Order 2010-11-05

Served: November 5, 2010

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

Issued by the Department of Transportation

on the 5th day of November, 2010

Applications of

 NATIONAL AIR CARGO GROUP, INC.

 d/b/a NATIONAL AIRLINES

for amended certificates of public convenience and 

necessity pursuant to 49 U.S.C. § 41102 to engage in 

interstate and foreign charter air transportation of 

persons, property, and mail

Dockets DOT-OST-2010-0181

 and

 DOT-OST-2010-0215

ORDER TO SHOW CAUSE

PROPOSING ISSUANCE OF CERTIFICATES

Summary

By this order, we tentatively conclude that National Air Cargo Group, Inc. d/b/a National 

Airlines (“National Airlines”) is a citizen of the United States and is fit, willing, and able to 

provide interstate and foreign charter air transportation of persons, property, and mail, and 

should be issued certificates of public convenience and necessity authorizing such operations, 

subject to conditions.

Background

Section 41102 of Title 49 of the United States Code (“the Transportation Code”) directs us to 

determine that applicants for certificate authority to provide interstate and foreign charter air 

transportation of persons, property, and mail are “fit, willing, and able” to perform such 

transportation and to ensure that all operations relating to this authority conform to the 

provisions of the Transportation Code and the regulations and requirements of the Department. 

In making fitness findings, the Department uses a three-part test that reconciles the Airline 

Deregulation Act’s liberal entry policy with Congress’ concern for operational safety and 

consumer protection. The three areas of inquiry that must be addressed in order to determine a 

company’s fitness are whether the applicant (1) will have the managerial skills and technical 

ability to conduct the proposed operations, (2) will have access to resources sufficient to 

commence operations without posing an undue risk to consumers, and (3) will comply with the 
2

Transportation Code and regulations imposed by Federal and State agencies. We must also 

find that the applicant is a U.S. citizen.

On July 9, and August 13, 2010, National Airlines, a U.S. air carrier holding certificate 

authority authorizing interstate and foreign air transportation of property and mail,1filed 

applications in Dockets DOT-OST-2010-0181 and DOT-OST-2010-0215 requesting 

amendments to its certificates authorizing it to provide interstate and foreign charter air 

transportation of persons, property, and mail. National Airlines accompanied its applications 

with information required by section 204.3 of our regulations (14 CFR 204.3) for an 

examination of its fitness to hold such authority.2

On August 18, 2010, National Airlines filed a Motion requesting to shorten the public 

comment period for filing of answers to the Department’s tentative decision from 14 normally 

permitted in such cases to 5 days. National Airlines states that the requested relief would 

permit it an opportunity to initiate its passenger operations by October 1, 2010, and, 

importantly, meet the eligibility requirements for Fall 2011 participation in the Civil Air 

Reserve Fleet’s (“CRAF”) passenger charter program. 

On August 19, August 23, and August 26, 2010, respectively, Air Transport International, LLC 

(“ATI”), Evergreen International Airlines, Inc. (“Evergreen”), and North American 

Airlines, Inc. (“North American”) (together, the “Interested parties”), each an operating U.S. 

certificated air carrier, filed answers opposing National Airlines’ Motion. The Interested 

parties argue that National Airlines’ request was untimely and lacked sufficient justification. 

The Interested parties further state that in the interest of due process, they should be allowed 

the full answer period normally permitted in certificated proceedings. 

At this same time, North American filed an answer to National Airlines applications,

contending that the applicant’s financial projections are based on questionable assumptions

and that the financial information provided contains discrepancies. North American urges the 

Department to conduct a thorough review of National Airlines compliance disposition in light 

of a recent settlement agreement National Air Cargo, Inc. (“NAC”), a company related to 

National Airlines by common ownership, entered into with the Department of Justice to 

resolve allegations that NAC defrauded the government.

 

1

See Order 2006-12-20, issued December 21, 2006. Currently, the air carrier’s authority is limited to three 

large aircraft.

2 National Airlines filed additional information supplementing its applications on September 2 and September 7, 

2010.

The applicant requested that certain information in its initial application be withheld from public disclosure. By 

letter dated August 31, 2010, the Department notified the applicant of our intended ruling on its confidentiality request, 

granting, in-part the applicant’s requests and informing National Airlines that certain information for which it requested 

confidentiality did not warrant such treatment. The applicant subsequently filed this information in the public docket on 

September 20, 2010.
3

On September 1, 2010, National Airlines filed a response to North American’s pleading, 

refuting the allegations raised by North American.

3

 National Airlines also reiterates its request 

to shorten the public comment period from 14 to 5 days. National Airlines believes its request 

would not prejudice any parties’ participation, especially since interested parties have already 

had an opportunity to comment on its applications. Furthermore, the applicant states the 

Department has granted similar requests in the past where the petitioning air carrier sought to 

add foreign passenger charter service to its already existing foreign cargo service.4

On October 4, 2010, ATI filed an answer to National Airlines’ applications and supplemental 

filings.

5

 ATI claims the historical and current financial statements provided by National 

Airlines for its parent company, National Air Cargo Holdings, Inc. (“NAC Holdings”),

contains discrepancies, and regardless of these discrepancies, indicates that NAC Holdings, of 

whom National Airlines is relying on for financial support, is in poor financial health. 

Moreover, ATI contends that a letter from NAC Holdings’ Chief Executive Officer offering to 

provide funding to National Airlines is a non-binding and unenforceable commitment of 

funding.

On October 14, 2010, National Airlines filed a response to ATI’s pleading. National Airlines 

contends that AIT’s assertions are without merit and intended to protract the regulatory process 

for ATI’s own competitive advantage. 

We have reviewed thoroughly the application, the answers provided by North American and 

ATI, and the responsive pleadings in this case and no special issues regarding the applicant 

have come to our attention requiring a hearing. Based on this review, our tentative findings, as 

more fully discussed in the FITNESS section below, are that National Airlines is a U.S. 

citizen and has established its fitness to provide, subject to conditions, interstate and foreign 

charter air transportation of persons, property, and mail, and that National Airlines should be 

issued certificates authorizing it to engage in interstate and foreign charter air transportation of 

persons, property, and mail, subject to conditions.

6 However, we will give interested persons 

an opportunity to show cause why we should not adopt as final these tentative findings and 

conclusions. We note that the applicant had requested a shortened public comment period for 

filing of answers to the Department’s tentative decision in order to facilitate an October 1 startup. Because that date has already passed, there is no longer a basis to grant that request, 

particularly in the circumstance where the request has been opposed. Therefore, we dismiss 

NAC’s Motion. Interested persons will be given 14 days following the service date of this 

order to show cause why the tentative findings and conclusions set forth here should not be 

made final with answers to objections due within 7 days thereafter.

