U. S. Department 

of Transportation 

Federal Aviation 

Administration 

DEC 14 Z01Z 

Alaskan Region 

Office of the Kc!Humu C!ritiris~r;. 

CERTIFiED MAIL-RETURN RECEIPT REQUESTED . 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

Re: In the Matter of Grant Aviation, Inc., FDrOS ~ l 

Case No. 2011AL030075 0\,ol a, -l ""-~ 

222 W. 7th Avenue # 14 

· Anchorage, Alaska 

99513-7587 

PH: (907) 271-5271 

FAX: (907) 271-2800 

qECEIVED 

DEC 1 9 2012 

HEARING DOCKET 

DearSirorMadam: ~DI3 -f\t.UA • C.ff)·ll.«o"7b 

On November 29, 2012, we were notified that Grant Aviation, Inc., requested a hearing in the abovereferenced case. 

Enclosed are the original and one copy of the Complaint in the above-referenced proceeding as required 

by§ 13.208(a) of the Rules of Practice in FAA Civil Penalty Actions, 14 C.P.R. Part 13, Subpart G. By 

copy of this letter, a copy of the Complaint is being served on Respondent as required by§ 13.208(b). · 

The FAA requests that the hearing in this matter be held in Anchorage, Alaska, and expects that the 

hearing will last no more than one day. ' 

HOWARD L. MARTIN, JR. 

Regional Counsel 

~y: 2f1(i___ 

Glenn H. Brown 

Senior Attorney 

Enclosures 

cc: Brent R. Cole, Esq. 

(with copy of FAR 13.16 and Subpart G of Part 13) 
In the Matter of: 

Grant Aviation, Inc. 

Judge Not Assigned 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

DEC 1 9 2012 

HEARING DOCKET 

FAA Docket No. Unassigned 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.P.R.§ 13.208), and states as follows: 

I. 

On March 23, 2012, Respondent was advised through a Notice of Proposed Civil Penalty 

that the FAA proposed to assess a civil penalty in the amount of$50,000. On November 

16, 2012, Respondent was advised through a Final Notice of Proposed Civil Penalty that the 

FAA proposed to assess a civil penalty in the amount of$25,000. On November 28,2012, 

Respondent submitted a written request for a hearing. 

II. 

1. Respondent is now, and at all times mentioned herein it was, the holder of Air Carrier 

Certificate No. ENHA618D and appropriate operations specifications authorizing it to 

conduct commuter operations under parts 119 and 13 5 of the Federal Aviation Regulations 

(FAR). 

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2. At all times referenced herein, Respondent was authorized by its operations specifications 

to operate civil aircraft N417PM, a Piper Model PA-31-350, in its operations under parts 119 

and 135 ofthe FAR, and was required by its operations specifications to inspect the aircraft 

in accordance with the approved aircraft inspection program (AAIP). 

3. At all times referenced herein, Airworthiness Directive (AD) 2009-13-06 was applicable 

to civil aircraft N417PM, and required an inspection of the nose baggage door latch and lock 

components every 100 hours oftime in service, the replacement of life-limited parts every 

1 000 hours of time in service, and the repair and replacement of damaged, worn, corroded, or 

non-conforming components in accordance with Piper Service Bulletin 1194A before further 

flight. 

4. On or about April 27, 2011, Respondent performed maintenance on civil aircraft 

N417PM, and made an entry in the maintenance records regarding the work performed and 

approving that work for return to service. 

5. The maintenance referenced in paragraph 4 inc~uded the replacement of the nose baggage 

door and the latch components. 

6. While performing the maintenance referenced in paragraph 5, Respondent failed to use 

acceptable methods, techniques, and practices in that the door handle bracket Respondent 

installed had bent tabs and was corroded, a clevis pin was installed upside down, a large 

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washer not shown in the drawings in Piper Service Bulletin 1194A was installed under the 

lock, and one of three required bolts in the front hinge attachment point was not installed. 

7. The maintenance record entry referenced in paragraph 4 regarding the maintenance 

referenced in paragraph 5 does not indicate whether the latch components used in the 

installation were those that had been on the nose baggage door that was removed or the 

accumulated time in service of the life-limited components, and it indicates the work was 

done in accordance with an irrelevant part of an obsolete Piper Service Bulletin. 

