• Published
  • By Brigadier General Michael Tomatz and Chief Master Sergeant Renee P.M. Cenov

Operations and International Law (JAO) Directorate Message



“What is JAO?” If you’d asked me this in 2012 when I was first assigned to the Operations and International Law Directorate (JAO), I would have described it as something akin to a small, boutique legal practice within the Headquarters Air Force; one focused on international law issues, operations law topics, and doctrine. When answering the same question today, my answer basically starts the same—we are a group of legal professionals dedicated to delivering timely, accurate, and responsive legal advice—but today the breadth, scope, and scale of what JAO does is very different. Now, JAO is something more akin to a medium or even large legal practice, with a variety of boutique practice areas focused on enabling air and space operations across the world. JAO offers our JAG Corps and our Air and Space forces legal expertise in every aspect of air and space law, operations and international law, cyber and information operations law, aviation law, including the responsibility for investigating air and ground mishaps, as well as ensuring operational capability through the addition of the environmental law and litigation division.

JAO offers our JAG Corps and our Air and Space forces legal expertise in every aspect of air and space law, operations and international law, cyber and information operations law and aviation law.


One of the biggest changes to JAO since our JAG Corps’ 50th Anniversary is the restructuring on 1 June 2020, through which JAO was incorporated into the AF/JA Field Operating Agency as one of three major directorates. These directorates enable the Judge Advocate General’s Corps to deliver national security law advice worldwide. JAO is now comprised of five distinct divisions: Aviation and Admiralty Torts (JAOA), Cyberspace and Information Law (JAOC), Environmental Law and Litigation (JAOE), Air and International Law (JAOI), and Space Law (JAOS). These divisions reflect the greatly expanded portfolio of JAO today and underscore the criticality of each of these practice areas to air and space operations. This new alignment also resulted in the addition of a second JAO office in the National Capital Region; the directorate now maintains offices at both the Pentagon Reservation and Joint Base Andrews, Maryland. Additionally, we have personnel embedded in multiple geographically separated offices, including a large presence at the Environmental Law Field Support Center in San Antonio, Texas, the Utility Law Field Support Center located at Tyndall Air Force Base (AFB), Florida, the East and West Regional Counsel Offices located at Dobbins Air Reserve Base, Georgia, and Travis AFB, California, respectively, and the Environmental Liaison Officers embedded inside many of the major command legal offices located throughout the United States.

Operations and International Law Directorate

With these divisions joined, the Operations and International Law Directorate advises the Secretary of the Air Force, Chief of Staff of the Air Force, Chief of Space Operations, and other senior leaders on issues spanning the full spectrum of Air Force and Space Force domestic and international operations and initiatives. JAO provides advice, policy counsel, and training to all echelons of command within the Department of the Air Force (DAF) to support the needs of both field units and headquarters staff. JAO represents the DAF in environmental and land use matters, including litigation, regulatory actions, utility matters, and legislative proposals. JAO oversees the DAF ground and aerospace accident investigation program and supports federal litigation defense of associated tort claims.

JAO develops and publishes department-level policy directives addressing international law and compliance with the law of war. JAO publishes and maintains several Department of the Air Force Instructions implementing headquarters-level guidance and participates in the development of two joint instructions that address weapons reviews, international agreements, foreign criminal jurisdiction, foreign tax relief, legal readiness, political asylum and temporary refuge requests, and assistance to friendly foreign forces and forces of sending states. JAO is a member of the Department of Defense (DoD) Law of War Working Group, responsible for producing and updating the DoD Law of War Manual and coordinating on whole-of-government working papers on a range of operational and international law topics. JAO members have participated in Air Force, Space Force, and joint policy development regarding the use of artificial intelligence, autonomous and semi-autonomous weapons, unmanned aerial system (UAS) activities, and DAF operations in space and the information environment. The directorate supports the Air Force’s LeMay Doctrine Center and reviews other doctrine across the other Services prior to publication. Additionally, on behalf of The Judge Advocate General (TJAG), JAO oversees JAG Corps support of the Air Force Crisis Action Team and implementation of the continuity of government operations program, reviews multiple joint actions from across DoD and other federal agencies, and serves as TJAG’s designated reviewer for Air Force, joint, and combined publications. JAO routinely drafts comments, positions, and memoranda for senior leaders responding to taskings from the Joint Staff and the Office of the Secretary of Defense (OSD).

Contingency Operations and Global Responses

During the past twenty-five years, JAO has actively advised during contingency operations and global responses to include, more recently, the Russian-Ukraine crisis, the COVID-19 pandemic, and the evacuation of more than 100,000 civilians from Afghanistan. Looking back further in time, JAO was heavily involved in the nation’s response to 9/11, and provided doctrinal and law of war advice and guidance for Operations NOBLE EAGLE and ENDURING FREEDOM, Operation IRAQI FREEDOM, and Operation INHERENT RESOLVE. JAO also provided continued support for Operations NORTHERN and SOUTHERN WATCH along with a range of humanitarian and disaster response operations. During Operations NOBLE EAGLE and ENDURING FREEDOM, JAO enabled legal professionals to provide unprecedented levels of support in areas such as target planning, counterterrorism, and homeland defense.

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The 5 Divisions

Environmental Law and Litigation–JAOE

If you really want to understand what JAO is today, you need to understand that, by far, our largest practice area is environmental law. Indeed, there are more attorneys working just in our JAOE litigation center than we had attorneys in all of JAO for decades. The move of JAOE to JAO in June 2020 brought with it an acknowledgement of the importance of environmental law compliance as it relates to military readiness and our ability to get the mission done effectively. Aligning our environmental law practice with JAO serves as an acknowledgement that a proactive approach to achieving environmental compliance helps to maximize operational freedom for our warfighters.

