02/27/2013 14:12 FAX 2024835142 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

FAA 

Southern Region 

Office of the Regional Counsel 

CERTIFIED- RETURN RECEIPT RE;QUESTED 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2W l 000 

Wilbur Wright Building 

800 Independence A venue, SW 

Washington, DC 20591 

Re: In the Matter of Worldwide Aircrail Services, Inc. 

FAA Case No.2009S0150216 

-!- OMS fdl 001/006 

P.O. Box 20636 

Atlanta, Georgia 30320 

(404) 305-5200 

(404) 305-5223 FAX 

Enclosed herewith please find a copy ()fa request for hearing and the original and one copy or 

the Complaint in the abuvc-rcfcrcnccd proceeding. 

The FAA requests that the hearing in this matter be held in the Orlando, Florida area, and 

expects that the hearing will last two days. 

Plem~e address all communications for the FAA to the undersigned, at: 

Federal Aviation Adminhstration 

Ot'l-lce of the Regional Counsel, AS0-7 

Southern Region 

P.O. Box 20636 

Atlanta, Georgia 30320 

Telephone: (404) 305-5200, facsimile (404) 305-5223. 

su~~u---

WILLIAM P. VINES 

Attol1ley 

Otlice of the Regional Counsel 

Enclosures 

RECEIVED 

fEB 2 5 2013 

HEARING DOCKET 
02/27/2013 14:12 FAX 2024835142 FAA ojo OMS 141002/008 

U.S. DEPARTMENT OF TRANSPORTATION 

OF.FICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

RFf'Ct\/~0 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

Worldwide Aircrall Services, Inc. 

Respondent. 

JUDGE NOT YET ASSIGNED 

FAA Docket No. 

Judge 

COMPLAINT 

FEB 2 5 2013 

HEARING DOCKET 

The Federal Aviation Administration (FAA), by co\msel, hereby t11es its Complaint, 

pursuant to Rule 208 ofthc Rules ofPractice (14 C.P.R. 13.208), and states as follows: 

I. 

1. On January 28, 2013, Respondent. Worldwide Aircraft Services, Inc. 

was advised through a Final Notice of Proposed Civil Penalty that the FAA proposed to assess a 

civil penalty in the amount of$12,375. On February 18, 2013, the Agency Attorney received a 

written request for a hearing from the Respondent. 

11. 

2. At all times material herein Respondent Worldwide Aircraft Services, Inc. 

(hereinafter "Worldwide") was and is now the holder or Air Carrier Certificate 

No. W50A880J .. 

Count 1 

3. On or about May 3, 2009, Worldwide operated civil aircraft N90LJ, a Lcarjct 

25D, on a flight from TDPD to MY AM (hereinafter "Plight''), under Part 135 of 

the Federal Aviation Regulations. 

4. Following the Flight, the flight crew learned that N90L.T's grom1d power unit 

(hereinafter "GPU") receptacle was damaged. 
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5. Worldwide's General Operations Manual, Section E-3, states the following: 

The Aircratl Discrepancy Form (MX-02) is a duplicate sheet. 

Upon the discovery of a mechanical discrepancy the Aircraft 

Discrepancy Fnnn will be cornpleted and left in the aircraft 

maintenance log. The person completing this l'onn will be 

expected to notify lhe Director of Maintenance immediately. A 

company appnwed mechanic will clear the discrepancy either hy 

deferring or repairing the item. The mechanic will then complete 

the Aircraft Discrepancy Form. The top (white) copy will become 

part of the aircraft permanent maintenance record and the bottom 

cardboard copy will remain with the aircraft for a minimum of 

thirty days. 

6. Worldwide's General Operations Manual, Section F-1, states the following: 

The pilot in command is required to report to the Director of 

Maintenance, in the space ·provided on the Aircraft Discrepancy 

Fom1 · (MX-02), any mechanical irregularities that come to the 

pilot's attention betbre, during, and after the completion of any 

flight. All entries must be accomplished be1ore the pilot in 

command releases the aircraft from a specitic flight. Before ~:ach 

flight. the pilot in conuna.nd wlll determine the status of each 

irregularity entered in the Aircran Discrepancy Form (MX-02) at 

the end or the preceding flight. A copy of this tbnn will remcin 

with the aircraft in the aircraft maintenance log (see E-1 ). 

7. Despite the flight crew's knowledge that N90LJ's GPU receptacle was damaged, 

the flight crew failed to document the discrepancy (on Aircraft Discrepancy Form 

MX-02) that came tn the flight crew's attention after the completion of the Flight. 

