U. S. Department 

of Transportation 

Federal Aviation 

Administration 

QEC 11.4 2.Qtt 

Alaskan Region - -- :, . _ 

Office of the Regional Counsei 

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 2Wl 000 

Re: In the Matter of Grant Aviation, Inc. 

222 W. 7thAvenue#l4 

Anchorage, Alaska 

99513-7587 

D!:·~g 

. ·~ .. PH: (907) 271-5271 

FAX: (907)271-2800 

RECEIVED 

DEC 1 9 2012 

HEARING DOCKET 

Cases Nos. 2011AL030031, 2011AL030046, 2011AL030047, 2011AL030055 & 2011AL030058 

a_ot3 -f\\.UA-c_,pp-\ 1"1 l..J~ ct 

Dear Sir or Madam: R\f\ ~mS ~, ~- , c;u&o 

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

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

by§ 13.208(a) of the Rules ofPractice 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 two days. 

HOWARD L. MARTIN, JR. 

Regional Counsel 

By: 2rlL 

Glenn H. Brown · 

Senior Attorney 

Enclosures 

cc: Brent R. Cole, Esq. 

(with copy ofFAR 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 

FAA Docket No. Unassigned 

RECE\VED 

DEC\ 920\1 

HEAR\NG DOCKET 

COMPLAINT 

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

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

I. 

On January 27, 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 $50,000. On November 28; 2012, 

Respondent submitted a written request for a hearing. 

II. GENERAL ALLEGATIONS 

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 135 of the Federal Aviation Regulations 

(FAR). 

1 
2. At all times referenced herein, Respondent was authorized by its operations specifications 

to operate, and did use in its operations under part~ 119 and 135 of the FAR, the following 

civil aircraft: 

Registration Make ·Model Model Name 

Number 

N207DF Cessna CE-207-A Stationair 8 

N2162C Cessna CE-207-A Stationair 8 

N6295H Cessna CE-207-A Stationair 7 

N6908M Cessna CE-207-A Stationair 8 

N7396U Cessna CE-207-A Stationair 7 

N9651M Cessna CE-207·-A Stationair 8 

N9728M Cessna CE-207-A Stationair 8 

N9874M· Cessna CE-207-A Stationair 8 

N9973M Cessna CE-207-A Stationair 8 

N207EX Cessna CE-207-207 Skywagon 

N207VA Cessna CE-207-207 Skywagon 

N48CF Cessna CE-207-T207A Skywagon 

N8NZ Cessna CE-207-T207A Stationair 7 

N162GA Cessna CE-208-B Caravan 

N207DR Cessna CE-208-B Caravan 

N208SM Cessna CE-208-B Caravan 

N25JA Cessna CE-208-B Caravan 

N454SF Cessna CE-208-B Caravan 

N804TH Cessna CE-208-B Caravan 

N27471 Piper PA-31-350 Navajo Chieftain 

N15PR Piper PA.;31-350 Navajo Chieftain 

N28KE Piper PA-31-350 Navajo Chieftain 

N4105D Piper PA-31-350 Navajo Chieftain 

N417PM Piper PA-31-350 Navajo Chieftain 

N77HV Piper PA-31-350 Navajo Chieftain 

N313HS Beech BE-200-200 King Air 

N90PB Beech BE-200-200 King Air 

3. At all time~ referenced herein, Respondent was required by its operations specifications to 

inspect the above aircraft in accordance with its Approved Aircraft Inspection Program 

(AAIP). 

2 
4. On or about November 5, 2010, at the request of Respondent, the Administrator approved 

a new AAIP for Respondent that substantially revised the AAIP it replaced. 

5. During the period March 7-24,2011, the aviation safety inspectors from the Anchorage 

Flight Standards DistriCt Office conducted a system safety special inspection of Respondent. 

6. Most of the flights referenced herein were subject to part 135 of the FAR. 

III. SPECIFIC ALLEGATIONS 

A.COUNTI 

(Case No. 2011AL030046) 

1. Beginning with the approval of the new AAIP as referenced in Section II, paragraph 4, 

Respondent was required by Chapter 1, Sections 12 & 13, of its AAIP to perform either an 

acceptance or complete inspection of each of the above aircraft, and then make entries in the 

daily aircraft log for each aircraft stating that the aircraft is now being inspected in 

accordance with the Respondent's Approved Aircraft Inspection Program, and further 

stating, "This aircraft has been inspected JJ AJW a Respondent Acceptance (or Complete) 

Inspection and was determined to be in airworthy condition." 

