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Five Steps to a Competitive Acquisition

by David Wyndham 1. October 2006 00:00
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In turbines, it is mostly a seller's market. Many of the manufacturers are sold out 18 – 24 months ahead. That doesn't mean that you can't negotiate, you just have to be willing to wait, or look at the pre-owned market which still has some great aircraft at reasonable prices.

Regardless of the market you are in, you need to follow some simple steps to ensure you are getting a good deal. The objective of a competitive acquisition is to get the best price for the right aircraft.

Step one is to do your homework. Have your performance parameters defined. What are your missions? What do you need in order to accomplish that mission? Be realistic – we all want more speed and more range. What do you truly need versus what would you like to have. Know the difference between the two.

I use "required" and "desired" criteria. Required criteria are those performance items that the aircraft must meet in order to be successful at accomplishing the mission. It may be a combination of payload, range, speed and take-off/landing capability. Desired criteria are the nice-to-have items that, although not necessary for mission accomplishment, will enhance the ability of the aircraft to perform the mission. Desired criteria enable you to better differentiate between the various aircraft.

What aircraft are capable of performing those missions? What do those aircraft cost to own and operate?

You need at least two types, and preferably three or more different types to set up a competition. If there is only one make/model that will do your job, then it is hard to expect much competition.

Step two is to get your in-house team together. You need technical expertise in aviation and finance. You also need legal and tax advice. Setting up a true competition takes time. Know what your options are before looking at aircraft. If you plan to get a loan, or to lease, what are the prices? If trading/selling one business aircraft for another can you take advantage of a tax-deferred exchange?

Step three: Separate Performance from Price. Be clear as to what performance parameters your aircraft must meet. All these specifications must be measurable - a 5 foot 9 inch cabin is measurable, a stand-up cabin is not. Make sure each specification ties into a mission parameter, i.e. is defensible as a requirement. Document these specifications for the seller.

In a separate document, have your pricing and delivery schedule. Set up the format that you want the price proposals to be in. You may specify the price proposals are to include life cycle costing, finance or lease options, and multiple delivery options. You may specify a base configuration with several options. Be realistic in your expectations. Don't plan to get an early delivery position on an extremely popular aircraft.

Once you have the performance and prices rules set forth, then its time to send them out. If you are dealing with both new and pre-owned aircraft, then you'll be dealing with multiple airframe manufacturers and perhaps an aircraft broker. Make sure they know that they are to return two separate items in response to your request, Performance and Price. Don't ask for proposals on Aircraft Model X, ask for a proposal on aircraft that meet the criteria you specify.

Step four: evaluate the proposals. First evaluate the performance without looking at price. For those that do not meet your required criteria – no more analysis is needed. Do not open the price proposal and be tempted by an aircraft that won't do the job for you. Rank order the remaining aircraft according to how well they meet or exceed your required and desired criteria.

Step five: Thank everyone for "coming to your party" and notify those that no longer are in competition. Of those remaining, whether there is room in the market for negotiations or not, ask them to improve their offer. Let the contenders know they are in a run-off. Acquisition price may be non-negotiable, but added equipment, delivery dates, training, etc. may be used to give you a better deal.

The goal is to get you the best value for the price. If you remove emotion and leave folks with the impression that not buying now is an option, and then even in a seller's market, you will still be able to get as good a deal as you can.

Gone through this process recently? Have any tips to share? Without naming names, let me know how it went.

PS: If you are attending the NBAA Convention down at Orlando, please drop by we are at Booth #2877

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David Wyndham

How to Compare Aircraft Costs

by David Wyndham 1. October 2006 00:00
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Given all the recent activity in announcing new models, plus the general overall health of the economy, you may be fortunate to be in a position to acquire a new, or new to you, aircraft. It would be a grave error to focus in on the acquisition cost alone. Why?
 
While there is a ceiling on how much you can spend, the operating costs are a significant part of aircraft ownership. An extreme example is a Gulfstream GII. You can buy an early model GII for under $2 million, but to operate it for 5 years will likely cost you more than $14 million!
 
When you are comparing aircraft costs, it is important to understand what costs are included and what aren't. Otherwise, you can end up comparing "apples and oranges." This can lead to making a decision with wrong or incomplete information. What is the general methodology to use when analyzing the acquisition of an aircraft? It is called Life Cycle Costing.
 