8. On or about May 12, 2011, June 1, 2011, June 29, 2011, and July 2, 2011, Respondent 

performed maintenance on civil aircraft N417PM that included inspecting the nose baggage 

door latch and lock components, and then made entries in the maintenance records for the 

aircraft indicating that an inspection in accordance with AD 2009-13-06 had been performed 

and that no defects were found. 

9. At the time of the inspections referenced in paragraph 8, the nose baggage door latch and 

lock components were damaged, worn, corroded, non-conforming, and not in accordance 

with Piper Service Bulletin 1194A in that the door handle bracket had bent tabs and was 

corroded, a clevis pin was installed upside down, a large washer not shown in the drawings in 

Piper Service Bulletin 1194A was installed under the lock, and one of three required bolts in 

the front hinge attachment point was not installed. 

3 
10. During the period from May 27, 2011, to July 26, 2011, Respondent operated civil 

aircraft N417PM on divers flights in commerce for some 319 hours of time in service. 

11. Most of the flights referenced in paragraph 1 0 were subject to part 13 5 of the FAR. 

12. At the time ofthe flights referenced in paragraph 10, civil aircraft N417PM was not in 

airworthy condition because of the discrepancies referenced in paragraphs 6 and 9, and 

because the nose baggage door light and switch and the drain lines for the fuel pumps located 

in the wing roots were missing. 

13. The operation of civil aircraft N417PM as described above was careless or reckless so as 

to endanger the life or property of another. 

III. 

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

following Federal Aviation Regulations (FAR): 

(a) Section 43.9(a) in that Respondent maintained, performed preventive 

maintenance, rebuilt, or altered an aircraft, airframe, aircraft engine, propeller, appliance, 

or component part and failed to make an entry in the maintenance record of that 

equipment containing the information specified in this section. 

4 
(b) Section 43.13(a) in that Respondent performed maintenance, 

alteration, or preventive maintenance on an aircraft, engine, propeUer, or appliance and 

failed to use the methods, techniques, and practices prescribed in the current 

manufacturer's maintenance manual of Instructions for Continued Airworthiness 

prepared by it manufacturer, or other methods, techniques, and practices acceptable to the 

Administrator. 

(c) Section 91.7(a) in that Respondent operated a civil when it was not in 

an airworthy condition. 

(d) Section 19.13(a) in that Respondent operated an aircraft in a careless 

or reckless manner so as to enlarge the life or property of another. 

(e) Section 91.405( a) in that Respondent operated an aircraft and failed, 

between required inspections, to have discrep~cies repaired as prescribed in part 43 of 

the FAR. 

(f) Section 135.25(a)(2) in that Respondent operated an aircraft under part 

135 ofthe FAR when it was not in an airworthy condition. 

2. Pursuant to 49 U.S.C. § 46301(a) and 14 C.F. R. § 13.305, Respondent is subject to a 

civil penalty of$11,000 for each violation ofthe FAR. 

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' 

3. Under the facts and circumstances of this case, a civil penalty of$25,000 is 

appropriate. 

WHEREFORE, the Federal Aviation Administration, by counsel, respectfully requests 

that the administrative law judge enter an order that Respondent be assessed a civil penalty in the 

amount of $25,000. 

RESPECTFULLY SUBMITTED this ( tt -4\ of ,~ 0 I~ 

HOWARD L. MARTIN, JR. 

Regional Counsel 

By: 

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JflJl_~ Glenn H. Brown 

Senior Attorney 
CERTIFICATE OF SERVICE 

Re: Grant Aviation, Inc. 

FAA Case No. 2011AL030075 

FAA Docket No. To Be Assigned 

I hereby certify that on this date I served a copy of the FAA's Complaint and a copy of the 

foregoing letter by placing them in the United States Mail, postage-prepaid, certified mail, return 

receipt requested, addressed as follows: 

Brent R. Cole, Esq. 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

I further certify that on this date I have served the original of the foregoing letter and the original 

and one copy of the FAA's Complaint by postage-prepaid, certified mail, return receipt requested, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Office of the Regional Counse 

222 West 7th A venue # 14 

Anchorage, Alaska 99513-7587 

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