2. On or about the dates shown in the second column of the following chart, Respondent 

inspected the aircraft listed in the first column using an old, replaced AAIP, and from then 

·until the date shown in the third column, operated each aircraft on flights in air commerce for 

the hours of time in service shown in the fourth column when Respond~nt had not made the 

3 
el).try referenced in paragraph 1 and had not inspected the aircraft under the new and then 

current AAIP: 

Aircraft 1st AAIP Inspection Date Entered Into Time in Service 

After 11/5/10 New AAIP 

N207DF February 14, 2011 May 19,2011 432.4 hours 

N2162C December 17,2010 May 11,2011 286.9 hours 

N6295H November 16,2010 April9, 2011 368.3 hours 

N6908M November 16,2010 May 17,2011 439.8 hours 

N7396U December 22, 2010 May 19,2011 352.7 hours 

N9651M February 9, 2011 May 11,2011 078.9 hours 

N9728M December 23,2010 May 25,2011 304.1 hours 

N9874M December 14, 2010 May 12,2011 344.6 hours 

N9973M December 7, 2010 May 8, 2011 433.2 hours 

N207EX December 10, 2010 August 8, 2011 368.9 hours 

N207VA November 23, 2010 May 18,2011 083.7 hours 

N48CF January 11, 2011 May 13,2011 149.3 hours 

N8NZ January 2, 2011 May 14,2011 438.8 hours 

N162GA January 24, 2011 May 20,2011 275.0 hours 

N207DR November 11,2010 July 6, 2011 207.6 hours 

N208SM November 17,2010 May 20, 2011 · 689.1 hours 

N25JA December 4, 2010 May 21,2011 795.3 hours 

N454SF December 8, 2010 May 16,2011 509.3 hours 

N804TH December 14,2010 May 16,2011 653.2 hours 

N27471 December 2, 2010 May 21,2011 708.5 hours 

N15PR November 9, 2010 July 6, 2011 823.7 hours 

N28KE November 15,2010 April 22, 2011 498.5 hours 

N4105D November 11,2010 May 16,2011 309.9 hours 

N417PM December 5, 2010 April27, 2011 488.7 hours 

N77HV December 11,2010 June 6, 2011 239.6 hours 

N313HS February 3, 2011 May 24,2011 357.5 hours 

N90PB January 19, 2011 May 28,2011 175.2 hours 

3. At the time of the flights referenced in paragraph 2, each of the above aircraft was not in 

an airworthy condition because inspections required by the new AAIP were due but had not 

been performed. 

4 
4. On or about the dates indicated in the third column in the chart in paragraph 2, 

Respondent began inspecting civil aircraft N454SF, N208SM, N162GA, N804TH, and 

N25JA under the new AAIP when Respondent had not performed either an acceptance or 

complete inspection of the aircraft. 

5. On or about the dates indicated in paragraph 4, Respondent made entries in the daily 

aircraft logs for the following civil aircraft that did not fully comply with the requirements 

identified in paragraph 1 in one or more respects: N454SF, N208SM, N162GA, N804TH, 

N25JA, N8NZ, N48CF, N9651M, N2162C, N9973M, N417PM, N4105D, N313HS, and 

N90PB. 

6. The operation of the aircraft as described in paragraphs 1-5 was careless or reckless so as 

to endanger the life or property of another. 

Based on the foregoing facts and circumstances, Respondent violated the following Federal 

Aviation Regulations: · \ 

(a) Section 43.15(a)(2) in that Respondent performed an inspection provided for in part 

125, 135, or§ 91.409(e) ofthe FAR and failed to perform the inspection in accordance 

with the instructions and procedures set forth in the inspection program for the aircraft 

being inspected. 

(b) Section 91.7(a) in that Respondent operated a civil aircraft when it was not in an 

airworthy condition. 

5 
(c) Section 91.13(a) in that Respondent operated an aircraft in a careless or reckless 

manner so as to endanger the life or property of another. 

(d) Section 119.5(1) in that Respondent operated aircraft under part 135 of the FAR in 

violation of an air carrier operating certificate, operating certificate, or appropriate 

operations specifications issued under part 119 of the FAR. 

(e) Section 135.2(a)(2) in that Respondent operated an aircraft under part 135 ofthe FAR 

. when it was not in an airworthy condition. 

