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jKhTREYM.IlARPER 

F/\A OFFICE OF REGIONAL COUKSF.L 

1601 LiND AVFKL'E SOUTin\'ESr 

RENTON, WASHINGTON 98057 

I'ELEPHOHE; (425)227-2161 

FACSIMIl.n: (425) 227-1007 

V -' ,-^H 'fT 

•^r.— i.._ • 

OCi" ^ 3 20 

UNITED STATES OF AMERICA 

DEPARl MENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

Comersione Aviation, Inc. 

<r>p - - ' J 

FAA Case No. 201 llNn^'f070021 

DMSNo. FAA-20U-0484 

Motion for Decision 

Judge Richard C. Goodwin 

f^3 -:^z 

I-O 

> goo 

CO 

To the Honorable Richard C. Goodwin; 

MO f TON FOR DECISION OR, IN THE ALTERNATIV T 

MOTION FOR SUMMARY .TUDGMENT 

HEREAFTER LIMITING HEAR1^'G TO SANCTION 

In accordance ^sith 14 C.F.R. § 13.218(f)(5) (Rule 13.218(f)(5)), the Administrator brings this 

Motion for Decision There are no genuine issues of material fact, as Respondent has admitted all 

relevant facts cither in its .Answer or in its rcspon.ses to Requests for Admissions, The 

Administrator is entitled to a decision as a matter of law. 

Facts 

The Complaint in this case was ser\'ed on May 26, 2011. The Complaint alleges Cornerstone 

Avialion, Inc. (Respondent) violated 14 C.F.R. §§ 141.77(a)(1), 141.77(h), 141.83(a)(1), and 

141.101(a).' These violations relate to Respondent's failure to maintain accurate iraiiiiDg records 

for an instrument student, Ms. Haley V/il.-^on. Respondent filed its Answer on June 12, 2011." 

The Answer admitred all the factual allegations in the Complaint, with the exception of 

paragraph 5. 

' CompJainr. 

" Answer. 

" Answer. 

Compliunani's NToiion Foi Decision 

Ciimcrsioftc Aviuiion, Inc. - l'AA-20J l-048d 

Page 1 of 8 

JEFFRiv M. HARPER, ?.\.\ ATTOPJ^v 

TEl.: (4251 227-2161: FAX: (425l 227-1007 
10/24/2011 16.04 FAX 202a935U2 FAA - OMS 0002/012 

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Paragraph 5 of the Complaint, alleged That Ms. Wilson was enrolled in the Instrument - Airplane 

rating course of training on June 10, 2010, and that she did not receive credit for any prior 

instrument airplane rating ground training. 

Howe\cr, Respondent's discovery response admitted every underlying fact of the Complaint's 

paragraph 5. Respondent admitted Ms. Wilson was enrolled in the Instrument course of training." 

Respondent adinitied Ms. Wilson's training record shows "0" hours of credit for previous ground 

training,^ Respondent admitted Ms. Wilson did not jtictivQ any credit for previous training, and 

even acknowledges that Ms. Wilson only would have been allowed partiai credit for any previous 

training received.^ Respondent admitted Ms. Wilson actually received ground training from 

another institution, which was not a Part 141 school. 

In brief, Respondent has admitted cver>' factual allegation of the Complaint. 

Argument 

Standard for Decision 

''The administrative law judge shall grantapart>*'s motion for decision if the pleadings, 

depositions, aniiwcrs to interrogatories, admissions, matters that the administrative law judge has 

officially noticed ... show that there is no genuine issue of material fact and that the party making 

the motion is entitled to a decision as a matter of law. The part>' making the motion ... has the 

burden of showing that there is no genuine issue of material fact disputed by the parties." 

14 C.F.R § 13.218(0(5). 

Merits 

a. Graduation & Graduation Cenificate^ 14 C.F.R. §§ 141.77(a)(1) and 141.77(b) 

The Administrator alleges Cornerstone issued a graduation certificate lo a snident who bad not 

completed the training specified in its course of training. Respondent is authorized to provide 

trainmg for the Instrument rating using the Jcppesen Sanderson, Inc. Instrument / Commercial 

Course Syllabus (Syllabus). Complaint 11.3, Answer 3. The Syllabus, in tiun, requires that 

students complete 30.0 hours of ground training. 