As the name implies, Life Cycle Costing looks at a period, or a "Life" of the asset. It does not have to be the entire useful life, but it should cover the anticipated period of ownership.
 
Life Cycle Costing also ensures that all appropriate costs should be considered. The Life Cycle Costing includes not only the acquisition cost, but also operating and maintenance costs, and market depreciation. If the acquisition is for business use, amortization, interest, depreciation, taxes and the cost of capital can be included. At the end of the Life Cycle, it also recognizes the estimated value of the asset (i.e. assumes a sale at the end). Think of Life Cycle Costing as a multi-year operating budget that also includes the acquisition and resale.
 
All your assumptions used need to be clearly spelled out. Fuel, hangar, insurance, all need to be reasonable estimates based on your experience, or that from a reliable source.
 
The costs should cover a specific period and take into account an expected aircraft value at the end of the term. If you plan to own the aircraft for 10 years, then that is your life cycle. As an estimate, I'd recommend at least 5 years to show the effects of a major inspection or two. The residual value or market value of the aircraft should be based on a combination of historical data and market prognostication. Don't forget about inflation. It adds to your costs and adds to the residual value as well.
 
When comparing two or more options, you should cover the same period of time and utilization. This provides for a fair comparison. A complete Life Cycle Cost can also account for the time- value of money in a Net Present Value (NPV) analysis. This way, the differing cash flows form two or more options that can be compared and analyzed from a fair and complete perspective. The NPV takes into account not only how much, but when expenses (and revenues) occur.
 
Calculating the NPV time value of money is a snap with a spreadsheet. In fact, doing the entire Life Cycle Cost in a well set up spreadsheet using reliable data is much easier that it sounds.
 
Different operations can have a different focus. Regardless of that focus, a well done Life Cycle Cost shows all the costs and allows the financial decision to be based on as complete a picture as possible. What methodology do you use to evaluate different aircraft costs? Are you directed to look only at certain costs? Please click reply and let me know.

How do you or your company determine Life Cycle Cost of the aircraft you fly. Do you follow the general outline listed above?

 

NTSB Appeals Policy

by Greg Reigel 1. October 2006 00:00
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Airmen, and sometimes their counsel, continue to suffer from the National Transportation Board's (NTSB's) strict application of its timing requirements for filing appeals. As you may know, when the FAA issues an order of suspension or revocation of an airman or medical certificate, the airman has an opportunity to appeal that order to the NTSB for a hearing on the merits. Additionally, if after a hearing the airman is unsatisfied with the NTSB administrative law judge's (ALJ's) decision, the airman has the opportunity to appeal that decision to the full NTSB Board.

Under the NTSB's rules of practice, 49 CFR Part 821, an airman has a specified period of time within which to file his or her appeal. In the case of an appeal of an FAA order, the airman has 20 days from the time of service of the order within which to file the appeal. Part 821.30(a). In the case of an appeal of an ALJ's initial decision, the airman has 10 days after the date on which the oral initial decision was rendered, or the written initial decision or appealable order was served, within which to file a notice of appeal with the NTSB. Part 821.47(a). The airman then has 50 days from the date the oral initial decision was rendered, or 30 days from the date of the written initial decision or when the appealable order was served, within which to file his or her appeal brief. Part 821.48(a).

The Board will not consider untimely appeals and will grant an FAA motion to dismiss such appeals unless the airman can show good cause for the delay in filing. Although this may seem like it grants an airman some leeway, in fact, the Board has very rarely found an airman's explanations for an untimely filing to constitute good cause. In order to better understand the Board's strict adherence to deadlines, it is helpful to review some of its decisions applying these rules.

Appeal Of An FAA Order

In Administrator v. DeLuca, the FAA issued an emergency revocation order on November 1, 2004 revoking all of the airman's certificates. The order was sent via regular and certified mail, and via Federal Express delivery. However, it wasn't until April 1, 2005 that the Board received a letter from the airman appealing the emergency revocation and attempting to justify his delay in filing the appeal with the explanation that he had been out of the country.

The ALJ granted the FAA's motion to dismiss the appeal as untimely. The ALJ relied upon the airman's statement that he "forgot to open all of the letters that were sent to me" in holding that the airman failed to exercise the required diligence and thus did not have good cause for his delay in appealing the emergency revocation.

