Order 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 17th 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

PROPOSING 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,” and 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 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 an air carrier’s fitness are whether the applicant: (1) will have the managerial 

skills 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 regulations imposed by 

federal and state agencies. We must also determine that the applicant is a U.S. citizen. 

On September 8, 2010, Star, an on-demand air taxi operator holding a Part 135 Federal Aviation 

Regulation (“FAR”) operating certificate from the FAA and serving the Commonwealth of the 

Northern Marianas Islands (“CNMI”), filed an application 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 information on April 5, May 12, May 30, June 

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION
2

27, July 19, and October 13, 2011. Star also provided information on February 1, March 8, and

June 11, 2012.

No answers 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 record, and we tentatively 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 incorporated under the laws of the CNMI in August 2007 and began on-demand air 

service between the CNMI islands of Saipan and Tinian 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 Tinian, mainly for clients and 

employees of the Tinian Dynasty Hotel and Casino (“Tinian Dynasty”). The Tinian Dynasty is 

Star’s main customer, responsible for approximately 90 percent of its revenues. Star also 

provides cargo flights to Guam and Rota. If granted the commuter authority it seeks, the 

applicant intends to provide 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 individuals. 

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 International 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 Airlines (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 Executive 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 Pacific Island Aviation, Inc. (August 

1996-December 2000). A U.S. citizen, Mr. Christian also served as the temporary President of 

Taga Air Charter Services, Inc. (“Taga Air”) (February 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 experience 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 Executive Officer (“CEO”) of PIH

(1996-2007); President of Pacific International Travel Services (1995-2005); President, CEO, 

and Director of Flight Operations for Pacific Island Aviation (1988-2005); CFO of Majestic 

Airlines (1986-1988); Vice President/General Manager of Maui Airlines (1984-1986); General 

Manager of Princeville Airlines (1979-1984); Adjunct Facility Member and Instructor at Embry 

Riddle Aeronautical University (2007-present and 1982-1984); and the General Manager of 

Hickham/Wheeler Aero Club (1977-1979). Mr. Christian is a licensed Airline Transport Pilot 

and certificated Flight Instructor and is type rated on Embraer-110 and-120 aircraft. He is a U.S. 

citizen.

Star’s Chief Pilot, Mr. James E. Bell, has held this position since August 2009. Previously, he 

was a Line Pilot for Star (April 2009-August 2009), Tinian Dynasty (October 2008-March 

2009), Slickrock Air Guides (May 2008-September 2008), Mokulele Airlines (February 2008-

April 2008), Taga Air (June 2007-October 2007), and Freedom Air (April 2006-May 2007). Mr. 

Bell is a licensed Commercial Pilot and a U.S. citizen. 

Mr. Manuel M. Gabor, is the Director of Maintenance for Star (April 2009-present) and is a 

licensed Airframe 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 Metal Mechanic and 

Mechanic Helper with Special Flight Services/Saudi Arabian Airlines (July 1991-July 1994), and 

as an Airframe and Powerplant 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 demonstrated that its key management and technical personnel have the 

managerial skills and technical ability to support its proposed operations. Moreover, the FAA 
4

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

respective positions. 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 operations between the islands 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 instead of operating an empty aircraft on a return leg, the air 

carrier proposes to provide a schedule for return flights.3 Star also 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 operations, forecasting, on average, 8 scheduled one-way flights per day between 

Tinian and Saipan. Star intends 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 pre-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 first 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 

available 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 carrier 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 positive working capital of $279,762 and a current ratio of 1:1.5 (that is, for every 

dollar owed on December 31, 2011, payable 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 minimum 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, Star has 

open seats on repositioning flights that can be used for individual seat sales. 

4 The $548,139 noted here is one-quarter of the applicant’s forecast of approximately $2.19 million in first year 

expenses.
5

In support of its financial fitness, the air carrier 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 also 

stated that there are no pending investigations, enforcement actions, or formal complaints 

involving the applicant, persons holding 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 authority 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 initially 

commenced operations. 

In light of these circumstances, we tentatively 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 the 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 of 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 on the air carrier’s Board of Directors. Additionally, Star’s key personnel, with 

the exception of its 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. Our 

review of the applicant’s citizenship has uncovered no reason to suggest that control of Star rests 

with non-U.S. citizens.

In 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 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 Star’s fitness and commuter 

authorization.

EFFECTIVE COMMUTER CONDITIONS & LIMITATIONS

If Star is found fit and issued 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 conditions attached to its commuter authorization. Among other things, this includes 

our receipt of evidence that Star has been certified 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 verification 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 certification 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 Mr. 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 an air carrier is found 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 

substantial 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 following the end of its first year of 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 it 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 

Division 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 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 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 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.

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 findings, 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 than 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 objections 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 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) 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 operations 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 limited 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 compliance 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 within 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 substantial 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.

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

air 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 passenger 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 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

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