(f) Section 135.419(g) in that Respondent failed to have an aircraft subject to an 

approved aircraft inspection program inspected in accordance with that program. 

B. COUNT II 

(Case No. 2011AL030031) 

1. At all times referenced herein, the Airworthiness Limitations section of the 

manufacturer's maintenance manual for each of the Cessna Model CE-208-B aircraft 

operated by Respondent has required certain periodic inspections and the replacement of 

certain parts, and some of these are based on the number of land.ings each aircraft has 

accumulated. 

6 
2. During the years preceding the system safety inspection referenced in Section II, 

paragraph 5, Respondent did not count or keep track of the number of landings each aircraft 

was accumulating, and hence, did not maintain records, and at the time of the inspection did 

not have records, containing the current status of the parts with a life-limit based on the 

number of landings. 

3. During the time frame referenced in paragraph 2, Respondent attempted to track the due 

dates for the periodic inspections and replacements referenced in paragraph 1 using cycles 

rather than landings. 

4. At all times referenced herein, the Airworthiness Limitations section of the 

manufacturer's maintenance manual for each of the Cessna Model CE-208-B aircraft 

operated by Respondent required that Respondent determine the operating environment for 

each aircraft, and then make an airplane logbook entry that stated which inspection schedule 

(typical or severe) was being used. 

5. During the years preceding the system safety inspection referenced in Section II, 

paragraph 5, Respondent operated each of the Cessna Model CE-208-B aircraft listed above 

when the operating environment was known but Respondent had not made an airplane 

logbook entry that stated which inspection schedule (typi~al or severe) was being used. 

7 
6. Beginning with the approval of the new AAIP on November 5, 2010, Respondent was 

. . 

required by its AAIP to track and comply with some 36 of the maintenance tasks set forth in 

Chapter 5 of the manuf~cturer' s maintenance manual. 

7. For some of the maintenance tasks referenced in paragraph 6 and the inspections 

referenced in paragraph 1, the. interval depended on which inspection schedule (typical or 

severe) was b,eing used. 

8. At the time of the system safety inspection referenced in Section II, paragraph 5, 

Respondent was tracking the intervals referenced in paragraph 7 using the typical inspection 

schedule for civil aircraft N454SF, N208SM, N25JA, and N804TH when the inspection 

schedule for each of these aircraft should have been severe. 

9. At all times referenced herein, the interval for two of the inspections referenced in 

paragraph 1 and for one of the maintenance tasked referenced in paragraph 6 depended on 

the bolt size. 

10. At the time of the inspection referenced in Section II, paragraph 5, the records used by 

Respondent to keep track of when each inspection and maintenance task became due did not 

- include any information regarding the bolt size for the inspections and maintenance task 

referenced in paragraph 9. 

11. The periodic inspections referenced in paragraph 1 include the following: 

8 
Name Supplemental Inspection Intervals 

Inspection No. Typical Severe 

Fuselage to Strut 53-20-07 Initial at 10,000 hours; Initial at 5000 hours; repeat 

Attach Fittings and repeat every 2500 hours every 400 to 1200 hours 

Lugs depending on bolt size 

Center Flap Track 57-50-01 Initial at 15,000 landings; Initial at 15,000 landings; 

repeat every 3000 landings repeat every 3000 landings 

Inboard Flap Track 57-50-01 Initial at 15,000 landings; Initial at 15,000 landings; 

repeat every 3000 landings repeat every 3000 landings 

Outboard Flap Track 57-50-01 Initial at 15,000 landings; Initial at 15,000 landings; 

repeat every 3000 landings repeat every 3 000 landings 

12. At the time of the system safety inspections referenced in Section II, paragraph 5, 

Respondent had operated. civil aircraft N25JA on divers flights in air commerce for 4284.4 

hours when Supplemental Inspection Number 53-20-07 was due b~t had not been performed. 

13. At the time of the system safety inspection referenced in Section II, paragraph 5, 

Respondent had operated civil aircraft N208SM on flights in air commerce for at least 320.4 

hours when Supplemental Inspection Number 53-20-07 was due but had not been performed. 

14. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking when Supplemental Inspection Number 57-50-01 

was next due on civil aircraft N804TH incorrectly indicated it was due 15,000 cycles after 

the first inspection, and by that date Respondent had operated civil aircraft N804TH on 

flights in air commerce for at least 12 cycles when, even under the measure Respondent was 

using, Supplemental Inspection Number 57-50-01 was due but had not been performed. 