The Board agreed with the ALJ noting that the airman admitted having access to his mail in December, 2004 when he was back in the country. They also noted that the airman admitted returning home on March 15, 2005, but that he dated his notice of appeal March 25th and it was not actually received by the Board until April 1st. Based upon this evidence, the Board held that the airman had not demonstrated good cause for his delay in filing a notice of appeal. The "out of the country" argument did not save the day.

Similarly, in Administrator v. Sepulveda, the FAA sent a Notice of Proposed Certificate Action ("NPCA") to the airman proposing to suspend the airman's certificate. The airman did not respond to the NPCA and the FAA then issued an order suspending the airman's certificate for forty-five days. Although the airman appealed the order, he filed his appeal with the NTSB three days late. The ALJ subsequently granted the FAA's motion to dismiss the airman's appeal based upon the untimely filing.

On appeal to the full NTSB Board, the sole issue was whether the airman had shown "good cause" for his untimely filing. In rejecting the airman's appeal, the Board stated that "[h]aving kept his father's address as his official address on file with the FAA while he apparently was living elsewhere, he was obliged to check that address for FAA mail, especially since a Notice of Proposed Certificate Action had been sent to him. The situation that caused the delay in respondents becoming aware of the Order of Suspension was of respondents own making."

This isn't the only case in which an airman has argued that an untimely appeal was the result of the airman's designation of his or her parents' address for FAA purposes. It is also not the only case in which the Board has rejected this argument. Although the practice of designating an official address with the FAA that may not be where the airman spends a great deal of time is fairly common, airmen who do so need to take steps to ensure that they are promptly notified of any mail from the FAA. The NTSB will not consider any delay in receiving or responding to mail from the FAA due to untimely receipt of the mail from the airman's parents' address supported by good cause.

Appeal Of An ALJ's Initial Decision

An airman filed his appeal from an ALJ's initial decision 14 days late in Administrator v. Grieshaber. On appeal of the dismissal of his appeal, the airman argued that his late filing was excusable because "(1) two other NTSB law judges (Judge Mullins and Judge Geraghty) allegedly told one of respondent's former attorneys during a discussion at the NTSB Bar Association meeting on June 8 and 9, 2005, that Judge Popes decision was "an advisory opinion"; and (2) there is "confusion" over whether he was properly advised of the deadline for filing a notice of appeal.

The Board rejected the airman's assertions holding that they were not good cause for his failure to file a timely appeal. With respect to the "advisory opinion" argument, the Board noted that the airman had not provided any "documentation or substantiation for the alleged statement by Judges Mullins and Geraghty that the oral initial decision in this case should be viewed as merely advisory." In fact, the Board stated that "any such statement would be obviously incorrect and patently inconsistent with our rules." Additionally, the evidence showed that the ALJ "discussed the evidence, affirmed the alleged violation, gave the parties written copies of their appeal rights, confirmed on the record that the attorneys for both parties had nothing further to raise before him, and then stated, "very well then the hearing is closed."

The Board was equally unsympathetic to the airman's argument that he was not properly informed of the filing deadline for a notice of appeal. According to the Board, "[n]ot only did the law judge hand respondents counsel a written copy of his appeal rights, presumably in respondent's presence, but the Boards procedural rules are publicly available and copies of those rules were sent to respondent's counsel of record when he filed his initial appeal to the Board. If his attorneys did not pass on this information or otherwise failed in their duty to respondent, his recourse is against the attorneys, not the Board." This appears to be unlikely given that the airman was represented by three attorneys at the hearing, one of whom was an Air Line Pilots Association senior attorney with many years of experience in NTSB proceedings.

It is interesting to note that the airman was not represented by counsel on his appeal to the Board. It appears that his failure to have counsel for the appeal may have contributed to the fact that his appeal was untimely and the airman was then required to make some creative arguments in an attempt to show good cause for his late filing. Unfortunately, his arguments were inconsistent with and unsupported by the facts, and did not amount to good cause as established by Board precedent.

Administrator v. Walkowicz also involved dismissal of an airman's untimely appeal. In response to the FAA's motion to dismiss the airman's appeal, the airman's counsel argued that the untimely filing was due to "clerical error" and that the FAA was not prejudiced by the late filing. The NTSB rejected the arguments.

First, it noted that "clerical error", without further explanation of the nature of the actual error, does not amount to good cause for the untimely filing. Second, the Board held that lack of prejudice to the FAA does not constitute good cause for an untimely filing. The Board stated that "we do not evaluate untimely filings under a prejudice standard; rather, we uniformly apply a good cause standard".