 

3 The substance of the interested parties’ answers and the applicant’s response are more fully discussed in the 

FITNESS section.

4

See Order 2010-4-8, issued April 15, 2010, in Dockets DOT-OST-2009-0267 and DOT-OST-2009-0268.

5 ATI accompanied its answer with a motion to file for leave. 

6

Specifically, we are proposing to limit the air carrier’s operations to four total aircraft: three cargo and one 

passenger aircraft.
4

FITNESS

The Company

National Airlines, a U.S. certificated air carrier authorized to provide interstate and foreign 

charter cargo air transportation, is based in Ypsilanti, Michigan, and was formed as a 

corporation under the laws of the State of Michigan on April 6, 1992. The air carrier was 

initially formed under the name Murray Air, Inc. (“Murray Air”), and operated under the 

Murray Air name until 2006, when the company underwent a change in ownership. The air 

carrier holds a Part 121 Air Carrier Certificate issued from the Federal Aviation 

Administration (“FAA”). National Airlines is ultimately wholly owned by Mr. Christopher Alf

through his sole ownership of NAC Holdings, a corporation organized under the laws of the 

State of New York in 1991 and headquartered in Orchard Park, New York. NAC Holdings 

wholly or partially owns eight subsidiaries, which together provide worldwide freight 

forwarding and air transportation of cargo.7

Currently, National Airlines operates a fleet of three DC-8 cargo aircraft and provides air

transportation of freight for a number of customers, including the U.S. Department of Defense. 

If granted the certificates it seeks, National Airlines intends to add one Boeing 757-200ER

passenger aircraft to its fleet for use in interstate and foreign passenger charter operations.

8

 

The air carrier intends to operate its passenger charter service for charter brokers, public 

charter operators, private corporations, and sports teams. 

Managerial Competence

National Airlines’ Board of Directors, officers, and other key management personnel, all of 

whom are U.S. citizens, consist of the following individuals:

Christopher Alf – Board Member

Loretta Alf – Board Member

John R. Baker – Board Member

Glen Joerger – Board Member

William Mortensen - Board Member

 

7

Specifically, NAC Holdings wholly owns National Air Cargo, Inc., a New York corporation; National Air 

Cargo S.a.r.l, a Luxembourg corporation, which is the ultimate parent company of National Air Cargo Middle 

East FZE, a United Arab Emirates corporation; National Air Cargo SGPS, Unipessoal Lda., a single-owner 

Portuguese limited liability company; NAC Acquisitions, a Michigan corporation; NACM OHQ, Sdn Bhd, a 

Malaysian private limited liability company; NACM Holdings, Sdn Bhd, a Malaysian private limited liability 

company; National Air Cargo Limited, a Thai private limited liability company; and NAC AC Ventures, LLC, a 

Delaware corporation. NAC Holdings has partial ownership in National Air Cargo GmbH, a German corporation.

8

In its application, National Airlines also references its plans to acquire four additional Boeing 757-200 

aircraft, which it intends to configure as “combi” aircraft for the transport of U.S. military personnel and cargo 

under the CRAF program. However, the applicant states that at this time, those plans have yet to mature, and 

should they mature, it will provide the required fleet expansion request to the Department (See Docket DOT-OST2010-0181, Application of National Air Cargo Group, Inc., at 3.)
5

Preston G. Murray – Chief Executive Officer (“CEO”)/Board Member

Thomas J. Quehl – President

Joseph A Stroud – Chief Financial Officer

Steven F. Clements – Director of Operations

Carlos Veliz – Director of Safety

Emmett M. Dotson – Director of Maintenance

Abraham V. Williams, Jr. – Director of Quality Control

Jonathan W. Wiesinger – Chief Pilot

Mr. Christopher Alf has more than 20 years of experience in the air cargo and freight 

forwarding industry. In 1991, he founded National Holdings in Orchard Park, New York, with 

a desire to provide global freight forwarding services. The company now operates offices in 

New York, Germany, United Arab Emirates, Malaysia, South Korea, Thailand, and Japan. As 

the sole shareholder of NAC Holdings, the ultimate owner of National Airlines, Mr. Alf is also 

the sole or primary shareholder of NAC Holdings’ numerous other worldwide subsidiaries. In 

addition to serving as chairman of NAC Holdings, Mr. Alf also serves as a board member at 

each of NAC Holdings’ subsidiaries. Prior to founding National Holdings, Mr. Alf was 

employed by Western New York Air Freight, Inc., as an Independent Sales Contractor (1986-

1991).

Mrs. Loretta Alf has more than 20 years of experience in sales, marketing, and executive 

leadership positions. In 2008, Mrs. Alf founded and serves as CEO of Palm Beach Ice Works, 

an ice skating park in Palm Beach, Florida, and Tacking Innovations, LLC, a supply chain 

management company. Prior to this, she was employed by National Air Cargo as a Strategic

Consultant (2005-2008) and as Vice President of Sales (1991-2005), and by Tower Group 

International as a Custom Broker (1988-1991).

Lieutenant General John R. Baker served in the U.S. Air Force (“USAF”) for more than 33 

years before retiring in 2002. During his career with the USAF, General Baker served as a 

pilot and staff officer, and held multiple positions as commander, including staff positions in 

the Pentagon and positions as Squadron Commander, Wing Commander, and Vice 

Commander. 

Colonel Glen Joerger served in the USAF for more than 24 years before retiring in 2007. 

During his career with the USAF, Colonel Joerger held various senior executive positions 

primarily in areas where he was responsible for strategic and operational supply chains and 

transportation networks. Currently, Colonel Joerger serves as the Managing Member of 

Innovative Concepts Consulting, LLC. In addition to serving as a Board member at National 

Airlines, he is also a Board member at Trident United Way, Charleston Chamber of 

Commerce, and Federal Executive Association. 

Lieutenant General William Mortensen retired from the U.S. Army in 2008 after 35 years of 

service. His last assignment was as Deputy Commanding General, U.S. Army, Material 

Command, where he was responsibilities for areas of acquisition, logistics, and research and 

development. General Mortensen has also held various command positions throughout his 
6

long military career and he has completed numerous Army and Joint assignments throughout 

the Department of Defense.

The Department reviewed Mr. Preston G. Murray’s employment background in connection 

with the certification of Murray Air.9 Since then, he has been employed by National Air Cargo 

as its President and CEO (2006-present) and as CEO of National Airlines (2006-present). Mr. 

Murray is also a member of the United States Air Force Lift Committee, a member of the 

Eastern Michigan University Aviation Advisory Board, and a partner in Murray Air 

Certifications, an FAA approved consulting and certification firm.

