
would not be acceptable.
Foreign Departure Information
Under Foreign Departure Information, first enter the four-letter ICAO code for the
airport of departure, the name of the airport, and the state where the airport is located.
On the next line enter the date and estimated time of departure (ETD) in local time at
the foreign airport of departure. Use a 24-hour (or military) format, e.g., 1334, not
1:34 p.m.
In the next five fields, enter the four-letter ICAO code for any airport where the aircraft
has landed during the 24 hours prior to the time of departure. If the aircraft has not
landed at any airport during the 24 hours prior to departure, leave all five fields blank.
If an airport at which the aircraft has landed during the 24 hours prior to departure does
not have an ICAO airport code, enter a name or other information that would identify
the airport. You can enter up to 10 characters to identify each such airport.
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Next enter the Estimated time and location of crossing U.S. Border or Coastline.
Use 24-hour format for the local time at the point of crossing and use the nearest U.S.
city or town for the location of crossing.
U.S. Arrival Information
Enter the four-letter ICAO code for the U.S. airport at which you will be landing. If the
U.S. airport at which you will be landing does not have an ICAO code, enter the ICAO
code for the nearest U.S. airport that does have an ICAO code.
Enter the date of your arrival and your estimated time of arrival (ETA) in local time at
the U.S. airport of arrival. Again, use 24-hour format for entering the time.
Enter the U.S. city for the airport of arrival. In the next field enter the two letter code
for the U.S. state. For a list of the two letter states codes, click on the arrow in the circle
next to the field.
If your airport of arrival has an ICAO code, you do not need to enter anything into the
Arrival Location Description.
When the U.S. airport of arrival does not have an ICAO airport code, however, enter the
ICAO code of the nearest airport that does have an ICAO code into the Airport field on
the first line of this section and then enter the name of the actual U.S. airport of arrival
in this Arrival Location Description field.
24 Hour Emergency Contact Information
Enter the last and first name and telephone number of an individual who is not on the
aircraft to be an emergency contact. You may also enter an email address, but
providing an email address is not mandatory.
Traveler Counts
Enter the number of crew members and the number of passengers on the flight.
Click to go to the next screen. NEXT
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6. The next screen is entitled Aircraft Information, and the first section on this screen
is also entitled Aircraft Information.
Aircraft Information
The tail number of the aircraft is already entered using the tail number that you have
already provided.
Enter the type of aircraft in the Type of Aircraft field, e.g., Gulfstream G-V. Enter its
color or colors in the Color field, e.g., white with blue stripes.
If you have a call sign that you will use for this flight, enter it under Call Sign.
If you have a CBP decal, enter the number of the decal under CBP Decal Number.
Aircraft Operator Information
The Aircraft Operator can be either an individual or a company. If the Aircraft Operator
is a Mexican air taxi, enter the name of the air taxi company in the Company Name
field, e.g., Aerotransportes Poinsettia, S.A. de C.V.
Enter the Street Address, Apartment or Suite Number (if applicable), City,
State/Province, Zip/Postal code, Country, Telephone Number, Fax Number
(optional), and Email Address for the Aircraft Operator.
Below is a list of the two letter codes that eAPIS uses for the Mexican states:
AGUASCALIENTES AG
BAJA CALIFORNIA NORTE BA
BAJA CALIFORNIA SUR BJ
CAMPECHE CE
CHIAPAS CI
CHIHUAHUA CH
COAHUILA CU
COLIMA CL
DISTRITO FEDERAL DF
DURANGO DO
GUANAJUATO GU
GUERRERO GR
HIDALGO HL
JALISCO JL
MEXICO MX
MICHOACAN MC
MORELOS MR
NAYARIT NA
NUEVO LEON NL
OAXACA OA
PUEBLA PB
QUERETARO QU
QUINTANA ROO QR
SAN LUIS POTOSI SL
SINALOA SI
SONORA SO
TABASCO TB
TAMAULIPAS TA
TLAXCALA TL
VERACRUZ VC
YUCATAN YU
ZACATECAS ZA
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Aircraft Owner/Lessee Information
The Aircraft Owner/Lessee can be either an individual or a company.
If the Aircraft Owner is a company and the Aircraft Lessee is a different company,
you can enter the name of either company in this field. If the MexIcan air taxi that is
operating the aircraft is leasing the aircraft from another person or company, the
Mexican air taxi will be the Aircraft Lessee.
Enter the Street Address, Apartment or Suite Number (if applicable), City,
State/Province, Zip/Postal code, Country, Telephone Number, Fax Number
(optional), and Email Address for the Aircraft Owner or the Aircraft Lessee.
Click to go to the next screen. NEXT
7. In the Select Crew row, the first field is labeled Crew and has the words Select
Crew Member. Click the down arrow to the right of Select Crew Member. A drop-
down list will appear that lists the names of the crew members that have already been
entered into eAPIS. If the drop-down list has the names of any of the crew members
for the flight, click on the name of a crew member and then click SHOW DETAILS in
the adjacent box. The information for that crew member will populate the data fields
under Crew Details. (If you have made an error and selected the wrong crew
member, click CLEAR DETAILS and start over by selecting a different crew member
and clicking SHOW DETAILS for that crew member.)
