O rder 2012

- 7

- 21

Served: July 17 , 2012

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY WASHINGTON, D.C.

Issued by the Department of Transportation

on the 17 th day of July, 2012

Fitness Determination of

STAR MARIANAS AIR, INC.

as a commuter air carrier under section 49 U.S.C. § 41738 Docket DOT

- OST

- 2010

- 0235

ORDER TO SHOW CAUSE

P ROPOSING ISSUANCE OF COMMUTER AIR CARRIER AUTHORITY

Summary

By this order, we tentatively find that Star Marianas Air, Inc. (“Star ”)

, is a citizen of the United States and is fit, willing, and able to conduct scheduled passenger operations as a commuter air carrier, subject to conditions.

Background

Section 41738 of Title 49 of the United States Code (“the Transportation Code”) and section 298.21(d) of the Department’s Aviation Economic Regulations (14 CFR 298.21(d)) direct us to determine whether companies proposing to provide scheduled passenger service as commuter air carriers are “fit, willing, and able to perform the service,” a nd to ensure that all operations relating to this service conform to the safety standards established by the Federal Aviation Administration ( “ FAA ” ). In making fitness findings, the Department uses a three

- part test that reconciles the Airline Deregulatio n 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 n air carrier’s fitness are whether the applicant: (1) will have the managerial

sk ills and technical ability to conduct the proposed operations, (2) has sufficient financial resources to commence the operations proposed without posing an undue risk to consumers or their funds, and (3) will comply with the Transportation Code and regulat ions imposed by federal and state agencies. We must also determine that the applicant is a U.S. citizen.

O n September 8, 2010

, Star

, an on

- demand air taxi operator holding a Part 135 Federal Aviation Regulation (“FAR”) operating certificate from the FA A and serving the Commonwealth of the Northern Marianas Islands (“CNMI”) , filed an applica tion in Docket DOT

- OST

- 2010

- 0235 for authority to conduct scheduled passenger operations as a commuter air carrier. The air carrier accompanied its application with fitness information required by section 204.3 of our regulations and supplemented its application with additional info rmation on April 5, May 12, May 30

, June

U N I T E D S

T A T E S O F A

M E R I C A D E P A R T M E N T O F T R A N S P O R T A T

I O N2

27

, July 19, and October 13, 2011 . Star also provid ed information on February 1, March 8, and June 11, 2012.

No a nswers opposing Star ’s application were filed and no special issues regarding the applicant have come to our attention. Under these circumstances, we propose to decide the issue of the applicant’s fitness on the basis of the written r ecord, and we tentativel y conclude that Star is a U.S. citizen and is fit, willing, and able to provide scheduled passenger operations as a commuter

air carrier. However, we will give interested persons an opportunity to show cause why we should not adopt as final these tentative findings and conclusions.

FITNESS

The Company

Star was incorporate d under the laws of the CNMI in August 2007 and began on

- demand air

s ervice be tween the CNMI islands of Saipan and Tinia n in April 2009. Ownership of Star is held equally by Mr. Shaun R. Christian and Ms. Paz L. Christian, both of whom are U.S. citizens. Currently, Star provides air transportation from Saipan to Tinia n , mainly for clients and employees of the Tinian Dynasty Hotel and Casino (“Tinian Dynasty”)

. The Tinian Dynasty is Star’s main customer, responsible for appro ximately 90 percent of its revenues. Star also provides cargo flights to Guam and Rota. I f granted the commuter authority it seeks, the applicant intends to prov ide scheduled service between Saipan and Tinian

. Star is headquartered on Tinian, and operates a fleet of 7 Piper PA32 aircraft, each configured with 6 seats.

Managerial Competence

Star ’s management and key technical personnel consist of the following i ndividuals.