The Department reviewed Mr. Thomas J. Quehl’s employment background in connection with 

the certification of Murray Air.10 At that time, Mr. Quehl was serving as the Director of 

Operations of Murray Air. In November 2008, he became the President of National Airlines.

Mr. Joseph A Stroud joined National Airlines in January 2009 as its Chief Financial Officer. 

Prior to joining the company, he served as a Consultant and Partner of General Management 

Partners, LLC (2005-2009) and J.F. Lehman Equity Investors I, LP (1997-2005). Mr. Stroud 

also was employed by Sperry Marine, Inc., as Executive Vice President and Chief Financial 

Officer (1993-1996); by Astra Holdings Corp., as Vice President of Finance and 

Administration (1989-1993); by General Defense Corporation as Vice President and Business 

Operations (1985-1989); and by Western Union Telegraph Company in various positions of 

increasing responsibly, including Director of Financial Planning, Manager of Finance and Cost 

Analyst (1978-1985). In addition to his duties and responsibilities as Chief Financial Officer 

of National Airlines, Mr. Stroud is also a Board member of OSI Geospatial and Burke 

Industries, Inc.

Mr. Steven F. Clements, an Airline Transport Pilot with over 14,500 total flight hours, has 

served as National Airlines’ Director of Operations since June 2009. Prior to joining National 

Airlines, he was employed by Cayman Airways as Vice President of Flight Operations (2009), 

as an FAA Certification Consultant (2008-2009), by Virgin America as Director of Training 

(2004-2008), by Airtran Airways as a Boeing 737 Fleet Manager (2004) and as Manager of 

Training (2000-2004), by Arrow Air as Vice President and Director of Operations (1999-2000) 

and as a pilot (1992-1993), by American International Airways as Director of Training 

(1993-1999), and by United Parcel Service as a Flight Standard Supervisor (1989-1992). 

Mr. Carlos Veliz joined National Airlines in January 2010 as the air carrier’s Director of 

Safety. Prior to this, he was employed at Cayman Airways as Director of Safety (2009). 

Mr. Veliz has also previously been employed by Arrow Panama, SA, as President and General 

Manager (2005-2008), at Planet Airways as Vice President of Compliance (2002-2004), at 

Arrow Air as Director of Safety (1989-1999), and at Batch Air, a Part 145 repair station, as 

 

9

See Order 2003-5-36, Docket DOT-OST-2003-14320.

10 See Order 2004-11-6, Docket DOT-OST-2003-14320.
7

Lead Mechanic and Shift Supervisor (1986-1989). Mr. Veliz holds FAA certificates as a 

Commercial Pilot, Flight Engineer, and Airframe and Powerplant Mechanic. 

Mr. Emmett M. Dotson, an Airframe and Powerplant Mechanic with more than 34 years of 

experience in aircraft maintenance, joined National Airlines in 2007 as the air carrier’s 

Director of Maintenance. Prior to this, he was employed by Murray Air as Director of 

Maintenance (2006-2007); by Air Transport International as Senior Coordinator of Aircraft 

and System Modifications (2006), Manager of Heavy Maintenance (2004-2005), Manager of 

Quality Control (2000-2004), and Quality Control Representative (1994-2000); by Page Avjet 

Corp. as Lead Mechanic (1992-1994); by Crown Airways as Director of Maintenance 

(1990-1992); by Metro Express II, Inc., as Director of Maintenance (1988-1990); by SMB 

Stage Line as Aircraft Inspector (1985-1988); by GTE Directories Services Corp. as a 

mechanic (1985-1988); and by Wright Airlines as a mechanic (1982-1984). Mr. Dotson also 

served in the U.S. Army for four years as an aircraft mechanic (1976-1980).

The Department reviewed the employment background of Mr. Abraham V. Williams, Jr., in 

connection with the certification of Murray Air.11 At that time, Mr. Williams was serving as 

the Vice President of Operations and Maintenance of Murray Air. In 2007, he became the 

Director of Quality Control of National Airlines.

Mr. Jonathan W. Wiesinger has served as Chief Pilot of National Airlines since June 2010. 

Prior to this, he was employed with the air carrier as its Director of Operations and as a DC-8 

Check Airman (2008-2010). Mr. Wiesinger has also been employed by United Airlines as an 

A-320 First Officer (2007-2008) and as a B-737 and B-727 First Officer (2000-2003), by 

National Airlines as a DC-8 Check Airman (2005-2007), by A-1 Mechanical as General 

Manger (2003-2005), and by Atlantic Coast Airlines as a J-32 First Officer (1999-2000). In

addition to his civilian aviation experience, Mr. Wiesinger was also employed in various 

aviation-related positions while serving in the U.S. Air Force (1989-1998) and he is currently a 

C-130H Instructor Pilot in the Ohio National Guard (since 2007).

In view of the experience and background of the applicant’s key personnel,12 we tentatively 

conclude that National Airlines’ management team possesses the managerial skills and 

technical ability to conduct its proposed service.13 

 

11 See Order 2003-5-36, Docket DOT-OST-2003-14321.

12 National Airlines also provided the resumes for three other individuals holding senior staff positions. These 

individuals are Richard A. Polas (Manager of Quality Assurance), Jahaziaha Webb (Director of Training), and 

Charles H. Davis, Jr (Maintenance Supervisor). We have reviewed the background and experiences of these 

individuals and each appears qualified for their position.

13 Before authorizing an air carrier to conduct air transportation operations, the FAA also evaluates certain of 

the applicant’s key personnel with respect to the minimum qualifications for those positions as prescribed in the 

Federal Aviation Regulations. The FAA’s evaluation of these key personnel provides an added practical and inperson test of the skills and technical ability of these individuals. All of National Airlines’ key technical personnel

have been approved by the FAA to hold their positions.
8

Operating Plan and Financial Position

As previously stated, if granted the certificates it seeks, National Airlines intends to add one 

Boeing 757-200ER passenger aircraft to its fleet for use in interstate and foreign passenger 

charter operations. To meet the Department’s financial fitness criteria, an applicant should 

have access to financial resources sufficient to cover its pre-operating expenses and the 

expenses that are reasonably projected to be incurred during three months of “normal” 

operations.14 National Airlines provided the Department with a financial forecast for its first 

year of passenger operations using one Boeing 757 aircraft and a list of all pre-operating 

expenses associated with adding the aircraft to its FAA Operation Specifications. The 

applicant projects that its total operating expense for its first year of charter operations with 

this aircraft will be about $13.6 million and that it will incur $845,000 in pre-operating 

expenses.15

In its August 26 answer objecting to National Airlines’ applications for certificate authority, 

North American declares that National Airlines has grossly underestimated the projected cost 

of its proposed service, thereby reducing the amount of working capital reserve the applicant 

needs to meet the Department’s financial fitness requirements. For example, North American 

states the applicant’s forecasted monthly lease expense of $40,000 does not reflect market 

realities. In support of its position, North American provided a survey of current lease rates for 

the B757-200 aircraft published by the International Society of Transport Aircraft Trading 

(“ISTAT”). North American also claims that National Airlines’ presented the Department with

an overly optimistic first-year operating forecast and questions whether the applicant can 

consistently achieve the 100 block hours of utilization forecasted per month or the $13,000 

block hour rate it proposes. North American claims that because National Airlines’ operating 

expenses are likely to be higher than forecasted and its revenues are likely to be lower than 

forecasted, the projected financials filed by National Airlines have very little resemblance to 

market realities.