Ms. Wilson was enrolled in Respondent's Instrument - Airplane course of training. Admission to 

Request for Admission 3. Respondent's records indicate Ms. Wilson did not receive any of the 

' Request for Admission No. 3. 

^ Request for Admission No. 4. 

'' P.equcst for A<lini«.sion No. 5. 

^ Requests for AdmisFioa Nos. 6 and 7. 

Complainani's Morion For Decision 

Cornerstone .Aviaiion. Inc. - F.^A-20l I-04t;4 

2011NMO7O021 

Pace 2 of K 

JEFFREY M. HARPER. F.-^A ATTOR>reY 

TEh:(425)127.Z\6l;FAX:{-t25]227-K'07 
10/24/2011 1B:04 FAX 2024935liJ2 FAA ^ DMS 0)003/012 

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ground training required by the syllabus. Complaint T17, Answer 7. Additionally, Ms. Wilson did 

not receive any credit for previously received ground gaining, as permitted by 14 C.F.R. 

§ 141.77(c)(4). Admission to Request for Admission No. 4, Admission to Request for Admission 

No. 5. The lack of Part 141 groimd training is corroborated by Ms. Wilson's logbook, which does 

not show Lhe completion of any required ground training. Complaint 11.6, Answer 6. 

Ms. Wilson did receive ground training under Part 61 from Utah Valley Unii'ersiry. AdtTiission to 

Request for Admission No. 6. However, Utah Valley University is a Pan 141 school. Admission 

to Request for Admission No. 7. As a result, at most 25% of the required 30 hours of training 

under the Syllabus could have been credited to Ms. Wilson for her training at Utah Valley 

University. 14 C.F.R § 141.77(c)(4). 

Respondent graduated Ms. Wilson from respondent's Instrument-Airplane course, issuing her a 

graduation certificate on November 17, 2010. Complaint II.8, Ans^^-er 8. A graduation certificate 

constitutes certification that a student has completed the required training. 14C.F.R. § 141.95. 

Unquestionably, Respondent issued a graduation certificate to an individual who had not 

completed the training specified for Respondent's students. Specifically. Ms. Wilson did not 

complete the ground training required for the Instrument- Airplane rating. Sections 141.77(a)(1) 

and 141.77(b) prohibit a holder of a pilot certificate from issuing a graduation certificate to a 

student unless the student has completed the training/curriculum specified in the pilot school's 

course of training. Respondent has done precisely the thing the regulation prohibits — graduated 

a student who had not received all required training. There is no genuine issue regarding these 

facts; the Adminisirator is entitled to a decision as a manei of law, 

b, Compliance v.-ith Approved Training Course — 14 C.F.R. § J41.83(a)(]) 

The Administraior alleges Cornerstone did not comply uith its approved training course. As 

discussed in subparagraph (a), Respondent was required to provide Ms. Wilson ^Aith 30 hours of 

ground training to complete lhe Instrument - Airplajie course under the approved Syllabus. 

Respondent failed to provide Ms. Wilson the required training, thereby deviating from its 

approved training course. 

c. Maintenance of Current and Accurate Records — 14C.F.R. § 141.101(a). 

Section 141.101(a) requires the holder of apilot school certificate to establi.sh and maintain a 

current and accurate record of the participation of each .student enrolled in an approved course of 

training that includes, at a minimum, the date the student enrolled, a chronological log of the 

student's course anendance. and the date the student either graduated, terminated training, or 

transferred. 