In a different case with a somewhat unusual procedural posture, the NTSB denied an airman's request for reconsideration of its decision affirming an ALJ's dismissal of the airman's appeal from the Administrator's order of suspension. The Board originally affirmed the ALJ's determination that the airman's appeal was filed late and held that the airman had not presented any evidence of good cause for the Board to accept the late appeal.

In Administrator v. Beissel, the airman requested reconsideration of the Board's decision claiming that "the Board applies its good cause standard unevenly, ruling more often in the Administrators favor than in a respondents favor." The airman argued that Ramaprakash v. FAA and NTSB, 346 F.3d 1121 (D.C. Cir. 2003) supported his claim of uneven application of the standard.

Initially the Board noted that "the good cause standard requires that a respondent prove his failure timely to file a notice of appeal within the required time had a good cause" and that the reasons for the airman's tardiness did not constitute good cause for his late filing. It went on to specifically address the airman's claim of uneven application of the standard by stating "[t]his is a question of fact, specific to each case. Whether the Board is applying this standard uniformly to notices of appeal and appeal briefs is determined by reviewing other cases involving late filing of notices of appeal and appeal briefs, not by comparing this case with other, entirely different types of cases that also happen to use the good cause test."

Finally, the Board noted that "Ramaprakash, infra, actually supports this conclusion, as the parties and the Court analyzed the reasonableness of our action in that case based on our actions in other stale complaint cases, not based on the universe of cases in which a good cause standard was used." Although it probably seemed like a good argument for the airman to make, unfortunately, he took it out of context and made an apples to oranges comparison. The Board didn't buy it and the airman was stuck with his 180 day suspension.

The 8th Circuit Court of Appeals has also affirmed dismissals based upon a certificate holder's untimely filing of a notice of appeal. In Cornish v. FAA, the Court dismissed a mechanic's appeal of an NTSB oral decision after the appeal brief was filed nine days late. The Court reviewed the rule requiring that the administrative appeal from an oral initial decision must be perfected by filing a brief within fifty days of that decision absent a showing of good cause. In this case, the mechanic's counsel apparently mistakenly believed that the appeal had to be filed within fifty days from the filing of the notice of appeal, as opposed to the date of the oral decision. The NTSB found that the error was without good cause and dismissed the appeal.

The Court of Appeals affirmed the NTSB's dismissal of the appeal. In response to the mechanic's argument that the dismissal was arbitrary and capricious because the Board had dismissed many appeals without explaining what constituted good cause, the Court stated that "the Board need not attempt to catalog what might be good cause in other cases when it consistently rules that mistakes by the appellants attorney in construing the agency's procedural rules is not good cause." Unfortunately, this case did not provide any helpful explanation as to what does, as opposed to what does not, constitute good cause.

Conclusion

Board precedent on this issue is clear: In the absence of "good cause", appeals must be filed within the time periods allowed by the rules. Certificate holders and their counsel need to understand and be aware of the deadlines for filing appeals in order to avoid finding themselves in the position of having to argue "good cause" for a delay. As the cases show, the good cause standard is not clearly defined and is very difficult to meet. The best bet is to be aware of, and to meet, the deadlines prescribed in the NTSB rules of practice.

If you have had any situations where you have found yourself between the FAA and the NTSB we would like to here about it.  Place your comments below.

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Greg Reigel

Equal Access to Justice Act: Making the FAA Pay

by Greg Reigel 1. October 2006 00:00
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If the FAA initiates an enforcement action or civil penalty action and then loses, does the certificate holder or target of the civil penalty action have any recourse? Well, under the Equal Access to Justice Act ("EAJA") it may be able possible to make the FAA pay for the attorney's fees and expenses incurred by the certificate holder or target of the civil penalty action to defend against the claims asserted by the FAA. Although this may not seem like much consolation, it provides some recourse when the FAA has improperly pursued an action.

The EAJA is found at 5 U.S.C. 504 and is implemented in 49 CFR 826. According to 49 CFR 826.1, "The Equal Access to Justice Act, 5 U.S.C. 504 (the Act), provides for the award of attorney fees and other expenses to eligible individuals and entities who are parties to certain administrative proceedings (adversary adjudications) before the National Transportation Safety Board (Board). An eligible party may receive an award when it prevails over the Federal Aviation Administration (FAA), unless the Government agency's position in the proceeding was substantially justified or special circumstances make an award unjust." In order to determine whether EAJA fees are available, the key inquiries for a certificate holder or target of a civil penalty action who is applying for an award of fees (the "Applicant") are (1) Is the Applicant a "prevailing party"? (2) Was the Applicant involved in an "adversary adjudication"? (3) Was the FAA's position "substantially justified"? and (4) Were the fees actually "incurred" by the Applicant?