In its response to North American’s allegations, National Airlines argues that $40,000 monthly 

aircraft lease amount in its expense forecast does not purport to be the full lease cost. National 

Airlines states that it also included an estimated aircraft maintenance reserve of $120,000 per 

month in its expense forecast. This combined figure amounts to $160,000 in monthly lease 

costs, which National Airlines notes is well within the average monthly B757-200 lease range 

cited in the ISTAT survey provided by North American. In addition, National Airlines claims 

that its forecasted 100 hours of monthly utilization is based on years of experience and is 

consistent with reported averages for other large aircraft passenger charterers.

 

14 Because projected expenses during the first several months of air transportation services frequently do not 

include all costs that will be incurred during a “normal” period of operations, it is our practice to base our threemonth test on an average of one-quarter of the first year’s operating cost forecast. 

15 National Airlines forecast of first-year operating expenses includes approximately $12.3 million in direct 

operating expenses and $1.35 million in indirect operating expenses. Indirect operating expenses were calculated 

by allocating indirect expenses evenly among the number of aircraft in National Airlines’ fleet.
9

We have carefully reviewed North American’s and National Airlines’ comments. While we 

evaluate the overall reasonableness of an applicant’s service proposal it is not our practice to 

judge the validity of utilization or revenue forecasts. Our primary focus is on evidence that the 

applicant fully understands and has reasonably estimated the costs involved in providing the 

proposed operations, and that it has available to it resources sufficient to meet our financial 

fitness requirements to cover those expenses.16 In this regard, we have reviewed the 

applicant’s projected direct costs on a block hour basis against the costs reported by other air 

carriers operating similar aircraft and find the applicant’s forecast to be reasonable. Based on 

this review we estimate that National Airlines will need access to $4.25 million in funding to 

meet our financial fitness test.17

Historical financial statements submitted in support of National Airlines’ fitness show that for 

the calendar year ending 2008, National Airlines experienced a net loss of $98,799 on 

approximately $25.21 million in operating revenues, and for the calendar year ending 2009, 

National Airlines experienced a net loss of $6.11 million on approximately $23.52 million in 

operating revenues. For the five months ending May 31, 2010, National Airlines lost $917,392

on approximately $12.93 million in operating revenues. The air carrier’s most recent balance 

sheet indicates that, as of May 31, 2010, it had current assets of $3.52 million and current 

liabilities of $2.08 million, giving the company a positive working capital balance of $1.44 

million. The same balance sheet shows the company as having negative retained earnings of 

$6.83 million and total shareholders’ equity of $620,605. 

In support of its ability to meet our financial fitness requirements, National Airlines states that 

its parent company, NAC, or its parent company, NAC Holdings, will provide any additional 

infusion of capital required to meet the Department’s financial fitness requirements. In 

addition, the applicant provided a letter from NAC confirming it would make funds available 

to National Airlines to support its proposed passenger operations, and third-party verification 

from JPMorgan Chase Bank (“JP Morgan”) confirming that NAC maintained account deposits 

in excess of the amount required by National Airlines to meet the Department’s financial 

fitness requirements. Furthermore, National Airlines provided a balance sheet for NAC 

Holdings shows that as of July 31, 2010, NAC Holdings had cash accounts of $8.76 million, 

total stockholders’ equity of $133.73 million, current assets of $55.19 million, and current 

liabilities of $22.87 million, for a current ratio of 2.41:1 (meaning that for every dollar that 

NAC Holdings owed on July 31, 2010, payable within 12 months, it has $2.41 with which to 

pay it).

In its August 26 answer, North American questions whether National Airlines has access to 

sufficient capital to meet the Department’s fitness requirements. North American claims the 

third-party verification of cash accounts that National Airlines provided from JP Morgan is not 

reflected in the applicant’s balance sheet, although the date of the JP Morgan letter predates the 

date of the balance sheet.

 

16 See Order 99-8-12, at 8.

17 This figure is comprised of the applicant’s forecasted pre-operating expenses ($845,000) and an average of 

one-quarter of the first year’s operating cost forecast ($3.41 million).
10

In its September 1 reply, National Airlines maintains that contrary to North American’s 

assertion, it has working capital reserves sufficient to satisfy the Department’s financial fitness 

requirements. National Airlines states that the letter from JP Morgan clearly identifies the cash 

accounts held by NAC. Therefore, there is no corresponding accounting entry on National 

Airlines balance sheet to reflect these funds. However, National Airlines contends, as stated in 

its application, that NAC and NAC Holdings have pledged to provide these funds to support 

National Airlines proposed passenger operations and the JP Morgan letter was provided as 

verification of their ability to extend their financial commitment to National Airlines.

In its October 4 answer, ATI claims the historical and current financial statements of NAC 

Holdings contain irregularities in the accounting of retained earnings. Specifically, ATI states 

that it is unable to reconcile NAC Holdings’ ending retained earnings by adding the net income 

for the year to NAC Holdings’ beginning retained earnings. Moreover, ATI contends that the 

financial statements of NAC Holdings’ show a dramatic decline in the company’s liquid assets 

over the past few years and that the dwindling of NAC Holdings’ short-term liquidity is 

indicative of poor financial health. Furthermore, ATI claims that a letter from NAC Holdings’ 

expressing a commitment to make funding available to support National Airlines’ proposed 

operations is non-binding and unenforceable. 

In its response to ATI answer, National Airlines explains that the “anomalies” ATI asserts in 

the accounting of NAC Holdings retained earnings is primarily attributable to distributions that 

have been made. In addition, National Airlines states, the financial statements that it provided 

to the Department for 2007 and 2008 are from audited financial statements while the 2009 and 

January-July 31, 2010, financial statements are preliminary unaudited results which are subject 

to change. National Airlines notes that the decline in NAC Holdings’ short-term liquidity is 

attributed to several factors, including a devaluing of the company’s investments following the 

fall of the stock market from late 2008 through the first part of 2009, customary distributions 

to the shareholder, and the liquidation of cash and investment accounts to purchase aircraft for 

use in National Airlines’ operations. As a final point, National Airlines states that the letter 

from NAC Holdings agreeing to commit funds to support National Airlines proposed 

operations is identical to commitments found in numerous other applications before the 

Department. In addition, National Airlines contends that a formal contract between affiliated

companies would be no more meaningful than the commitment letter it provided since it would 

be absurd for one affiliate to sue another affiliate to force performance under a contract.