9 
15. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking when Supplemental Inspection Number 57-50-01 

was next due on civil aircraft N208SM indicated Respondent had operated the aircraft on 

flights in air commerce for at least 70 cycles when Supplemental Inspection Number 57-50-

01 was due but had not been performed. 

16. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records used by Respondent to keep track of when each of the required inspections and 

maintenance tasks for each of the Cessna Model CE-208-B aircraft it operated became due 

did not include any information for 23 of the 36 maintenance tasks referenced in paragraph 6. 

17. The maintenance tasks referenced in paragraph 6 include the following: 

Name Maintenance Supplemental Inspection Intervals 

Manual Inspection Typical Severe 

Chpt/Sec/Subj No. Initial/Repeat Initial/Repeat 

Starter-Generator 5-10-01, Item [None] Every 500 hours Every 500 hours 

Brush Holders 801002 or 1 year or 1 year 

Starter-Generator 5-10-01, Item [None] 500 hours or 1 500 hours or 1 

Brushes Code 801003 year year 

Cargo and Passenger 5-14-03 53-20-01 7500 hours/2500 7500 hours/ 2500 

Door Doublers hours hours 

Lower Forward 5-14-05 53-20-03 12,500 hours/ 12,500 hours/ 

Carry-Thru Bulkhead 2500 hours 2500 hours 

MLG Attach Fittings 5-14-07 53-20-05 12,500 hours/ 12,500 hours/ 

and Aft Carry-Thru 2500 hours 2500 hours 

Bulkhead 

Seat Rails and 5-14-13 53-10-07 7500 hours/ 2500 7500 hours/ 2500 

Attachment Structure hours hours 

Bulkheads and 5-14-14 53-20-12 7500 hours/ 2500 7500 hours/ 2500 

Stiffeners Below the hours hours 

Seat Rail '\ 

Attachments 

10 

Stringers at Inter- 5-14-15 53-20-13 12,500 hours/ 12,500 hours/ 

sections with Carry- 2500 hours 2500 hours 

Thru Bulkheads 

Fuselage Skin 5-14-16 53-20-14 5000 hours(2500 5000 hours/2500 

Doubler at MLG hours hours 

Cutout 

Fuselage to Wing 5-14-21 53-20-06 12,500 hours/ 12,500 hours/ 

Carry-Thru Attach 2500 hours 2500 hours 

Fitting and Bulkhead 

Wing Strut Fittings 5-14-28 57-60-01 10,000 hours/ 5000 hours/3600 

5000 hours hours 

18. During the period from the date indicated for each aircraft Un.til the time of the system 

safety inspection referenced in Section IT, paragraph 5, Respondent operated the following 

aircraft on divers flights for the hours of time in service indicated when the indicted 

maintenance task was due but had not been performed: 

Name N208SM Nl62GA N804TH N454SF N25JA N207DR 

11117110 1124/11 12/14/10 12/04110 12/4/10 11111110 

Starter-Generator 32.4 hours 

Brush Holders 

Starter-Generator 32.4 hours 

Brushes 

Cargo and Passenger 421.8 98.6 hours 384.8 242.5 462.9 201.4 

Door Doublers hours hours hours hours hours 

Lower Forward 421.8 

Carry-Thru hours 

Bulkhead 

MLG Attach Fittings 421.8 

and Aft Carry-Tluu hours 

Bulkhead 

Seat Rails and 421.8 98.6 hours 384.8 242.5 462.9 201.4 

Attachment hours hours hours hours hours 

Structure 

Bulkheads and 421.8 98.6 hours 384.8 242.5 462.9 201.4 

Stiffeners Below the hours hours hours hours hours 

Seat Rail 

Attachments 

Stringers at Inter- 421.8 

sections with Carry- hours 

Thru Bulkheads 

11 
Fuselage Skin 421.8 98.6 hours 384.8 242.5 462.9 201.4 

Doubler at MLG hours hours hours hours hours 

Cutout 

Fuselage to Wing 421.8 

Carry-Thru Attach hours 

Fitting and Bulkhead 

Wing Strut Fittings 400.3 462.9 

hours hours 

19. At the time of the flights referenced in paragraphs 12-15 and 18, each of the above 

aircraft was not in an airworthy condition because the inspections and maintenance tasks 

referenced above were due but had not been performed. 