Was The Applicant A Prevailing Party?

Obviously, if an Applicant was successful at the hearing and the administrative law judge dismissed all charges against the Applicant, then the Applicant is a prevailing party. However, an Applicant may also be a prevailing party in situations where the FAA dismisses some, but not all of the charges or if the FAA asserts multiple charges against the Applicant but is only successful on some of the charges at the hearing. It is also possible that an Applicant could be considered a prevailing party under EAJA when the Applicant has been able to reach a favorable settlement with the FAA.

Was The Applicant Involved In An Adversary Adjudication?

For purposes of EAJA, an adversary adjudication does not arise until after an FAA order is appealed by the Applicant. If the FAA does not issue an order, EAJA is not triggered. Once the order is appealed, then the attorney's fees and expenses incurred from that point on become eligible for an EAJA award.

Was The FAA's Position Substantially Justified?

In order for the FAA's position to be substantially justified, it must have been reasonable both in fact and in law. This means that sufficient, reliable evidence must have existed in support of a reasonable legal theory asserted by the FAA in the action. This determination is made based upon the entire administrative record and the FAA's failure to prevail on the merits does not automatically result in award of the requested attorney's fees and expenses. It is important to note that under EAJA, the FAA's burden of proving substantial justification is less demanding than its burden of proof when arguing the merits of the underlying complaint at the hearing. If key factual issues can only be resolved through a credibility determination by the ALJ, then the FAA's position is considered justified. This is often the case and certainly the most common argument raised by the FAA in opposition to an EAJA fee request.

Were The Fees Actually Incurred By The Applicant?

In order to recover EAJA fees, an Applicant must show that the Applicant actually incurred the fees and expenses requested. In a situation where the Applicant has paid an attorney for representation throughout the enforcement process out of the Applicant's own pocket, this is easy. Conversely, when an Applicant's employer or union pays the fees then the Applicant did not incur the fees for purposes of EAJA. However, if the employer advances the fees and the Applicant is obligated to repay those fees regardless of the outcome of the action, then the Applicant would be considered to have incurred the fees.

Also, it may be possible for an Applicant to incur fees by retaining an attorney on a contingent fee basis under which the attorney would only receive payment in the event of an EAJA recovery. However, this type of arrangement must be documented at the time the attorney is retained in order for it to qualify under EAJA. In general, documentation of the payment of, or obligation for, the fees is critical to recovery under EAJA.

The Application Process

Under EAJA, an application for an award must be filed within 30 days of the final disposition of the enforcement action. Final disposition occurs as of the date on which an un-appealed initial decision becomes administratively final. For example, in a certificate action, any appeal of an initial decision must be filed within 10 days from the date of the NTSB administrative law judge's decision. Since the last day of a designated period is included in the computation of a time limit, on that tenth day, the 30-day period for filing an EAJA application also begins to run. Thus, in the case of a certificate action, the final day to file the EAJA application is actually the 29th day after expiration of the 10-day appeal period. As with many other deadlines in the enforcement process, this deadline is jurisdictional and will result in the denial of an EAJA request if it is filed after expiration of the 30 days. EAJA requires that the application be detailed and that it contain specific documentation and explanation of the fees and expenses requested. Additionally, the Applicant will need to submit evidence that the Applicant meets the net-worth limitations under EAJA (generally $2,000,000 for individuals and $7,000,000 for businesses).

The fees and expenses recoverable under EAJA include attorneys fees (at a current rate of approximately $156.00 per hour based upon the CPI) as well as costs and expenses reasonably incurred in the action such as witness fees, expert witness fees etc. The attorney's fees and expenses will be evaluate to determine their reasonableness based upon the customary fee or cost for such services, the prevailing rate for similar services in the community, the time actually spent in the representation of the Applicant, and the time reasonably spent in light of the difficulty or complexity of the issues enforcement action.

This means that the attorney representing the Applicant must include more detail than simply the amount owed. To do this, the attorney needs to be careful to provide a description of the nature of the work performed on behalf of the Applicant without disclosing sensitive client information or information subject to the attorney-client privilege.

