Overview

Jason is an associate in the firm's Transportation group. He advises multinational corporations, trade associations, and transportation intermediaries on domestic and international matters involving logistics services and transportation. These matters include: regulatory compliance; regulatory enforcement; agency rulemaking; legislative concerns; service issues; loss and damage claims; transportation security; contract drafting and negotiation; and rate disputes before the Surface Transportation Board (STB).

Jason's practice is multimodal, involving air, motor, ocean and rail transportation, and encompasses a wide variety of logistics services, such as warehousing and terminal services. In addition, his practice involves the regulation of transportation and transportation-related activity by the Bureau of Alcohol, Tobacco, Firearms, and Explosives, Census Bureau, Customs and Border Protection, U.S. Department of Transportation (DOT), Federal Aviation Administration, Federal Maritime Commission, Federal Motor Carrier Safety Administration, Federal Railroad Administration, National Highway Traffic Safety Administration, Pipeline and Hazardous Materials Safety Administration, and STB.

Prior to joining Thompson Hine, Jason was a law clerk in the general counsel's office of a global maritime freight carrier and at an enforcement office of the DOT. Jason also was an airline pilot and holds aircraft dispatcher, commercial pilot, and certified flight instructor certificates.

Experience
Aviation
  • Provided guidance on commercial use of Unmanned Aircraft Systems (UAS), including:
    • Satisfying aircraft certification requirements via an experimental airworthiness certificate or Section 333 exemption
    • Entering public/private partnerships
    • Obtaining operating authority via Certificates of Authorization or Waiver
    • Applying for a Section 333 exemption
    • Identifying regulations applicable to manned flight and for which a waiver is necessary
  • Counseled US air carrier on impact of preferential access on application for passenger facility charge
  • Coordinated a face-to-face meeting between a client and the FAA UAS integration office to discuss paths to commercial operations
  • Advised parts manufacturer on part-marking and authority requirements
  • Advised repair station on scope of repair authority, including use of subcontractors to fabricate parts
  • Develop strategy for challenging foreign air carrier schedules under 14 CFR Part 213
  • Provide guidance on airman licenses required to pilot aircraft in the course of non-aviation-related employment, receive reimbursement for aircraft operation, and carry multiple employees on business travel.
Hazardous Materials

Jason’s experience with HAZMAT regulation includes providing advice on:

  • PHMSA enforcement matters
  • Compliance with the Hazardous Materials Regulations, IMDG Code, and ICAO Technical Instructions as they apply to international and domestic air, truck, rail, and ocean vessel shipments
  • Applications for PHSMA approval of hazardous material
  • Special Permit approvals and compliance
  • Compliance reviews for offerors and transloaders of crude oil and natural gas
  • Hazardous Materials Regulations requirements for packaging manufacturers and distributors
  • Registration requirements for HAZMAT offerors
  • Criminal liability for violations of the Hazardous Materials Regulations
  • Compliance with foreign and international standards in lieu of the Hazardous Materials Regulations
  • Shipment of limited and excepted quantities
  • Training requirements
  • Packaging requirements, including for truck and rail shipments of Bakken crude oil
 Ocean Transportation
  • Drafted and counseled clients on ocean transportation contracts, including service contracts for containerized shipments, NVOCC negotiated rate arrangements, NVOCC service arrangements, voyage charters, project cargo agreements, and tow agreements
  • Counseled ocean transportation intermediaries on compliance with Federal Maritime Commission regulations
Rail Transportation
  • Represent plastic and chemical manufacturers in the some of the largest and most complex rate cases before the Surface Transportation Board
  • Counseled clients on railcar leases
  • Advised on preemption of local zoning and siting permit requirements as they pertain to rail facilities
  • Drafted and reviewed rail transportation contracts for shippers
Truck Transportation
  • Drafted less-than-truckload (LTL) and truckload agreements for shippers
  • Drafted broker agreements for shippers and brokers
  • Counseled shippers in negotiating truck transportation agreements with motor carriers and brokers
  • Advised 3PLs on compliance obligations under MAP-21 and the Federal Motor Carrier Safety Regulations, including operating authority and financial responsibility requirements
  • Advised shippers on the FMCSA’s Compliance, Safety, Accountability (CSA) program
  • Provided guidance to shippers on selecting motor carriers with reference to their CSA Behavioral Analysis and Safety Improvement Category (BASIC) performance
  • Analyzed cargo loss and damage claims
  • Counseled businesses on rules pertaining to their commercial motor vehicle (CMV) operations, including driver licensing requirements, drug and alcohol testing, recordkeeping requirements
  • Drafted comments to the FMCSA on driver hours of service rules
Publications
News