8. As a result of paragraph 6, Worldwide failed to ensure that Worldwide's flight 

personnel used Worldwide's General Operations Manual when conducting its 

operations. 

Count II 

9. On or about May 7, 2009, Brian Fanning, Worldwide's Chief of Maintenance, 

inspected N90LJ and found damage to a non-structural section of the fuselage 

skin aft of the GPU receptacle. 

10. After detecting the damage listed in paragraph 8, Worldwidtl deferred the damage 

1br repair at a later date. 

11. Worldwide failed to record the deferral action concerning the reported or 

observed failure or malfunction ufthe air1J:amc in the aircraft maintenance log. 
02/27/2013 14:13 FAX 2024935142 FAA -t OMS ~ 004/008 

Ill. 

12. By reason of the foregoing facts and circumstances, Respondent violated the 

following sections of the Federal Aviation Regulations: 

a. Section 135.21 (a) in that each certiticatc holder, other than one who uses only 

one pilot in the ccrtif1catc holder's operations, shall prepare and keep current a 

manual setting forth the certificate holder's procedures and policies acceptable 

to the Administrator. This manual must be used by the certificate holder's 

tlight, ground, and maintenance personnel in conducting its operations. 

However, the Administrator may authorize a deviation from this paragraph if 

the Administrator finds that, because of the limited size ofthe operation, all or 

part of the manual is nut necessary for guidance of flight, ground, or 

maintenance personnel. 

b. Section 135.65(c) in that each person who takes corrective action or defers 

action conceming a reported or observed failure or malfunction of an 

airframe, powerplant, propeller, rotor, or appliance, sha11 record the action 

taken in the aircraft maintenance log Ul'lder the applicable maintenance 

requirements of this chapter. 

Pursuant to 49 U.S.C. Sections 46301(a)-(d), Respt'mdent is subject to a civil penalty not 

to exceed$ 1 1 ,000 for each of the violations alleged. 

Under the litcts and circumshmce!:l ol"this case, a civil penalty of$12,375 is appropriate. 

WHEREFORE~ the Agency, by counsel respectfully requests that the Administrative Law 

Judge enter an ord9r that Respondent be assessed a civil penalty ln the amount of$12,375. 

Respectfully submitted this 3 or< day of February, 2013. 

LJJ--

WILLlAMP. VINES 

Attorney 

Office ofthc Regional Counsel 
02/27/2013 14:13 FAX 2024935142 FAA -t OMS Ill 005/008 

PLEASE NOTE: 

Pursuant to Title 14 CFR Section 13.209(a), you are required to f1le a written answer to this 

Complaint, or a written Motion to Dismiss if appropriate, not later than 30 days after the date 

shown on the Certificate of Service which follows. 

CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Complaint has been mailed this date by Certified 

Mail, Return Receipt Requested, to the following: 

Hearing Docket Clerk 

FAA, AGC-430, SuiLe 2WIOOO 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Worldwide Aircrafl Services, Inc. 

Michael A. Honeycutt, President 

c/o JET I.C.U. 

2561 Rescue Way 

Brooksville, l''lorida 34604 

i \ 

Legal Assistant 

FFP 2 0 7.013 ----~--- ----------- Dated 

(original+ 1 copy) 
02/27/2013 14:13 FAX 2024935142 

February 15, 2013 

Federal Aviation Administration 

Attn: llearing Dock(:! Clerk 

AGC-430 

800 Independence Av<..~rlm: SW 

Wilbur Wright Building 

Suite 2W1000 

Washington, DC 20591 

William Vines, Esquire 

Office of Regional Counsel 

Southern Region 

Federal i\ viatinn Adrnini~lration 

P.O. Rox 20636 

Atlanta. Ucurgia 30320 

FAA 

~ -_,..., -..... rJ ~ I I .. I..U. 

When experi€mce matters. 

2561 Rescue Way 

Rrooksville, fL 34604 

PII- 352-796-2540 I FX- 352-796-251J9 

~ OMS 

·- .. ····---

REQUEST FOlt HEARING ON FINAL NOTICE OF PROPOSED PF~NAL TY BY 

WORLDWIDE AIRCRAFT SERVICES, INC. 

141008/008 

Worldwide Aircran Services, Inc. responds to the Final Notice of Proposed Civil penalty and 

denies the allegations contained in tlll· letLer. As a result, Worldwide hereby reqvcsts a hearing on the 

Final Notil.:e as set forth in the Final Notice. 

P</•~1~4- . chacl Honcycu~t/ President 

Worldwide Aircran Services, Inc. 

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