Ms. Paz L. Christian

– President , Secretary, Treasurer

Mr. Shaun R. Christian

– Executive Vice President , Board Member

Mr. Robert F. Christian

- Director of Operations

, Board Member 1

Mr. James E. Bell

- Chief Pilot

Mr. Manuel M. Gabor

- Director of Maintenance

Ms. Paz L. Christian has been Star ’s President since April 1, 2012. She previously served as

Star’s Executive Vice President (April 2009

- March 2012). She is also an assistant to the President of CCI Corporation (April 2008

- present). Previously, Ms. Christian was employed by Wells Fargo Insurance Services as an Accounting Manager (May 2007

- March 2008) and has

also worked for Pacific Internation al Holdings, Inc., an aviation consulting firm (‘PIH”) (1998

- 2005), and for Pacific Island Aviation, Inc., as an Executive Vice President (1998

- 2005) and Chief Financial Officer (“CFO”) (1992

- 1998). Ms. Christian was also a Deputy Director with

Caucasus A irlines (2001

- 2005); a Senior Accountant with PASIPIKO Incorporated (1989

- 1992);

1 Ms. Paz L. Christian and Mr. Robert F. Christian are married. Mr. Shaun R. Christian is Mr. Robert F.

Christian’s son.3

and an Accountant with AYA Marketing and Promotion (1987

- 1989). Ms. Christian is a

Certified Public Accountant and a U.S. citizen.

Mr. Shaun R. Christian has been Star’s Exe c utive Vice President since April 1, 2012. He had previously served as Star ’s President ( December 2009

- March 2012)

. Other previous aviation experience includes positions as a Commercial Airline Sales Manager with Fatigue Technology Inc. (August 2006

- December 2009); an Aviation Consultant with PIH (December 2000

- July 2006); and a Procurement Manager/Quality Auditor with Pacif ic Island Aviation, Inc. (August

1996

- December 2000). A U.S. c itizen, Mr. Christian also served as the temporar y President of Taga Air Charter Services , Inc. (“Taga Air”) (Fe bruary 2008

- March 2008) and is a licensed Airframe and Powerplant Mechanic.

Mr. Robert F. Christian

, Director of Operations for Star

, has over 30 years of e xperience in airline operations. He is the founder

, and member of the Board of Directors of Star (April 2009

- present) and also the President of CCI Worldwide, a consulting firm (April 1995

- present). Mr. Christian previously was a senior aviation consultant to the Kurdistan regional government ( February 2005

- February 2007); the President and Chief E xecutive O fficer (“CEO”) of PIH (1996

- 2007); President o f Pacifi c Internatio nal Travel Services (1995

- 2005); President, CEO, and Director of Flight Operations for Pacific Island Aviation (1988

- 2005) ; CFO o f Majestic Airlines (1986

- 1988); Vice President/Ge neral Manager of Maui Airlines (1984

- 1986); General Manager of P rinceville Ai rlines (1979

- 1984); Adj un c t Facility Member and Instructor at Embry

Riddle Aero nautical University ( 2007

- present and 1982

- 19 84 ); and the General Manager of

Hickham/Wheeler Aero Club (1977

- 1979)

. Mr. Christian is a licensed Airline Transport Pilot

and certificated Flight Instruct or and is type rated on Embraer

- 110 and

- 120 aircraft. He is a U.S.

citizen.

Star ’s Ch ief Pilot, Mr. James E. Bell , ha s held this position since August 2009. Previously

, he

was a L ine P ilot for Star ( April 2009

- August 2009), T inian Dynasty (October 2008

- March 2009) , Slickrock Air Guides (May 200 8

- September 2008), Mokulele Airlines ( February 2 008

- April 2008), Taga Air (June 2007

- Octo ber 2007), and Fre edom Air (April 2006

- May 2007). Mr.

Bell is a licensed Commer c i al Pilot and a U.S. citizen.

Mr. Manuel M. Gabor

, is the Director of Maintenance for Star ( April 2009

- present) and is a

licensed Air frame and Powerplant Mechanic. He previously was employed as an Airframe and Powerplant Mechanic for Taga Air (June 2005

- April 2009) and for Pacific Island Aviation Inc. (February 1995

- June 2005). He also was employed as an Aircraft Sheet M etal Mechanic and Mechanic Helper with Special Flight Services/Saudi Arabian Airlines (July 1991

- July 1994), and

as an Airframe and Powe rplant Ground Instructor at PATTS College of Aeronautics (1983

- 1991). Mr. Gabor is a citizen of the Philippines.