The opposing parties have provided no convincing evidence to support their contention that the 

applicant does not have access to sufficient financial resources or that its financial projections 

are unreasonable or erroneous. The record shows that NAC Holdings and its subsidiaries have 

extended an offer to provide National Airlines with the capital necessary to meet the capital 

requirements for its proposed passenger charter operations. In addition, the applicant provided 

evidence demonstrating the availability of the funds necessary to honor this commitment, as 

well as third-party verification of these funds. In light of the foregoing, we tentatively 

conclude that National Airlines will have access to sufficient financial resources to commence 

the operations it proposes without posing an undue risk to consumers or their funds. 
11

Moreover, we note that, as is our practice, prior to making any authority awarded to National 

Airlines effective, we will require the company to demonstrate that it continues to have access 

to the financial resources needed to meet our financial test. 

This tentative finding of fitness is based on the operations proposed in this application. Were 

National Airlines to propose a substantial expansion in its plans, including the operation of 

more than the one passenger aircraft discussed here, this finding may not continue to apply. 

Therefore, if our tentative finding regarding National Airlines’ fitness is made final, and 

National Airlines is issued the authority it seeks, we will require that, should the company want

to operate more than four total aircraft and/or more than one passenger aircraft, it must first 

provide the Department with at least 45-days advance notice of such plans and provide updated 

information establishing its fitness for such expansion.

Compliance Disposition

In 2005, a NAC employee filed a qui tam action in the U.S. District Court alleging that NAC 

had violated the Federal False Claims Act by submitting false invoices to the Department of 

Defense. In October 2007, NAC and the DOD entered into a negotiated settlement that 

resolved all of these charges except for a single count of submitting a false invoice. According 

to the settlement agreement, NAC agreed to plead guilty to one count of knowingly making a 

material misstatement to the United States, a felony charge and violation of Title 18 of the

United States Code, Section 1001(a)(2), and it agreed to pay certain penalties and restitution. 

Subsequent to this, NAC entered into an Administrative Agreement with the USAF under 

which, among other things, Mr. Alf and five employees were required to leave the company.

Mr. Alf’s stock was placed in a voting trust with the company operating under the management 

of the voting trust. Furthermore, the USAF debarred Mr. Alf from government contracting for 

a period of three years. 

Similarly, because of the nature and degree of the allegations made against NAC and its owner, 

Mr. Alf, and the common ownership between National Airlines and NAC, the Department

found it appropriate to impose certain fitness conditions on National Airlines to ensure its 

independence from NAC, including requiring that management of National Airlines be placed 

under a voting trust and an independent board of directors; removing certain individuals, 

including Mr. Alf, from any influence or control over the company; regular reporting 

requirements; and a requirement that Mr. Alf dispose of his interest in National Airlines within 

a reasonable period of time. 

In May 2009, Mr. Alf filed a complaint in the U.S. District Court for the District of Columbia

contesting his debarment from government contracting and on October 29, 2009, the District 

Court issued an Order and Opinion granting Mr. Alf a preliminary injunction against 

enforcement of the debarment decision of the USAF. The District Court found that the USAF 

had erred in its findings that any fraud beyond the single false statement had occurred, and that 

it was improper to impute the alleged misconduct associated with that false statement to 

Mr. Alf. Shortly thereafter, the USAF permanently terminated Mr. Alf’s debarment and in 
12

December 2009, the USAF and NAC amended the Administrative Agreement to permit

Mr. Alf to dissolve the voting trust and resume control of NAC.

On December 3, 2009, National Airlines requested that, in light of the District Courts findings 

and the Amended Administrative Agreement with the USAF, the Department remove the 

fitness conditions previously imposed. Upon review of the matter, the Department found 

National Airlines fit under the ownership, control, and management of Mr. Alf, and removed 

the fitness conditions. By letter dated August 12, 2010, we informed National Airlines of our 

conclusion. At the same time, we imposed various reporting requirements, including requiring 

the air carrier report, within 7 days of occurrence, (1) any charge of unfair or deceptive or 

anticompetitive business practices, or of fraud, felony or antitrust violation, brought against 

any relevant corporation,18 or member of the key personnel19 employed (or to be employed) by 

any relevant corporation; (2) investigations, enforcement actions, or formal complaints filed by 

the Department or other government agency, involving any relevant corporations, personnel 

employed (or to be employed) by any relevant corporations or person having a substantial 

interest20 in any relevant corporation; (3) any complaint or other action by the USAF alleging 

that NAC had failed to comply with any aspect of the December 2009 Amended Settlement 

Agreement; and (4) any aircraft accidents or incidents (as defined by the National 

Transportation Safety Board Regulations, 49 CFR 830.2) experienced by National Airlines, its 

personnel, or any relevant corporation. With these reporting requirements in place, the 

Department may more closely monitor the air carrier’s compliance posture.

In its application, the applicant stated that other than noted above, there have been no charges 

of fraud or felony against it, its owners, or its key personnel nor have there been any charges of 

unfair, deceptive or anti-competitive business practices, or of or antitrust violations brought 

against National Airlines, its owners, or its key personnel in the past ten years. Moreover, the 

applicant stated that there are no pending legal actions or outstanding judgments or pending

investigations, enforcement actions, or formal complaints filed by the Department against it, its 

key personnel, or persons having a substantial interest in it with respect to compliance with the 

Transportation Code or the Department’s regulations. 

On October 8, 2010, the Department received a complaint from an interested party alleging 

that National Airlines had violated section 201.5 of our rules, by advertising its proposed 

 

18 Section 204.2(k) of our rules (14 CFR 204.2(k)) defines a relevant corporations as the air carrier, any 

subsidiary thereof, any predecessor thereof (i.e., any air carrier in which any directors, principal officers or 

persons having a substantial interest have or once had a substantial interest), and any company (including a sole 

proprietorship or partnership) which has a significant financial or managerial influence on the applicant or air 

carrier. The latter includes any company (including a sole proprietorship or partnership) holding more than 50 

percent of the outstanding voting stock of the air carrier; and any company (including a sole proprietorship or 

partnership) holding between 20 percent and 50 percent of the outstanding voting stock of the air carrier and 

which has significant influence over the air carrier as indicated, for example, by 25 percent representation on the 

board of directors, participation in policy-making processes, substantial inter-company transactions, or managerial 

personnel with common responsibilities in both companies (See 14 CFR § 204.2(k)).