20. The operation of the aircraft as described in paragraphs 1-19 was careless or reckless so· 

as to endanger the life or property of another. 

Based on the foregoing facts and circumstances, Respondent violated the following Federal 

Aviation Regulations: 

(a) Section 43.16 in that Respondent performed an inspection or other maintenance 

specified in an Airworthiness Limitations section of a manufacturer's maintenance 

manual or Instructions for Continued Airworthiness and failed to perform the inspection 

or other maintenance in accordance with that section or in accordance with operating 

specifications approved by the Administrator under part 121 or 13 5, or an inspection 

program approved under § 91.409( e). 

(b) Section 91.7(a) in that Respondent operated a civil aircraft when it was not in an 

airworthy condition. 

12 
(c) Section 91.13(a) in that Respondent operated an aircraft in a careless or reckless 

manner so as to endanger the life or property of another. 

(d) Section 91.403(c) in that Respondent operated an aircraft for which a manufacturer's 

maintenance manual or instructions for conti9nued airworthiness had been issued that 

contains an airworthiness limitations section when the mandatory replacement times, 

inspection intervals, and related procedures specified in that section or alternative 

inspection intervals and related procedures set forth in an operations specification 

approved by the Administrator under part 121 or 13 5 of the FAR or in accordance with 

an inspec~ion progr~ approved under§ 91.409(e) had not been complied with. 

(e) Section 91.417(a)(2)(ii) in that Respondent operated an aircraft for which it had not 

kept records containing the current status of life-limited parts. 

(f) Section 119.5(1) in that Respondent operated aircraft under part 135 of the FAR in 

violation of an air carrier operating certificate, operating certificate, or appropriate 

operations specifications issued under part 119 of the FAR, 

(g) Section 135.25(a)(2) in that Respondent operated an aircraft under part 135 of the 

FAR when it was not in an airworthy condition. 

13 
·(h) Section 135.419(g) in that Respondent failed to· have an aircraft subject to an 

approved aircraft inspected program inspected in accordance with that pro grain. 

C. COUNT III 

(Case No. 2011AL030047) 

1. At all times referenced herein, the Airworthiness Limitations section of the 

manufacturer's maintenance manual for each of the Beech Model BE-200-200 aircraft 

operated by Respondent required a hydrostatic test of the engine fire extinguishers every five 

years, a hydrostatic test of the cabin fire extinguisher every 12 years, replacement of the 

lower forward wing bolt and nut every five years, the replacement of the upper forward, 

upper and lower aft wing bolts and nuts every 15 years or 15,000 hours of time in service, the 

replacement of the windshield screws every 10,000 cyCles, and a test of the main oxygen 

cylinder every three or five years, depending on which tank was installed. 

2. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking when the matters referenced in paragraph 1 were 

due on civil aircraft N313HS did not include entries for the hydrostatic test of the cabin fire 

extinguisher or the five- and 15-year replacements of the above-referenced wing bolts and 

nuts, and the entry for the five-year hydrostatic test of the engine fire extinguishers was being 

tracked as due every 12 years. 

3. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking when the matters referenced in paragraph 1 were 

due on civil aircraft N90PB did not include entries for the hydrostatic test of the cabin fire 

14 
extinguisher, the three-year test of the main oxygen cylinder, or the replacement of the 

windshield screws, and the entry of the five-year hydrostatic test ofthe engine fire 

extinguishers was being tracked as due every 12 years. 

4. During the period from April20, 2010, until October 5, 2010, Respondent operated civil 

aircraft N90PB on divers flights in air commerce for some 265 hours of time in service when 

the replacement of the right hand windshield screws was overdue by more than 3700 cycles 

but had not been performed. 

5. At all times referenced herein, Airworthiness Directive (AD) 89-19-04 R1 required an 

inspection of the center wing fuel bay upper skin panels on civil aircraft N313HS every 600 

hours of time in service or 18 months, whichever occurs first. 

6. At the time ofthe system safety inspection referenced in Section II, paragraph 5, civil 

aircraft N313HS had a total time in service of 7663.9 hours. 

7. At the time of the system safety inspection referenced in Section II, paragraph 5, the most 

recent time the inspection required by AD 89-19-04 R1 had been performed on civil aircraft 

N313HS and properly documented in the maintenance records for the aircraft was on 

February 13, 2009, at aircraft total time of 6659.7 hours. 