CymplainanL's Motion For Dccif^ion 

CyfTiSfsronc .Aviacjon, Jnc. - FAA-201 J-0J84 

20UNM070021 

Page 3 Of S 

JEFFRliYM.HAKl'EP^FAAAtTOR^Jei' 

TEL: (425) 227-216! :rA,X:C425> 227-1007 
10/24/2011 1B:04 FAX 2024935142 FAA - OMS 121004/012 

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The Certificate of Graduation for Ms. Wilson is inaccurate in thai it states she completed all the 

course requirements. As disctisscd above, she had not — her records show no ground training 

received. The record of ground training is itself inaccurate. Ms. Wilson received ground training 

from Utah Valley Universit)'. Admission to Request for AdmissionNo. 6. Her record shows "0" 

hours credit for that training. Admission to Request for Admission No. 4. As Respondent admits 

to inaccuracies in Ms. Wilson's Part 141 records, there is no genuine issue of the material facts 

related to whether Respondent maintained accurate records as required by 14 C.F.R. 

§ 141.101(a). 

d. Merits — Conclusion 

In conclusion, there are no genuine i.ssues of material fact in this case — all material facts have 

been admitted by Respondent in either the Answer or as a result of Requests for Admission 

propounded in discovery. The facts establish the alleged violations occurred. The Adminisirator 

is entitled to a decision as a matter of law by 14.C.F.R § 13.218(f)(5). 

Sanction 

a. Standard 

Under 49 U.S.C. § 46301 (a)(5)(A), a "small business concern i.s liable to tlie Government for a 

civil penalty of not more than $10^000..." The majcimum penalty was adjusted to $11,000 on 

June 15, 2006. 14 C.F.R. § 13.305 (Tablc).^ 

[n determining an appropriate civil penalt)', the Agency considers seven factors. In the Matter of 

Warbtlo^v 'a Air Ventures, inc., FAA Order No. 2000-3 at 16-17 n, 22 and 21 (February 3, 2000). 

The Agency has the burden of justifying the amount of civil penalty sought. 14C.F.R. 

§ 13.224(a)i In the Matter of Luxemburg, FAA Order 1994-18 (June 22, 1994) at 4. To guide the 

FA.^' S prosecutorial discretion, the Agency has promulgated penalty guidelines, which are found 

in FAA Order 2150.3B Chapter 7 and Appendix B dated October 1, 2007 (Sanction Guidance). 

The Sanction Guidance contains tables that establish specific penalty ranges for different types of 

violations.'^ The starting point for a sanction determination is the middle of the sanction range! 

Sanction Guidance. Appcndi.x B, Paragraph 2.c. The FA^\' S sanction deierminarion does not, 

however, reflect a fixed mathematical computation: in addition to the published penalty ranges, it 

takes into account thirteen factors set forth in Chapter 1, paragraph 4 of the sanction guidance. 

'28 U.S.C. §2461 (Noic). 

' Sanaion Guidance, Appendix B. 

Cfimplainanl's Motinn Kor Dccisicin 

Cornerstone .-Vviation, Inc. - ?i\A-ZOt I -0484 

2nnNM07OQ2] 

Pace 4 of 8 

JEFFREY M. HARPER, FA-A ATTOT>JEV 

TEL: C425) 227-2161: FAX: (425) 227-1007 
10/24/2011 1G:04 FAX 2024935142 FAA ^ D(.1S 0005/012 

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which address the issues set forth in iVarhehw.^^ I'hese factors are used to adjust the sanction 

upward or downward from the middle of the recommended range. 

The FAA Order reflects the Administrator's general views about appropriate civil penalties; civil 

penalties must reflect the totality of the circumstances surroimding the violations. Folsom'.? Air 

Service. /«c., FAA Order No. 2008-11 (November 6, 2008). The weight to be given to each of 

these factors is within the discretion of the Complainant; "the Complainant maintains relative 

prosecutorial discretion in determining the case's final aggregate weight in proposing the level of 

civil penalty." y/J the Matter of William A. Luker. Jr., FAA Docket No. CP09SW0008, 2010 WL 

1989430 (May 13,2010) (Order of Chief Judge Yoder Granting Complainant^s Motion for 

Summary' Judgment). Although a Department of Transportation Administrative Law Judge is not 

statutorily bound to follow the Administrator's guidance, "[aln administrative agency is entitled 

to substantial deference in assessing the civil penalty appropriate for a violation of its regulations. 