19 See 14 CFR § 204.2(i).

20 See 14 CFR § 204.2(m).
13

passenger air transportation prior to receiving effective authority from the Department.21 

These allegations are currently being investigated by the Department’s Assistant General 

Counsel for Aviation Enforcement and Proceedings (“Enforcement Office”). 

While National Airlines’ compliance disposition is a concern to us in light of the Enforcement 

Office’s investigation, we do not believe that this action alone would warrant a negative 

finding of fitness for National Airlines.

22

 A review of our records and other information 

available to us has uncovered no additional information which would lead us to conclude that 

the applicant or any of its key personnel lacks the proper compliance disposition to be found

fit. In addition, according to the FAA, the air carrier has conducted its operations satisfactorily

and the agency knows of no reason why the air carrier should not be granted the authority it is 

seeking.23 Moreover, the Enforcement Office has informed us that it has no objections to the 

approval of National Airlines’ application.

In light of these circumstances, we tentatively find that National Airlines has the proper regard 

for the laws and regulations governing its services to ensure that its aircraft and personnel 

conform to applicable safety standards and that acceptable consumer relations practices will be 

followed. 

CITIZENSHIP

Section 41102 of the Transportation Code requires that certificates to engage in air 

transportation be held only by citizens of the United States as defined in 49 U.S.C.

§ 40102(a)(15). That section specifies that the president and two-thirds of the board of 

directors and other managing officers be U.S. citizens, that at least 75 percent of the 

outstanding voting interest be owned by U.S. citizens, and that the air carrier must be under the

actual control of U.S. citizens.

As noted earlier, National Airlines is a corporation organized under the laws of the State of 

Michigan. The company is wholly-owned by National Air Cargo Acquisitions, LLC (“NAC 

Acquisitions”), a Delaware limited liability company. NAC Acquisitions in turn, is whollyowned by NAC Holdings, a New York corporation. Mr. Christopher J. Alf, a U.S. citizen, is 

the sole owner of NAC Holdings. In addition, National Airlines’ president, its board of 

directors, and all of its key personnel are U.S. citizens. Furthermore, National Airlines

provided an affidavit attesting that it is a U.S. citizen. Finally, there is no other information 

before us that would lead us to conclude that National Airlines is not controlled by U.S. 

citizens.

 

21 See 14 CFR § 201.5. 

22 We will monitor the course of this enforcement action as part of our continuing fitness responsibilities.

23 National Airlines notes that neither it nor any of its key personnel have been involved in an accident or 

incident in the year preceding its application or at any time in the past which remains under investigation by the 

FAA, the NTSB, or the company itself.
14

In view of the foregoing, we tentatively conclude that National Airlines is a U.S. citizen and 

that it is fit, willing, and able to provide air transportation services as a U.S. certificated air 

carrier, subject to conditions. 

PUBLIC CONVENIENCE AND NECESSITY

No finding of consistency with the public convenience and necessity is required for the award 

of authority for interstate charter air transportation of persons, property, and mail under section 

41102, although such a finding is required for authority to engage in foreign charter air 

transportation.

We tentatively find that the foreign charter air transportation proposed by National Airlines is 

consistent with the public convenience and necessity. By Order 78-7-106, which instituted the 

Former Large Irregular Air Service Investigation, the Civil Aeronautics Board found that 

there was a continuing demand and need for additional charter air carriers. These findings 

remain valid and apply to the authority sought by National Airlines. Therefore, if National 

Airlines meets the fitness requirements of the Transportation Code, it will receive certificates 

authorizing it to engage in interstate and foreign charter air transportation of persons, property, 

and mail under section 41102.24

OBJECTIONS

We will give interested persons 14 days following the service date of this order to show cause 

why the tentative findings and conclusions set forth here should not be made final; answers to 

objections will be due within 7 days thereafter. We expect such persons to direct their 

objections, if any, to the applications and points at issue and to support such objections with 

detailed economic analyses. If an oral evidentiary hearing or discovery procedures are 

requested, the objector should state in detail why such a hearing or discovery is considered 

necessary, and what material issues of decisional fact the objector would expect to establish 

through a hearing or discovery that cannot be established in written pleadings. The objector 

should consider whether discovery procedures alone would be sufficient to resolve material 

issues of decisional fact. If so, the type of procedure should be specified (See Part 302, Rules 

19 and 20); if not, the reasons why not should be explained. We will not entertain general, 

vague, or unsupported objections. If no substantive objections are filed, we will issue an order 

that will make final our tentative findings and conclusions with respect to National Airlines’

fitness and certification.

 

24 Pursuant to 49 U.S.C. § 41307, issuance of foreign authority to the applicant is subject to Presidential review.
15

EFFECTIVE CERTIFICATE CONDITIONS AND LIMITATIONS

If National Airlines is found fit and issued the certificates it seeks, its authority will not 

become effective until the air carrier has fulfilled all of the requirements for effectiveness as 

set forth in the terms and conditions attached to its certificates. Among other things, this 

includes (1) our receipt of evidence that National Airlines has been certificated by the FAA to 

engage in passenger operations, (2) evidence of liability insurance coverage that meets the 

requirements of section 205.5(b) of our rules, (3) a statement of changes it may have 

undergone since its fitness was examined, and (4) evidence that National Airlines continues to 

have adequate financial resources available to it.

We also wish to remind National Airlines of the requirements of 49 U.S.C. § 41110(e). 

Specifically, that section requires that, once an air carrier is found fit initially, it must remain 

fit in order to hold its authority. To be assured that certificated air carriers continue to be fit 

after effective authority has been issued to them, we require that they supply information 

describing any subsequent substantial changes they may undergo in areas affecting fitness. 

Therefore, if National Airlines is issued effective certificate authority and subsequently 

proposes substantial changes in its ownership, management, or operations, it must first comply 

with the requirements of section 204.5 of our rules.25 

Moreover, this tentative finding of fitness is based on the operations proposed in this 

application. Were National Airlines to propose a substantial expansion in its plans, including 

the operation of more than the one passenger aircraft discussed here, this finding may not 

continue to apply. Therefore, if our tentative finding regarding National Airlines’ fitness is 

made final, and National Airlines is issued the authority it seeks, we will require that, should 

the company want to operate more than three cargo aircraft and/or more than one passenger 

aircraft, it must first provide the Department with at least 45-days advance notice of such plans 

and provide updated information establishing its fitness for such expansion. The compliance 

of the company with this requirement is essential if we are to carry out our responsibilities 

under section 41110(e).26

 

25 The air carrier may contact our Air Carrier Fitness Division to report proposed substantial changes in its 

operations, ownership, or management, and to determine what additional information, if any, will be required 

under section 204.5. In addition, by notice dated July 21, 1998, the Department requested air carriers to provide a 

30-day advance notification of any proposed change in ownership, restructuring, or recapitalization. If the air 

carrier fails to file this updated information or if the information fails to demonstrate that the air carrier will 

continue to be fit upon implementation of the substantial change, the Department may take such action as is 

appropriate, including enforcement action or steps to modify, suspend, or revoke the air carrier's certificate

authority.

