as an unauthorized indirect air carrier in violation of the Federal Aviation Act with respect to business transacted via its GSA schedule listing, and that the violations of the Federal Aviation Act constituted unfair and deceptive practices and unfair methods of competition in violation of 49 U.S.C. § 41712, issuing a cease-and-desist letter to CSI ordering CSI to terminate its business contractual relationships with various federal agencies. The United States Court of Appeals for the District of Columbia Circuit subsequently issued an opinion in CSI Aviation Services, Inc. v. U.S. Department of Transportation April 1, 2011 which found that the DOT had overstepped its legal authority when attempting to block the federal contracts of CSI Aviation Services, stating in their opinion that “given DOT’s complete failure to explain its reading of the statute, we find it impossible to conclude that the agency’s cease-and-desist order was anything other than arbitrary and capricious, and hence unlawful.” The CSI case was seen as significant on a number of levels. First, the case is the first successful challenge of the scope of DOT’s consumer protection regulatory authority and it established the first precedent limiting DOT’s broad interpretation of what constitutes "common carrier" in the context of the definition of "air transportation". Second, the case involved an inter-agency dispute involving the General Services Administration, which strongly disagreed with DOT’s position on having the authority to regulate CSI’s ability to enter into government contracts with various federal agencies. Finally, the case is significant because the court held that the DOT does not possess the authority to interfere with business relationships between the federal government and air charter brokers unless and until the DOT provides a reasonable explanation for its actions. The immediate impact of the legal decision is that CSI, along with other air charter brokers, will be able to continue to enter into contracts to arrange air transportation as a principal without the fear of a potential DOT enforcement action. In regards to this decision, ACANA’s policy of implementing transparent best practices and “self-policing” within the air charter industry are attempts to diminish the need for and/or the desire of the DOT to provide this regulatory oversight of the air charter industry. The intent is that the DOT will rely more heavily on industry trade groups such as ACANA and individual air charter broker members to maintain their own high business standards, providing education to