GPSolo Magazine - July/August 2006

Lobbying for the Aviation Security Act After Lockerbie

On December 21, 1988, Pan Am Flight 103 exploded over Lockerbie, Scotland. Among the victims was my son, Christopher Andrew Jones, age 20. This event dramatically changed my life both professionally and personally. At the time, I was a real estate broker with a background in teaching, not a promising future for the lobbying and administrative rulemaking testimony I was to engage in during the next several years.

The families of the victims soon became painfully aware of the gaps and oversights in our aviation security system. Although the families railed for a congressional hearing examining everything that went wrong to permit this act of terrorism, we got, instead, a blue ribbon presidential commission. Surprisingly, the President’s Commission on Aviation Security and Terrorism delivered a stinging report that led to the Aviation Security Act of 1990. The families, myself included, were intimately involved with the commission and the lobbying process that followed the commission report. No one person among the families did all the work; we all participated to the extent possible. The family members became skilled lobbyists for the passage of the bill.

Once it became law, a new realization dawned: Few of the changes called for in the law would occur until administrative rulemaking changed the way different agencies performed their functions. Administrative law—something I’d never heard of—dominated my life for several years, although I didn’t have a name to put to what I was doing. Family members each engaged in different aspects of the requirements of the new law. Mine was the compilation, accuracy, and rapid provision of passenger manifests. I wrote testimony for administrative rulemaking procedures. I visited the offices of various elected officials to garner their support. I researched international laws regarding privacy. I met with representatives of the International Air Transport Association, the international agency that informs air travel. All this before I went to law school in 1993.

One of the classes I took at Albany Law School was administrative law. We studied agencies and rulemaking, and I realized, much to my surprise, that I had been engaged in the practice of administrative law as a lobbyist for the past three years! I had been so busy plowing through the intricacies of our endeavors that I had never stopped to look at the process as a whole. This moment hit me during class and my professor asked what the problem was. I blurted out that I had been doing all these things for the past three years without realizing—until that moment—that this “stuff” I had been doing was, in fact, administrative law. I’m still not sure if he was amused or appalled.

Ultimately, I worked for a state agency: the New York State Department of Taxation and Finance. And, yes, I engaged in administrative rulemaking. And I understood the frustration of the public that does not understand the relationship between law and agency rules that apply the law.


Georgia F. Nucci is a retired lawyer living in Jocotepec, Mexico. She can be reached at


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