8. On or about February 22, 2010, at aircraft total time of 6756.6 hours, the area on civil 

aircraft N313HS covered by AD 89-19-04 R1 was inspected, but the maintenance record 

15 
entry for this inspection does not indicate that the "inspection was done in accordance with 

either the AD or the service bulletin the AD references. 

9. During the period from November 5, 2010, until March 8, 2011, Respondent operated 

civil aircraft N313HS on divers flights in air commerce for 288.4 hours when the inspection 

required by AD 89-19-04 R1 was overdue but had not been performed. 

10. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking AD compliance for civil aircraft N313HS 

indicated that AD 89-19-04R1 was not applicable to the aircraft and did not indicate the time 

and date when the next action was due. 

11. At all times referenced herein, Respondent was required by its AAIP to track and comply 

with the following maintenance tasks at the intervals indicated: 

Item Action Required Intervals 

Altitude Warning Switch Inspect 12 Months 

Oxygen System Passenger Replace 24 Months 

ShutoffValve 0-ring 

Windshield Comers Inspect Initial at 10,000 cycles; each 

Doublers and Clips 1000 cycles thereafter 

Inconel Wing Bolts, L and R Inspect 5 years 

Inconel Wing Bolts, L and R Replace 15 years 

Exterior Frame Skin Inspect Initial at 10,000 cycles; each 

1000 cycles thereafter 

Fuselage Frame Web Inspect 5 years 

Fuselage Subfloor Frames Inspect Initial at 10,000 cycles; each 

1000 cycles thereafter 

16 

--------------------------
12. During the period March 1-18, 2011, Respondent operated civil aircraft N313HS on 

divers flights in air commerce for 64.3 hours when the inspection of the altitude warning 

switch was due but had not been performed. 

13. During the period from February 1, 2011, until March 18, 2011, Respondent operated 

civil aircraft N90PB on divers flights in air commerce for 62.7 hours when the inspection of 

the altitude warning switch was due but had not been performed. 

14. During the period from April 20, 2010, until April 27, 2011, Respondent operated civil 

aircraft N313HS on divers flights in air commerce for some 1062.2 hours when the 

replacement of the oxygen system passenger shutoff valve o-ring required every 24 months 

by the AAIP was due but had not been done since July 1998. 

15. At the time of the system safety inspection referenced in Section II, paragraph 5, the 

records by which Respondent was tracking when the maintenance tasks referenced in 

paragraph 11 were due on civil aircraft N313HS did not include an entry for the oxygen . 

system passenger shutoff valve o-ring. 

16. At the time of the flights referenced in paragraphs 4, 9, 12, 13, and 14, civil aircraft 

N313HS and N90PB were not in an airworthy condition because, as described above, they 

had not been maintained as required. 

17 
17. The operation of the aircraft as described in paragraphs 1-16 was careless or reckless so 

as to endanger the life or property of another. 

Based on the foregoing facts and cirGumstances, Respondent violated the following Federal 

Aviation Regulations: 

(a) Section 39.7 in that Respondent operated a product that did not meet the requirements 

of an applicable airworthiness directive. 

(b) Section 43.16 in that Grant Aviation performed an inspection or other maintenance 

specified in an Airworthiness Limitations section of a manufacturer's maintenance 

manual or Instructions for Continued Airworthiness arid failed to perform the inspection 

or other maintenance in accordance with that section or in accordance with operating 

specifications approved by the Administrator under part 121 or 135, or an inspection 

program approved under§ 91.409(e). 

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

airworthy condition. 

(d) Section 91.13(a) in that Respondent operated an aircraft in a careless or reckless 

manner so as to endanger the life or property of another. 

(e) Section 91.403(c) in that Respondent operated an aircraft for which a manufacturer's 

maintenance manual or instructions for continued airworthiness had been issued that 

18 
contains an airworthiness limitations section when the mandatory replacement times, 

inspection intervals, and related procedures specified in that section or alternative 

inspection intervals and related procedures set forth in an operations specification 

approved by the Administrator under part 121 or 13 5 of the FAR, or in accordance with 

an inspection program approved under § 91.409( e), had not been complied with. 

(f) Section 91.417(a)(2)(ii) in that Respondent operated an aircraft for which it had not 

kept records containing the. current status of life-limited parts. 