JAO and JAOE have worked a broad range of strategic basing actions for the F-35, B-21, KC-46, and the Ground-Based Strategic Deterrent/Sentinel ICBM replacement program. On a related note, whenever the DAF stands up a new weapon system like the F-35, T-7A, or Sentinel, we must comply with the National Environmental Policy Act (NEPA) to determine the effect the federal action will have on the environment. If we fail to conduct the environmental analysis properly, it can lead to litigation, force us to repeat the process, and potentially delay critical national missions. And speaking of adverse consequences to the mission, if we fail to comply with environmental laws and regulations, the fines come directly out of Operations & Maintenance (O&M) funds. That is why JAOE’s Regional Counsel work so hard to negotiate down fines to preserve as much O&M as possible when violations do occur.

The JAOE team works tirelessly to balance the environment with the mission. Here are a couple of examples. When it became apparent that wind turbines create issues for radar and present a physical hazard for helicopters, JAOE partnered with Air Force Global Strike Command on a legislative proposal that limits turbine heights near missile sites. Our Utility Law team worked with multiple utility concerns across the country to maximize energy efficiency and negotiated with utilities on behalf of the federal government to ensure our installations are fairly charged for their energy use. The Utility Law team is currently working to bring carbon pollution-free electricity to DoD installations in South Carolina, Arkansas, and Colorado, by developing the legal mechanisms to usher in cleaner and more resilient energy resources to the national grid. These efforts will bring clean power generation onto DAF installations that will reduce dependency on aging grid systems and harden our utility infrastructure against outside threats.

Aviation & Admiralty Torts–JAOA

JAOA is, simply put, critical to the viability of air operations, because without credible investigations and public accountability, we find ourselves with grounded aircraft or wondering about safety of flight. In Fiscal Year 2022 alone, JAOA adjudicated and defended over 420 aviation tort claims and litigation which involved over $2 billion at risk. Additionally, JAOA led OSD’s effort on the congressionally mandated Air Investigation Review Board (AIRB) proposal and was selected to chair OSD’s AIRB Task Force for the entire Department. From an operator’s standpoint, JAOA maintains access to airpower itself.

Air and International Law–JAOI

Our JAOI Division also partnered with the DAF-MIT Artificial Intelligence Accelerator team to develop an AI-enabled, searchable database for over 200 weapons legal reviews, accelerating legal advice and ensuring compliance with international and domestic law.

Cyberspace and Information Law–JAOC

Our JAOC Division continues to support the DAF across the board, to include advising on the development of the newest member of the Intelligence Community, the United States Space Force Intelligence Element. JAOC continues to engage across the spectrum of cyberspace and information law issues, including advising on and developing policy for cyberspace operations, special access programs, intelligence and counterintelligence, electromagnetic warfare, autonomous weapons, and the responsible use of artificial intelligence.

Space Law–JAOS

Our JAOS Division, as you might imagine, has been incredibly active since 2019 when the United States Space Force (USSF) became a separate and distinct branch of the Armed Forces. JAOS has supported planning efforts for the permanent basing of USSF organizations, including Space Training and Readiness Command and five Deltas. JAOS assisted with drafting a Space Component legislative proposal to combine the regular and reserve components into a single component. JAOS also delivered unrivaled support on multiple major organizational changes, including the stand-up of the Space Warfighting Analysis Center and Delta 18 (National Space Intelligence Center). Moreover, JAOS actively engaged with global space law experts to develop space law manuals to increase understanding on the application of international law to military activities in the space domain.

JAO and its five divisions play a key role in the very broad and critically important enterprise of delivering air and space power for the American people.



JAO and its five divisions play a key role in the very broad and critically important enterprise of delivering air and space power for the American people. Put simply, the legal professionals of the Operations and International Law Directorate provide legal capabilities to expand command decision options and enable projection and employment of ready air, space, and cyber forces to defend the nation and our allies. They preserve and maintain access to installations and training ranges, review regulations, policies, and doctrine, including in rapidly evolving areas like cyber and space, and maintain flexibility for our warfighters through persistent engagement on international and operational law matters. The entire Directorate engages across the JAG Corps, the Services, and the DoD to ensure our operations and efforts comply with U.S. law and policy and our obligations under international law. JAO is privileged to support our legal personnel assigned and deployed across the globe, and our team works proactively and swiftly to prevent legal issues from impairing the ability of Airmen and Guardians to organize, train, equip, and most importantly, to operate and, where necessary, fight effectively.

About the Author

 Brigadier General Michael Tomatz

Brigadier General Michael Tomatz, USAF

(B.A., University of Houston, Houston, Texas; J.D., University of Texas, Austin, Texas) is the Director of Operations and International Law Directorate, Office of The Judge Advocate General, Washington, D.C.
Chief Master Sergeant Renee P.M. Cenov

Chief Master Sergeant Renee P.M. Cenov, USAF (Ret.)

(A.A.S., Criminal Justice, Community College of the Air Force, Maxwell Air Force Base Gunter Annex, Alabama; A.A.S., Paralegal Studies, Community College of the Air Force, Maxwell Air Force Base Gunter Annex, Alabama; A.A.S., Instructor of Technology and Military Science, Community College of the Air Force, Maxwell Air Force Base Gunter Annex, Alabama; B.S., American Military University, Charles Town, West Virginia) is the Senior Enlisted Leader, Operations and International Law Directorate, Office of The Judge Advocate General, Washington, D.C.
Edited by: Major Allison K.W. Johnson (Editor-in-Chief), Major Victoria H. Clarke, Major Brianne L. Seymour and Major Andrew H. Woodbury
Layout by: Thomasa Huffstutler