Check the information to make sure that it is correct. Except for the name of the crew
member, you can change any of the information for this crew member for purposes of
this flight, but making changes for this flight will not permanently change the information
that you have previously entered for this crew member in eAPIS. To update the
information permanently, you must separately go to the Crew Maintenance section as
described above and make any changes there.
Next please notice the Crew Member Status. It will be either Pilot or Crew, but the
crew manifest for a private flight can only list one pilot. If you have previously listed
each of two crew members for a private flight as Pilot under Crew Member Status,
you will need to decide which one will be the Pilot for this flight. You will then need to
change the Crew Member Status for the other crew member to Crew.
Next enter the Street Address, City, State, and ZIP Code for this crew member
while in the United States. This can be a hotel, if applicable, but the address must
begin with a number, e.g. 123 Main Street. If you do not have an address for the crew
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member, e.g., the flight is turning around and leaving the U.S. the same date that it
arrives, you can enter the address of a fixed-base operator at your Arrival Airport.
Note: Although this Memorandum is describing the procedure to submit a Notice of Arrival,
please note that eAPIS also asks for a U.S. address for each crew member on a Notice of
Departure. For Notices of Departure we recommend that you enter the address where the crew
member stayed while in the U.S., and if there is no such address, to use the address for a fixed-
base operator at your U.S. Departure Airport.
When the information for the first crew member is complete, click
SAVE TO MANIFEST
NOTE AGAIN If you have changed any information for a crew member for this
flight, the changed information is only valid for this flight. Any changes are not
permanent until you make the changes in the Crew Maintenance Section
After you click SAVE TO MANIFEST, you will see that crew members Crew Status and
Name at the bottom of the screen under Manifest Crew List.
To the right of the crew members name is a column with the heading View
Information and in this column is a red caret ( v ). If you click on the red
caret, you then reopen the screen with the data for this crew member. Any
changes that you make for this crew member will only apply to this flight.
In the next column to the right is a column entitled Remove from Submission
with a red dash ( ) to the right of the red caret. If you click on this dash, you
will go to a screen that lists the Name, Date of Birth, and Document Type for the
Crew Member and asks, Do you want to remove this Crew Member from the
Manifest? To proceed with the removal, please select Next. If you do not want
to remove the crew member, select Back to return to where you were in eAPIS.
Whether you select Next or Back, you will then return to the Crew Information
screen.
Continue to add crew members by following this process until you have added all of the
crew members. When you have completed adding crew members, click NEXT STEP.
8. The next screen is entitled Passenger Information.
This screen provides the fields to enter the passenger data for up to five passengers.
The data that is required is similar to the data that is required for crew members. Again,
please note that a red asterisk ( r ) marks every field that is mandatory.
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NOTE: If your flight has more than five passengers, enter the data for the first five passengers
on this screen and then click ADD PASSENGERS at the bottom of this screen. You will then go
to another screen that will have space to enter the data for five more passengers.
You should enter each passengers Address While in the United States such as a
hotel or private residence if you know this information. It you do not have a U.S.
address for a passenger, you can use the address of the fixed base operator at your
airport of arrival. This is the same procedure as when no U.S. address is available for
crew members.
Under Document 1" select Passport under Document Type and then enter the
passport number under Document Number. Next, be certain to enter the Country
of Issuance and Expiration Date for the passport. Even though these two fields
do not have red asterisks, the Country of Issuance and Expiration Date are
mandatory for persons who are not U.S. citizens.
It is not necessary to enter information under Document 2, but if you have the
information for any of the other types of documents for a particular passenger, you may
enter it here.
When you are through entering the information for all of your passengers, click
. REVIEW MANIFEST
9. You will next go to a screen entitled List of Travelers. This screen lists the names
of all of the persons on the aircraft -- i.e., one pilot, any other crew members, and all
passengers. By clicking on the red caret ( ) next to each traveler, you can view the
information that you have entered for that person. By clicking on the red minus sign or
dash ( ) in the row for each person, you can delete that person from the list.
On this screen you can also click to go back to the first screen,
EDIT FLIGHT INFO
, where you can review and change the information
that you have previously entered regarding the details of the flight for example,
departure and arrival points, aircraft information, dates, times, etc. When you are
through on that screen, you will then navigate through the screens where you have
previously entered Aircraft Information, Crew Information, and Passenger
Information to return to the screen entitled List of Travelers.
If everything is complete, click . If you have entered information into all of the DONE
required fields and the information that you have entered is in the correct format, the
next screen will read--
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10.
You have completed all of the necessary information for submitting a manifest
through eAPIS.
Please review your eAPIS manifest before submitting to CBP.