The agency's choice of a sanction is not lo be overturned unless it is unwarranted in law or 

without justification in fact." NL Industries, Inc. v. Dept. of Transportation, 901 F.2d 141, 144 

(D.C. Cir. 1990). 

Further, the Administrator has the ability lo impose the Agency's sanction pohcy on appeal if the 

assessed civil penalty is not consistent with the policy. In the matter ofWarheh\v 'sAir Ventures, 

Ific, YAA Order No. 2000-3 (February 3, 2000) at 20; Ifj the maner of Northwest Airlines, ?Pu\ 

Order No. 1990-37 (November 1, 1990) at 8-9. 

b. Multiplicity 

Complainant has charged respondent with violating 14 C.F.R. ^§ 141.77(a)(1), 141.77(b), 

141.83(a)(1), and )41.101(a). Complainant concedes, hou'ever, that sections 141.77(a)(1) and 

141.77(b) require proof of the same facts and therefore should be considered as one violation 

under the Bhckhurger test. Ball v. U.S., 470 U.S. 856, 861 ^1985); Blockhurger v. U.S., 2S4 U.S. 

^^' Tho^e. factors are: 

a. Nature of the violaiion; 

b. Whether the violation was inadvcnenr and not deliberate; 

c. Jhe certificate hoidtr's level of experience; 

d. The attitude of the violator; 

e. The degree of hazard: 

f UTiether there was action taken by the employer or other authority against the employee that commifld the 

violation(5); 

g. llsi: of the certificaie; 

h. Viniaiion history; 

i- Decisional hw; 

j. Ability to absorb the .sanction; 

k. Consistency of Sanction; 

1. Whether the violation was reponed voluntarily; and 

m. Con-eciive Action. 

Ct'mpl3in»ni',<:Mo:iynFc.r Oecisjon 

Cornerstone Aviation, Inc. - FA.'\-20 I l-O-IS-* 

2011IJM07n(121 

PiireScfft 

JEFFP.?-:> M. HAJU-ER. FAA ATTORISEY 

TEL: (425) 227-:i61i FAX: (425) 227-1007 
10/2a/20n 1G04 FAX 2024935142 FAA - DMS I300B/012 

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299, 304 (1932); In the Matter of James WahK 2008 WL 926620 at 9 (March 31, 2008); In (he 

Mailer of Folsom's Air Service, Inc , 2006 WL 1316970 at 11 (May 3, 2006) (stating that one 

violation that incorporates the others may not be considered as a separate violation for 

determining the amount of the sanction). The Adniinistrator thus considers this case as having 

three violations, each of which is subject to the maximum SI LOCO civil penalty. The 

Administrator seeks a total penalty of $5,000. 

c. Sanction Guidance 

As discussed, the Sanction Guidance establishes penalty ranges for different types of violations. 

Figure B-3-d lists penalty ranges. The listed penalty ranges are; 

Citation Penalty Range 

B-3-d(5)(b) Improper graduation of student 

(inadvertent) 

(14 C.F.R. §§ I4l.77(a)(l)& 141.77(b)) 

B-3-d(8) Failure to maintain training record 

(14 C.F.R. § 141.101(1)) 

B-3-d(7) Unauthorized instruction 

(14 C.F.R. § 141.83(a)ri)) 

Moderate to Maximum 

Moderate lo Maximum 

Moderate to Maximum 

For a small business concern holding an Air Agency certificate, a moderate penalty is in the 

range of S3,950 - 57,149; a maximum penalt>' is in the range of $7,150 - SI 1,000. Sanction 

Guidance, Appendix B, Paragraph 3.c(4). The starting point of a sanction calculation is the 

midpoint of these ranges, $7,425. At the low end of the range, an appropriate sanction would be 3 

^ J3,950 = Sl 1,850. The Administrator seeks a total of $5,000^ less than half of the lowend of 

the sanction guidance range, reflecting the application of a number of inirigaiing factors. 

Any deviation from the Sanction Guidelines has been lo Respondent's benefit. The 

Administrative Law Judge should defer to the Administrator's selection of sanction under A7. 

Indiisiries, Inc., 901 F.2d at 144, and enter an Order assessing the full $5,000 penalty sought in 

the complaint. 