26 We also remind National Airlines about the requirements of section 204.7 of our rules. This section provides, 

among other things, that (1) the certificate authority granted to a company shall be revoked if the company does 

not commence actual flying operations under that authority within one year of the date of the Department's 

determination of its fitness; (2) if the company commences operations for which it was found fit and subsequently 

ceases such operations, it may not resume commuter operations unless its fitness has been redetermined; and (3) if 

the company does not resume operations within one year of its cessation, its authority shall be revoked for 

dormancy.
16

Finally, if National Airlines is granted effective authority, it would be required to submit a 

detailed progress report, within 45 days following the end of the first year of certificated flight 

operations, to the Air Carrier Fitness Division. The submission of a first year progress report 

is conditioned upon all newly certificated air carriers and was adopted as policy by the 

Department to aid in monitoring the fitness of new air carriers. The report should include a 

description of the air carrier’s current operations (number and type of aircraft, principle 

markets served, total number of full-time employees), a summary of how its operations have 

changed during the year, a discussion of any changes it anticipates from its current operations 

during its second year, current financial statements,27 and a listing of current senior 

management and key technical personnel. The air carrier should also be prepared to meet with 

staff members of the Fitness Division to discuss its current and future operations.

ACCORDINGLY,

1. We direct all interested persons to show cause why we should not issue orders making 

final our tentative findings and conclusions stated above and award certificates to National Air 

Cargo Group, Inc. d/b/a National Airlines authorizing it to engage in interstate and foreign 

charter air transportation of persons, property and mail, subject to the attached specimen 

Terms, Conditions, and Limitations.

2. We deny the Motion of National Air Cargo Group, Inc, in Docket DOT-OST-2010-0181, 

requesting to shorten the comment period.

3. We direct any interested persons having objections to the issuance of orders making final 

any of the proposed findings, conclusions, or the certificate awards set forth here to file such 

objections with the Department of Transportation Dockets, 1200 New Jersey Avenue, S.E., 

West Building Ground Floor, Rm. W12-140, Washington, D.C. 20590, in Dockets DOT-OST2010-0181 and DOT-OST-2010-0215 and serve them upon all persons listed in Attachment A 

no later than 14 days after the service date of this order; answers to objections shall be filed no 

later than 7 days thereafter.

4. If timely and properly supported objections are filed, we will accord full consideration to 

the matters or issues raised by the objections before we take further action.

5. In the event that no objections are filed, we will consider all further procedural steps to be 

waived and we will enter orders making final our tentative findings and conclusions and will 

issue National Air Cargo Group, Inc. d/b/a National Airlines certificates that will contain exact 

copies of the attached specimen Terms, Conditions, and Limitations.28

6. We will grant all motions for leave to file in Docket DOT-OST-2010-0181.

 

27 These financial statements should include a balance sheet as of the end of the company’s first full year of 

certificated flight operations and a 12-month income statement ending that same date.

28 Since we have provided for the filing of objections to this order, we will not entertain petitions for 

reconsideration.
17

7. We will serve a copy of this order on the persons listed in Attachment A.

8. We will publish a notice of this order in the Federal Register.

By:

SUSAN L. KURLAND

Assistant Secretary

for Aviation and International Affairs

An electronic version of this document is available on the World Wide Web at

http://www.regulations.gov
Attachment

Specimen

Terms, Conditions, and Limitations

NATIONAL AIR CARGO GROUP, INC.

d/b/a NATIONAL AIRLINES

is authorized to engage in interstate charter air transportation of persons, property, and mail 

between any point in any State, territory, or possession of the United States or the District of 

Columbia, and any other point in any of those entities.

This authority is subject to the following provisions:

(1) The authority to conduct cargo charter air transportation under this certificate became 

effective on December 21, 2006. The authority to conduct passenger charter air transportation 

under this certificate will not become effective until six (business) days after the Department has 

received the following documents; provided, however, that the Department may stay the 

effectiveness of this authority at any time prior to that date:

(a) A copy of the holder's Air Carrier Certificate and Operations Specifications 

authorizing such operations from the Federal Aviation Administration (FAA).

(b) A certificate of insurance on OST Form 6410 evidencing liability insurance 

coverage meeting the requirements of 14 CFR 205.5(b) for all of its aircraft.

(c) A statement of any changes the holder has undergone in its ownership, key 

personnel, operating plans, financial posture, or compliance history, since the date of the 

Show Cause Order in this case.

(d) A revised list of pre-operating expenses already paid and those remaining to be 

paid, as well as independent verification that the holder has available to it funds 

sufficient to cover any remaining pre-operating expenses and to provide a working 

capital reserve equal to the operating costs that would be incurred in three months of 

operations.

(2) Pending receipt of effective authority, the holder may not accept payment of any kind 

(i.e., cash, check, or credit card), issue tickets for the operations proposed under this certificate, 

or enter into contracts with charter operators, and any advertisement by the holder must 

prominently state: "This service is subject to receipt of government operating authority." 

(3) The holder shall at all times conduct its operations in accordance with the regulations 

prescribed by the Department of Transportation for the services authorized by this certificate, 

and with such other reasonable terms, conditions, and limitations as the Department of 

Transportation may prescribe in the public interest.
2

(4) The holder's authority under this certificate is effective only to the extent that such 

operations are also authorized by the Federal Aviation Administration (FAA), and comply with 

all U.S. Government requirements concerning security, including, but not limited to 49 CFR Part 

1544.



(5) The holder shall at all times remain a "Citizen of the United States" as required by 49 

U.S.C. 40102(a)(15).

(6) The holder shall maintain in effect liability insurance coverage as required under 14 

CFR Part 205. Failure to maintain such insurance coverage will render a certificate ineffective, 

and this or other failure to comply with the provisions of Subtitle VII of Title 49 of the United 

States Code or the Department's regulations shall be sufficient grounds to revoke this certificate.

(7) The holder is not authorized to engage in air transportation operations between points 

within the State of Alaska.

(8) Should the holder propose any substantial change in its ownership, management, or 

operations (as defined in 14 CFR 204.2(l)), it must first comply with the requirements of 14 CFR 

204.5.

(9) In the event that the holder does not commence actual flying operations under this 

certificate within one year of the date of the Department's determination of its fitness, its 

authority shall be revoked for dormancy, unless the holder is conducting operations under 

another type of certificate authority. Further, in the event that the holder commences operations 

for which it was found "fit, willing, and able" and subsequently ceases all such operations, its 

authority under all certificates held shall be suspended under the terms of 14 CFR 204.7 and the 

holder may neither recommence nor advertise such operations unless its fitness to do so has been 

redetermined by the Department. Moreover, if the holder does not resume operations within one 

year of its cessation, its authority shall be revoked for dormancy.