Select Next to review your manifest.
NOTE: The eAPIS program does not check whether the information that you
have submitted is correct. eAPIS can only determine whether you have
completed all of the mandatory fields and whether the information is in the
correct format. You are responsible for the accuracy of the information. If you
enter an incorrect passport number for a passenger or you fail to enter a
Country of Issuance for a passport, CBP could impose a penalty if a CBP
inspector becomes aware of incorrect or omitted information.
If there is an error, the next screen will notify you of the error and require you to correct
the error before you can submit the manifest.
If there is a warning, eAPIS will advise you. You should try to fix the entry that caused
the warning, but you can choose to ignore the warning. You will still be able to submit
your manifest.
If your screen displays No Errors or Warnings, click . NEXT
11. The title of the next screen is Final Review. Carefully review all of the information
that you have entered for this flight. If you need to change any item of information, click
Update Info > at the end of each section of information to go to the eAPIS screen where
you can change information in that section.
If all of the information is correct, you are finally ready to submit your eAPIS manifest to
CBP. Before you submit, we recommend that you print a copy of the information on
this screen. Then click to submit the manifest. SUBMIT
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Part II, Step 3 Receiving CBP Approval for Departure
1. The next screen after you click is Submission Details. There are three SUBMIT
important pieces of information on this screen. First is advice that the eAPIS
submission does not fulfill notice of departure requirements and that you will receive
an email with departure instructions. Second is advice that you can print a copy of your
manifest for your records and receive additional instructions by clicking HERE. The
third important item of information is your eAPIS Submission Number that appears on
this screen. We recommend that you copy your eAPIS Submission Number and click
the word HERE.
Print Manifest
2. You will then see a screen with a complete Manifest Information, including your
Submission Number. Click the Printer ICON to print all of the Manifest Information.
CBP recommends that the pilot carry a copy of the Manifest and the Submission
Number in the aircraft during the flight.
IMPORTANT: The Department of Homeland Security (DHS) will send an email to the
email address used during the enrollment process. See the IMPORTANT NOTE on
page 6 of this Memorandum.
3. eMail for Flights Arriving Into the United States
The email will state that Notices of arrival and/landing rights must be coordinated
directly with the CBP destination port. In other words, you must call CBP at the U.S.
destination airport and provide your usual arrival notice.
IMPORTANT: The flight should not take-off from the foreign departure airport until after
receipt of the email and after notice has been provided to CBP at the U.S. port of
arrival. Prior to takeoff, follow all instructions given by the CBP port at the U.S.
destination airport.
4. eMail for Flights Departing From the United States Follow the instructions in the
email.
If there are no problems the email will state Based on the information submitted, you
are cleared for departure. The aircraft may then depart from the U.S. airport.
If DHS has any objections to the aircraft departing the United States, the email will
provide specific instructions, such as to call DHS. DHS will provide the telephone
number.
IMPORTANT: Do not take off until fully complying with DHS instructions.
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PART III -- CHANGES TO MANIFEST & OBTAINING ANSWERS TO QUESTIONS
Changes to a Submitted Manifest
It is not possible to use eAPIS to withdraw a manifest for a flight that has been
canceled. You should notify CBP of the flight cancellation by telephone.
Changes to ETA, ETD, or the arrival or departure locations can be made either by
submitting a new manifest or by telephone or radio, but CBP prefers that you make a
new eAPIS submission to make these changes whenever possible.
Although the regulations do not specify how much your ETA or ETD must change for
you to make a new submission, we recommend that you submit a change to your ETA
whenever it changes from the original ETA by more than two hours or moves to another
day. If the change in your ETA is more than 15 minutes, however (but less than two
hours) we recommend that you advise CBP by telephone or radio as a courtesy in order
to minimize any inconvenience to CBP officials.
For a change in ETD, treat your CBP approval as valid for a departure time on the
same day as the original ETD. If your ETD is delayed to the next day, we recommend
that you submit a new manifest to update the ETD.
After you submit an amended manifest, any clearance based on an earlier manifest is
invalid, and you must wait for your new approval before you depart on a flight to the
U.S. or from the U.S.
Note: CBP states that it will accept manifest information by telephone when unforeseen
circumstances preclude submission of the information via eAPIS. CBP does not define
unforeseen circumstances, but you should only attempt to submit manifest information by
telephone when no internet is available or in emergency situations.
Additional eAPIS Questions & Assistance. Please let us know if you have any
questions about submitting private eAPIS manifests.
We are also available to provide additional assistance with respect to eAPIS matters.
For example, we can enroll your air taxi/company in Private Aircraft eAPIS. We can
also activate your eAPIS account on your behalf. Finally, we can provide instructions to
persons in your company on the use of eAPIS.
You can contact us at 202-331-3300 or airlaw@rollerbauer.com.
We hope this Memorandum will be useful to you. Please let us know if you have any
suggestions to improve this Memorandum.