Conclusion 

For lhe reasons stated above, the FAA respectfully requests that this Court grant this Motion for 

Decision. There are no genuine issues of material fact; the sanction sought is appropriate under 

the facts. In the alternative, if further litigation is warranted, the pleadings establish that any 

Comptainiuit's Moiinn For Decision 

Cornerstone Aviation, Inc. - FAA-2011-0484 

2O))i-}M07002l 

Pare 6 of S 

.iHhFREYM. HARPFR, KAAATTOKNTV 

TEL: (•125) 227-216!; F.AX: (425) 227-1007 
10/24/2011 IB.05 FAX 2024935142 FAA - OMS 1^007/012 

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hearing in this case be limited to the sanction, as all the substantive facts of this case have been 

established. 

DATED this 13Th day of October, 2011. 

Jefjfey M. Harper 

F^VAAtiomev 

Enclosures; (1) Respondent's Discovery Response 

Complainanis M-^tion For [decision 

Comcr.iionc Aviaiion, Inc. FAA-2011-04S4 

:0]iNM070021 

PttL-c 7 of 8 

jKhTUfvM. HA.VER, FAAAirOR-STV 

TEL-.(d25i 227-2161; F-AV; (425) 227-1007 
10/24/2011 1G:05 FAX 2024935112 FAA - OMS 0008/012 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoingMotion for Decision has been served via facsimile and 

Certified Mail - Return Receipt Requested this date, lo the following: 

Honorable Richard C, Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor. Rm El 2-320 

Washington, D.C. 20590 

FAX: 202.366.7536 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

F.A-X: 202.493.5020 

Susan Horsiman 

Chief Executive Officer 

Cornerstone Aviation, Inc. 

337 North 2370 West #130 

Salt Lake Cit>; UT 84116 

F,OC: (801) 355-2754 

Dated this 13^, day of October, 2011. 

MOIFAIR CHTN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Kenton, WA 9S057 

425.227.2160 

Complainam'i Moiion Tor Dctibion 

Cornerstone Aviation, fnc. - F.\A-2011-0'154 

201IN'M0700;i 

Pflgc J*ofS 

JiLITPiY M. 11.^PJ'ER, FA.'Si ATIORMEV 

TEL: (425) 227-21hl; FAX: (425) 227-1007 
10/24/2011 16:05 FAX 2024935U2 FAA 

^'^'^ - 0^15 12)009/012 

FAA Correspondence Complainanr's Initial Discovery Request CornaKtone Aviation 

IhrreRROGATORlES ^f P J j -,-

Since complaioK are consoh'dated into one letter, the responses have also been consotidat^!lSf3S 

refer to initial letter to CSA for details of item numbers. 

1. Names, Addresses and Telephone Numbers (see attachment) 

2. AM correspondence from FAA is in the possession of Susan Horstman, including al) copies of 

documents sent to her by Jeffrey Harper, 

3. Names, Addresses and Telephone Numbers of persons whom CSA intends to have testify as a 

factual or expert w'rtness in CSA's defense at the hearing of this matter, (see attachment) 

4. The documents CSA anticipsries offering into evidence al the hearing of this matter are the same 

CSA offered to the FAA FSDO, all of which were sent to Jeffrey Harper. The matters concerning 

SLCC records will be addressed by either Susan Horstman or Fiona Silcox. 

5. All expert witnesses are involved in flight training in one aspect or another, either as instructors, 

check pilots, assistant or chief Instructors or FAA DP examiners, {see attachment) 

6. All expert witnesses are involved tn flight training in one aspect or another, either as instructors, 

check pilots, assistant or chief instructors or FAA DP examiners. The subject matter is my FAA 

Part 141TCO. One witness is a computer software specialist designing our new program. 

7. Please clarify this request JS J do not know who Mr. Micliaelby is. 

8. Since this has been ongoing for several months it is impossible to recall exact dates of 

conversations and with whom I have discussed the matters alleged in the Complaint. It is most 

likely limited to persons affiliated with the flight school as they have received instruction so the 

occurrences will not happen again. 