 



To assure compliance with all applicable U.S. Government requirements concerning security, the holder shall, 

before commencing any new service (including charter flights) to or from a foreign airport, contact its Principal 

Security Inspector (PSI) to advise the PSI of its plans and to find out whether the Transportation Security 

Administration has determined that security is adequate to allow such airport(s) to be served.
Attachment

Specimen

Terms, Conditions, and Limitations

NATIONAL AIR CARGO GROUP, INC.

d/b/a NATIONAL AIRLINES

is authorized to engage in foreign charter air transportation of persons, property, and mail: 

Between any place in the United States and any place outside thereof.

This authority is subject to the following provisions:

(1) The authority to conduct cargo charter air transportation under this certificate became 

effective on December 21, 2006. The authority to conduct passenger charter air transportation 

under this certificate will not become effective until six (business) days after the Department has 

received the following documents; provided, however, that the Department may stay the 

effectiveness of this authority at any time prior to that date:

(a) A copy of the holder's Air Carrier Certificate and Operations Specifications 

authorizing such operations from the Federal Aviation Administration (FAA).

(b) A certificate of insurance on OST Form 6410 evidencing liability insurance 

coverage meeting the requirements of 14 CFR 205.5(b) for all of its aircraft.

(c) A statement of any changes the holder has undergone in its ownership, key 

personnel, operating plans, financial posture, or compliance history, since the date of the 

Show Cause Order in this case.

(d) A revised list of pre-operating expenses already paid and those remaining to be 

paid, as well as independent verification that the holder has available to it funds 

sufficient to cover any remaining pre-operating expenses and to provide a working 

capital reserve equal to the operating costs that would be incurred in three months of 

operations.

(2) Pending receipt of effective authority, the holder may not accept payment of any kind 

(i.e., cash, check, or credit card), issue tickets for the operations proposed under this certificate, 

or enter into contracts with charter operators, and any advertisement by the holder must 

prominently state: "This service is subject to receipt of government operating authority." 

(3) The holder shall at all times conduct its operations in accordance with the regulations 

prescribed by the Department of Transportation for the services authorized by this certificate, 

and with such other reasonable terms, conditions, and limitations as the Department of 

Transportation may prescribe in the public interest.
2

(4) The holder shall at all times conduct its operations in accordance with all treaties and 

agreements between the United States and other countries, and the exercise of the privileges 

granted by this certificate is subject to compliance with such treaties and agreements and with 

any orders of the Department of Transportation issued under them or for the purpose of 

requiring compliance with them.

(5) The exercise of the authority granted here is subject to the holder's first obtaining from 

the appropriate foreign governments such operating rights as may be necessary.

(6) The holder's authority under this certificate is effective only to the extent that such 

operations are also authorized by the Federal Aviation Administration (FAA), and comply with 

all U.S. Government requirements concerning security, including, but not limited to 49 CFR Part 

1544.

(7) The holder shall at all times remain a "Citizen of the United States" as required by 49 

U.S.C. 40102(a)(15).

(8) The holder shall maintain in effect liability insurance coverage as required under 14 

CFR Part 205. Failure to maintain such insurance coverage will render a certificate ineffective, 

and this or other failure to comply with the provisions of Subtitle VII of Title 49 of the United 

States Code or the Department's regulations shall be sufficient grounds to revoke this certificate.

(9) Should the holder propose any substantial change in its ownership, management, or 

operations (as defined in 14 CFR 204.2(l)), it must first comply with the requirements of 14 CFR 

204.5.

(10) In the event that the holder does not commence actual flying operations under this 

certificate within one year of the date of the Department's determination of its fitness, its 

authority shall be revoked for dormancy, unless the holder is conducting operations under 

another type of certificate authority. Further, in the event that the holder commences operations 

for which it was found "fit, willing, and able" and subsequently ceases all such operations, its 

authority under all certificates held shall be suspended under the terms of 14 CFR 204.7 and the 

holder may neither recommence nor advertise such operations unless its fitness to do so has been 

redetermined by the Department. Moreover, if the holder does not resume operations within one 

year of its cessation, its authority shall be revoked for dormancy.

 



To assure compliance with all applicable U.S. Government requirements concerning security, the holder shall, 

before commencing any new service (including charter flights) to or from a foreign airport, contact its Principal 

Security Inspector (PSI) to advise the PSI of its plans and to find out whether the Transportation Security 

Administration has determined that security is adequate to allow such airport(s) to be served.
Attachment A

SERVICE LIST FOR NATIONAL AIRLINES

JAMES L HOBSON JR

PRESIDENT AND CEO

AIR TRANSPORT INTERNATIONAL LLC

2800 CANTRELL ROAD

LITTLE ROCK ARKANSAS 72202

GEORGE A GOLDER ESQ

GENERAL COUNSEL

AIR TRANSPORT INTERNATIONAL LLC

7100 TPC DRIVE SUITE 100

ORLANDO FLORIDA 32822

MARK W ATWOOD

ELIZEBETH J WADSWORTH

COZEN O’ CONNER

1627 EYE STREET NW SUITE 1100

WASHINGTON DC 20006

BERNARD STANKUS RTS-42

OFFICE OF AIRLINE INFORMATION

DOT/RSPA/BTS E-36

1200 NEW JERSEY AVE SE

WASHINGTON DC 20590

WILLIAM J WEBER

CERTIFICATION SECTION MANAGER

FAA AFS-900

45005 AVIATION DRIVE, SUITE 131

DULLES VA 20166

CLAY MORITZ, RTS-42

OFFICE OF AIRLINE INFORMATION

DOT/RSPA/BTS E-36

1200 NEW JERSEY AVE SE

WASHINGTON DC 20590

PETER LYNCH AGC-300

ASST CHIEF COUNSEL FOR 

ENFORCEMENT

FEDERAL AVIATION ADMINISTRATION

800 INDEPENDENCE AVE SW

WASHINGTON DC 20591

MALCOLM L BENGE

ZUCKERT, SCOUTT & RASENBERGER LLP

888 7TH STREET NW SUITE 700

WASHINGTON DC

TIM WAHLBERG

PRESIDENT

EVERGREEN INTERNAITONAL AIRLINES INC

3850 THREE MILE LANE

MCMINNVILLE OREGAN 97128

EDWARD W SAUER

SQUIRE SANDERS & DEMPSEY LLP

1201 PENNSYLVANIA AVE NW 

SUITE 500

WASHINGTO DC 20004