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

conclude that Star has dem onstrated that its key management and technical personnel have the managerial skills and technical ability to support its proposed operations . Moreover

, the FAA4

has advised us that all of the applicant’s key personnel have been found qualified to hold their respective position s. 2

Operating Proposal and Financial Plan

As previously mentioned, Star is currently operating as an on

- demand air taxi and has now requested commuter authority to conduct scheduled operation s between the islan ds of Tinian and Saipan. If granted the commuter authority it seeks, Star intends to continue to ferry customers to

and from the Tinian Dynasty, but i nstead of operating an empty aircraft on a return leg, the air

carrier proposes to provide a schedule for return flights. 3 Star al so states that, in providing a schedule, it hopes to diversify its customer base. The air carrier submitted a plan for its first year of scheduled oper ations, f orecasting

, on average
, 8 scheduled one

- way flights per day between Tinian and Saipan

. Star int ends to perform its proposed schedule with its existing fleet of 7 Piper

Cherokee aircraft

.

In establishing financial fitness, the Department typically asks an applicant to demonstrate that it has access to financial resources sufficient to cover its p re

- operating expenses and any negative working capital balance, plus a working capital reserve equal to the operating costs that are reasonably projected to be incurred during three months of “normal” operations. Because projected expenses during the firs t several months of air service frequently do not include all costs that will be incurred during a “normal” period of operations, it is our practice to base our

three

- month test on one

- quarter of the first year’s operating costs. Further, in calculating

a vailable resources, projected revenues may not be used.

Financial statements submitted in support of Star ’s fitness for the year ended December 31, 2011, show the air carr ier earned net income of $311,984 on revenues of $3.36 million

. Star’s

historic financial statements show net profits of $191,068 and $ 273,346 for calendar years 2009

and 2010

, respectively. The applicant’s balance sheet at December 31, 2011 , shows that the company has current assets and current liabilities of $767,004 and $487,242

, respectively, indicating posi tive working capital of $279,762 a nd a current ratio of 1:1.5 ( that is, for eve ry dollar owed on December 31, 2011 , pa yable within 12 months, Star had $1.57 with which to pay it)

.

Star provided forecasts for its pre

- operating costs and first year revenues and expenses associated with its proposed commuter operations. The air carrier states that the one

- time cost of gaining FAA and DOT approvals for commuter operations is $6,152, which has already been paid. Star projects its first year expenses will total approximately $2.19 million

. Based on this forecast, we estimate that it will require about $548,139 to meet our financial fitness criteria

. 4

2 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 mi nimum qualifications for those positions as prescribed in the FARs. The FAA’s evaluation of these key personnel provides an added practical and in

- person test of the skills and technical ability of these individuals.

3 According to the applicant, most of the flights being chartered are for one

- way service and therefore, Sta r has open seats on reposition ing flights that can be used for individual seat sales.

4 The $548,139 noted here is one

- quarter of the applican t’s forecast of approximately $2.19 million in first year

expenses.5

In support of its financial fitness, t he air carri er provided bank statements from the Bank of Saipan, First Hawaiian Bank, and Bank of Guam that show as of June 2012

, Star has $663,461

available in its name.

We have reviewed the forecast and financial statements provided by Star and find them to be

reasonable.

In light of the above

, we tentatively conclude that Star will have access to sufficient financial

resources to enable it to commence the proposed operations without posing an undue risk to

consumers or their funds

. 5

Compliance Disposition

The applicant states that there are no actions or outstanding judgments against it, persons holding a substantial interest in it, or its key personnel, and that none of these parties have been the subject of any charges of unfair, deceptive or anti

- competitive business practices, or of fraud, felony or antitrust violations, or other legal action during the past ten years. The air carrier al so stated that there are no pending investigations, enforcement actions, or formal complaints involving the applicant, persons holdi ng a substantial interest in it, or its key personnel with respect to compliance with the Statute or the Department’s regulations.

The FAA advises us that it is working with Star in connection with the applicant's efforts to

obtain commuter operating aut hority from that agency, and it knows of no reason why we should act unfavorably on the company’s commuter application. Additionally, our review of FAA

records indicates that Star has not been involved in any accidents or incidents since it i nitially commenced operations.

In light of these circumstances, we tent atively conclude that Star 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 authority 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 requires 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 voting interest be owned by U.S. citizens,

and that t he air carrier must be under the actual control of U.S. citizens.

As noted earlier, Star was incorporated under the laws of the CNMI in August 2007

. Ownership

of Star is shared equally by Mr. Shaun Christian and Ms. Paz Christian

, 6 both o f whom are U.S.