9. CSA's Part 141 TCO and tramsng documents 

REQUESTS FOR PftODUCTION 

1 ^ The FAA already has copies of the documents - do you need me to make additional copies 

ot the materials you sent to me? The software designer of new flight school training 

program has computer prototype ready. This will have to be shown in person to FAA. 

REQUEST FOR ADfVUSSIONS 

1. Admit 

2. Admit - did at the time; with FAA consent have now changed method of record keeping 

3. Admit 

4. Admit - She was a transfer student from Utah Valley Unwersitv where she completed her 

private pilot ground school course. 

Page 1 of 4 
l0/2fl/20 n 1G:05 FAX 2Ci24935142 FAA ^ DI,1S 010/012 

FAA Correspondence Complainant's Initial Discovery Request Cornerstone Aviation 

5. Admit - she only qualifies to receh/e partial credit under her part 61 training which amounts to 

75% of the course requirements. So she could only count 7.5 hour^ tovrards her instrument 

ground instruction. Dun'ng the course of instrument training her instructor togged 18.8 hours of 

briefing time with her on a one-on-one basis. That equates to 26.3 hours out of the required 30 

hours, 

6. Admit 

7. Admit-they used to be 141 but at the time of Wilson's training they were Part 61. 

S. Admit 

9. Admit 

10. Admit 

11. Admit 

12. Admit 

13. Admit 

14. Admit 

15. Admit 

16. Admit 

17. No - When CSA administration discovered that Cameron HowelJ, his (f^structor, and Michael 

Stann began the flight training prior to his passing his private pilot certification check ride, CSA 

repaid Mr. Stann for his training up until that point (several.thousand dollars) and told him that 

we could not count any of that training and would re-start his instrument program. CSA selfdisclosed that information to the FSDO in SLC CSA told his CFI to begin a new training record 

and destroy the old record as it could not he used. Additionally, students have access to online 

scheduling program to schedule flights. Michael Stann scheduled ahead to start instrument 

training 

Page 2 of 4 
10_^./2_0_11 16:05 FAX 2024935142 FAA , DMS ©011/012 

FAA Correspondence Cornplainanf s Initial Discovery Request Cornerstone Aviation 

ATTACHMENT 

Cameron Howell -CR I for Michael Stann 

1Z51 North I^urdock Drive 

Pleasant Grove, UT 84062 

(801) 623-2S5S 

Kris Krie - CFIl for Haley Wilson 

B791 South Terra Point Way 

West Jordan, UTa4088 

(801) 864-4431 

Michael Stann - student of Cameron Howell 

2115 S. Richard St. 

Salt Uk e City, UT 84115 

(801) 244-1404 

Fiona Silcox - Assistant chief instructor for CSA at SLCC campus 

250 W. 3900 So. 

Salt Lake Qty, UT 84107 

(801) 949-3194 

Brian Vanderwel - Chief instructor for CSA 

1015 N. 1010 W. 

Pleasant Grove, UT 84062 

(801) 836-7112 

Richard Marshall - former chief instruaor for CSA - Private Pilot Certification program 

7883 South Grant Street 

Midvale, UT 84047 

(SOI) 671-3302 

Tom Kuhlman - retired FAA, current Designated Pilot Examiner (DPE) 

9508 South Kilmuir Circle 

So. Jordan, UT 84095 

(801) 633-5386 

Jack Garzella - Computer Software specialist 

1871 Longbranch Drive 

Draper, UT 34020 

(801)523-8243 

Page 3 of 4 
10/24/2011 1B:05 FAX 2024935142 FAA - QMS ©012/012 

FAA Correspondence Complainant's Initial Discovery Request Cornerstone Aviation 

Bernard Connelly - FAA FSDO 

1020 N. Flyer Way 

Salt Uke City, UT 84116 

[801)257-5054 

William Hughes - FAA 

1020 N. Flyer Way 

Salt Lake City, UT 84116 

(801) 257-5045 

George David Cawthra - FAA - FSDO Manager 

1020 N. Flyer Way 

Salt Lake City, UT 84116 

(801) 257-5045 

Page 4 of 4