Conclusion

If you have to defend yourself against the FAA in an enforcement action or civil penalty action, having the charges dismissed can be a bittersweet victory. You have won the war, but your wallet is a lot lighter. Fortunately, the EAJA can provide you with some consolation. Assuming you qualify, you can force the FAA to reimburse you for the attorney's fees and expenses you incurred defending yourself. Although this may not be complete satisfaction, making the FAA pay can certainly provide some consolation.

Question:

Have you or someone you know ever been in an enforcement action or civil penalty action with the FAA.  If you have please tell us about your experiences win or lose.

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Greg Reigel

Aircraft Market Report: 2006 Q3

by Jeremy Cox 1. October 2006 00:00
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Most of the data contained in this report is very courteously and kindly provided by the folks from Kansas at the Aircraft Bluebook – Price Digest, http://www.aircraftbluebook.com/ I would again like to especially thank Mr. Paul Wyatt, the Bluebook Editor for the use of his data in the production of my report. I hope that you find the report of some use to you.

The following aircraft/helicopters saw the largest gains in value, including the normal yearly/model new price increases:

The Winners

Augusta 109C at 6.63%, which is 6.35% UP from the last Quarterly Report.

Bell Jet and Long Rangers (B206 and B407), at 22.17%, which is 5.88% UP from the last Quarterly Report.

Bombardier Challenger 300, at 11.39%, which is 4.17% UP from the last Quarterly Report.

Cessna Citation Jet and CJ2 (525 and 525A), at 5.25%, which is 3.83% UP from the last Quarterly Report.

I.A.I. Westwind (1124, I and II), at 6.20%, which is 1.10% UP from the last Quarterly Report.

Dassault Falcon 900 (900A, B, C, DX and EX), at 5.36%, which is 0.78% UP from the last Quarterly Report.

Most Are Holding Their Own Regarding Value

The Overall Market has shown an Increase in value ‘Across the Board', equal to 3.9% over the last twelve months, which is 0.02% better from the last Quarterly Report. This may however, be an indication of a slowdown, or it may just be the normal effect of the annual summer holidays, on the overall marketplace.

The Losers

Rockwell Commander (112, 114 and 115) at -8.05%, which is a staggering 6.46% DOWN from the last Quarterly Report.

Cirrus (SR20 and SR22) at -5.42%, which is a further 1.03% DOWN from the last Quarterly Report.

Interpretation

Well the personal/corporate helicopter has won the day, so to speak when it comes to the percentage of value gains in the overall marketplace, especially when viewed against the figures of the last Quarterly Market Report back in August of this year (2006.) Both the Augusta 109C and Bell JetRanger and LongRanger have rocketed up in value this quarter.

The Challenger 300 still appears that it is the number one, most sought after used business jet aircraft, as reflected by the value increases seen both during this and the last quarter of 2006. The Citation Jet and CJ2 models still continue to be a strong market, but I wonder how soon the value increase of these models will be arrested as more CJ3 aircraft are delivered?

Surprisingly, what many might consider a member of the dinosaur category of aircraft, the Westwind 1124/I/II series have seen a good increase in its value over the last Quarterly Report. This has got to have a lot to do with its range/speed/fuel consumption profile, which is pretty impressive, even by today's standards.

And again, the values of the Falcon 900 continue a steady march upward. Its cabin size and runway performance, I believe, has a lot to do with this.

Watch for a new Quarterly Market Report in February.

Any input that you care to make will be of great interest to all of the readers here at Globalair.com. So please don't be bashful and go ahead and write your comments and suggestions here. Please don't forget that whatever you write here, can be seen publicly by everyone that visits this page, so please be funny, be inspired, but most importantly of all, please be nice. See you next month.

The Data

Historical Data

Label Data
OPEC Basket Price $53.89
One Year Ago $53.13
Dow Jones IA 12,134
One Year Ago 10,303
LIBOR % Rate (USD) 5.28875
One Year Ago 3.32875
FBO / Fuel Prices by Region (Full Service JETA)
Central Region $3.78
Eastern Region $4.28
Great Lakes Region $3.91
New England Region $4.00
Northwest Mountain Region $3.97
Southern Region $4.11
Southwest Region $3.88
Western Pacific Region $4.03
Alaska Region $4.52

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Jeremy Cox



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