5 As is our practice, prior to making any authority awarded to Star effective, we will require the company to

demonstrate that it continues to have the financial resources needed to meet our financial fitness criteria.6

citizens and sit o n the air carrier’s Board of Directors

. Additionally

, Star ’s key personnel , with the exception of it s Director of Maintenance, are U.S. citizens and the company has provided an affidavit attesting that it is a citizen of the United States within the meaning of the Statute. O ur review of the applicant’s citizenship has uncovered no reason to suggest that c ontrol of Star rests
with non

- U.S. citizens.

I n light of the foregoing, we tentatively find that Star is owned and actually controlled by U.S. citizens, consistent with 49 U.S.C. § 40102(a)(15) and is fit, willing, and able to provide the proposed commuter operations, subject to conditions

.

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 application and points at issue an d 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 de cisional 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 decision al 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 Star ’s fitness and commuter

authorization

.

EFFECTIVE COMMUTER CONDITIONS & LIMITATIONS

If Star is found fit and issue d the commuter authority it seeks, its authority will not become effective until the company has fulfilled all requirements for effectiveness as set forth in the

terms and condit ions attached to its commuter authorization . Among other things, this includes our receipt of evidenc e that Star has been cert ified by the FAA to engage in the subject operations, a fully executed OST Form 6410 evidencing liability insurance coverage that meets the requirements of section 205.5(b) of our rules for all of its aircraft, third

- party verifica tion of available funding necessary to meet the Department’s fitness requirements, and a statement of changes it may have undergone since its fitness was examined.

In addition, consistent with the applicant’s proposed operations, we propose to limit any authority issued to Star to operations using aircraft that can be operated under FAR Part 135 (that is, aircraft with no more than 9 seats in scheduled passenger operations). Should Star desire to acquire and operate larger aircraft that would require ce rtification from the FAA under 14 CFR Part 121, our fitness findings might no longer apply. Therefore, should Star desire to operate aircraft that would require certification from the FAA under Part 121, it must first provide the

6 M r. Christian and Ms. Christian own 10,000 shares each of Star ’s stock. There are no other shareholders in the

air carrier.7

Department with at least 45 days advance notice of such plans and provide updated information establishing its fitness for such expansion.

Furthermore, we remind Star of the requirements of 49 U.S.C. § 41110(e). Specifically, that section requires that, once a n air carrier is f ound fit initially, it must remain fit in order to hold its authority. To be assured that commuter air carriers continue to be fit after effective authority has been issued to them, we require that they supply information describing any subsequent

substan tial changes they may undergo in areas affecting fitness. Therefore, if Star is issued an effective commuter authorization and should it subsequently propose substantial changes in its ownership, management, or operations, it must first comply with the requirements of section

204.5 of our rules. 7 The compliance of the company with this requirement is essential if we are to carry out our responsibilities under section 41110(e)

. 8

Additionally, if the air carrier is granted effective authority, it would be required to submit a

detailed progress report, within 45 days foll owing the end of its first year o f commuter flight operations, to the Air Carrier Fitness Division. The submission of a first year progress report is conditioned upon all newly authorized 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

Star ’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 i t anticipates from its current operations during its second year,
current financial statements, 9 and a listing of current senior management and key technical personnel. 10 The air carrier should also be prepared to meet with staff members of the Fitness

Div ision to discuss its current and future operations.

ACCORDINGLY,

1. We direct all interested persons to show cause why we should not issue an order finding

that Star Marianas Air, Inc.

, is fit, willing, and able under 49 U.S.C. § 41738 to provide

7 Star may contact our Air Carrier Fitness Division to report proposed substantial changes in its operations, ownership, or managem ent, 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 , restructurin g, or recapitalization. If Star 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 commuter authority.

8 We also remind Star about the requirements of section 204.7 of our rules. This section provides, among other things, that (1) the commuter 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 operation s 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.

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

commuter flight operations and a 12

- month income statement ending that same date.

10 If the air carrier has hired or replaced any of the senior management and key technical personnel since being found fit, a resume for such person or people should be included in the First Year Report.8

scheduled passenger service as a commuter air carrier using small aircraft pursuant to Part 135 of the Federal Aviation Regulations.

2. We direct any interested persons having objections to the issuance of an order making final any of the proposed findin gs, conclusions, or award of authority set forth here to file them with Department of Transportation Dockets, 1200 New Jersey Avenue, SE, Washington, D.C. 20590, in Docket DOT

- OST

- 2010

- 0235 and serve them upon all persons listed in Attachment A

no later th an 14 days after the service date of this order; answers to objections shall be filed no later than 7 days thereafter.

3. If timely and properly supported objections are filed, we will accord full consideration to the matters or issues raised by the objec tions before we take further action. 11

4. In the event that no objections are filed, we will consider all further procedural steps to be waived and we will enter an order making final our tentative findings and conclusions.

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

6. We will publish a summary 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

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

reconsideration.

### Attachment

SPECIMEN 

### Terms, Conditions, and Limitations

STAR MARIANAS AIR, INC.

is authorized to engage in scheduled passenger air transportation operations as a commuter air

carrier.

This authority is subject to the following provisions:

(1) The authority to conduct scheduled passenger operations 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 an y 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

i nsurance 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 th e 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 expens es 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) or issue tickets for scheduled passenger operations, and any advertisement or listing of flights 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 ope rations in accordance with the requirements of 14 CFR Part 298 and any other regulations prescribed by the Department of Transportation for the services authorized here, and with such other reasonable terms, conditions, and limitations as the Department of Transportation may prescribe in the public interest.

(4) The holder’s authority is limited to operations conducted pursuant to Part 135 of the Federal Aviation Regulations. In the event that the holder wishes to institute operations that would require Part 121 certification from the FAA, it must first be determined fit for such operations.2

(5 ) 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 li mited to 49 CFR Part

1544

. ∗

(6 ) The holder shall at all times remain a "Citizen of the United States" as required by 49 U.S.C. 40102(a)(15).

(7

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

CFR Part 205. Failure to maintain such insurance coverage will render this authority 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 authority.

( 8 ) In the event that the holder receives effective scheduled passenger authority, the following additional conditions will apply:

(a) The holder may reduce or terminate service at any point or between any two points, subject to complianc e with the provisions of 49 U.S.C. 41734 and all orders and regulations issued by the Department of Transportation under that

section.

(b) The holder may not provide scheduled passenger air transportation to or from Dallas (Love Field), Texas, except with in the limits set forth in section 29 of the International Air Transportation Competition Act of 1979, as amended by section 337 of the Department of Transportation and Related Agencies Appropriations Act, 1998.

( 9 ) Should the holder propose any substant ial changes in its ownership, management, or operations (as that term is defined in 14 CFR 204.2(l)), it must first comply with the requirements of 14 CFR 204.5.

(1 0 ) In the event that the holder does not commence actual flying operations as a commuter

ai r carrier under this authority within one year of the date of the Department's determination of its fitness, its commuter authority shall be revoked for dormancy. Further, in the event that the holder commences but subsequently ceases all scheduled passen ger operations, the authority granted here 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 such operations within one year of its cessation, its commuter 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 fore ign 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 STAR MARIANAS AIR , INC.

MR SHAUN CHRISTIAN

MS PAZ CHRISTIAN

STAR MARIANAS INC

PO BOX 520461

TINIAN MP 96952 OFFICE OF AIRLINE INFORMATION

DOT/RSPA/BTS E

- 36

1200 NEW JERSEY AVE SE

WASHINGTON DC 20590 MR THOMAS BREHM

POI FOR STAR MARIANAS INC

135 NAKOLO PLACE

HONOLULU HI 96819

MR PETER LYNCH AGC

- 300

FAA ASST CHIEF COUNSEL

FOR ENFORCEMENT

800 INDEPENDENCE AVE SW

WASHINGTON DC 20591 REGIONAL COUNSEL

FAA

PO BOX 92007

LOS ANGELES CA 90009

- 2007 MR WILLIAM J WEBER

CERTIFICATION SECTION

MANAGER

FAA AFS

- 900

45005 AVIATION DRIVE SUITE 131

DULLES VA 20166

COMMONWEALTH PORTS

AUTHORITY

SAIPAN INTERNATIONAL AIRPORT

SAIPAN NORTHERN MARIANAS

ISLANDS