(g) 91.417(a)(2)(v) in that Respondent operated an aircraft for which it had not kept 

records containing the current status of an applicable AD and the time and date when the 

next action was due. 

(h) Section 119.5(1) in that Respondent operated aircraft under part 135 ofthe FAR in 

violation of an air carrier operating certificate, operating certificate, or appropriate 

operations specifications issued under part 119 of the FAR. 

(i) Section 135.25(a)(2) in that Respondent operated an aircraft under part 135 ofthe 

FAR when it was not in an airworthy condition. 

G) Section 135.419(g) in that Respondent failed to have an aircraft subject to an 

approved aircraft inspection program inspected in accordance with that program. 

19 
D. COUNT IV 

(Case No. 2011AL030055) 

1. On or about January 26, 2011, Respondent performed maintenance on civil aircraft 

N9973M that included fixing an inoperative turn coordinator, and then approved the aircraft 

for return to service. 

2. During the period from January 27, 2011, until March 9, 2011, Respondent operated civil 

aircraft N9973M on divers flights in air commerce for some 102 hours . 

. 3. At the time Respondent approved civil aircraft N9973M for return to service as referenced 

in paragraph 1. and at the time of the flights referenced in paragraph 2, the maintemince 

record entry required by§ 43.9(a) for the maintenance referenced in paragraph 1 had not 

been made. 

4. The operation of the aircraft as described above was careless or reckless so as to endanger 

the life or property of another. 

Based on the foregoing facts and circumstances, Respondent violated the following Federal 

Aviation Regulations: 

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

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

20 
part and failed to make an entry in the maintenance record of that equipment containing 

the information specified in this section. 

(b) Section 91.13 (a) in that Respondent operated an aircraft in a careless or reckless 

manner so as to endanger the life or property of another. 

(c) Section 91.407(a)(2) in that Respondent operated an aircraft that had undergone 

maintenance, preventive maintenance, rebuilding, or alteration when the maintenance 

record entry required by § 4 3. 9 or § 4 3.11 of the FAR, as applicable, had not been done. 

E. COUNTV 

(Case No. 2011AL030058) 

1. At all times referenced herein, AD 2003-24-07 was applicable to civil aircraftN77HV, 

and required an inspection every 12 calendar months. 

2. During the period from February 1, 2011, until March 27, 2011, Respondent operated 

civil aircraft N77HV for some 15 hours when the inspection required by AD 2003-24-07 was 

due but had not been performed. 

3. At the time of the flights referenced in paragraph 2, civil aircraft N77HV was not in 

airworthy condition because the inspection required by AD 2003-24-07 was due but had not 

been performed. 

21 
4. On or about January 13,2011, Respondent performed maintenance on civil aircraft 

N77HV that included fixing a broken passenger door support cable bracket and a loose 

passenger door seal plate, and then approved the aircraft for return to service. 

5. During the period from January 14, 2011, until March 9, 2011, Respondent operated civil 

aircraft N77HV on divers flights in air commerce for some 24.1 hours of time in service. 

6. At the time Respondent approved civil aircraft N77HV for return to service as referenced 

in paragraph 4 and at the time of the flights reference in paragraph 5, the maintenance record 

entry required by § 43.9(a) for the maintenance referenced in paragraph 4 had not been made. 

7. On or about February 5, 2011, at a time when Respondent was operating civil aircraft 

N417PM on a flight in air commerce, the landing gear would not extend normally, and had to 

be extended using emergency procedures. 

8. The events referenced in paragraph 7 constituted a failure, malfunction, or defect in an 

aircraft component that resulted in the taking of emergency action during flight. 

9. Respondent failed to report the failure, malfunction, or defect referenced in paragraph 7 

within the time specified in§ 135.415(d) ofthe FAR. 

10. Respondent's operation of civil aircraft N77HV as described above was careless or 

reckless so as to endanger the life or property of another. 

22 
Based on the foregoing facts and circumstances, Respondent violated the following Federal 

Aviation Regulations: 

(a) Section 39.7 in that Respondent operated a product that did not meet the requirements 

of an applicable airworthiness directive. 

(b) 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. 

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

airworthy condition. 

(d) Section 91.13(a) in that Respondent operated an aircraft in a careless or reckless 

manner so as to endanger the life or property of another. 

(e) Section 91.407(a)(2) in that Respondent operated an aircraft that had undergone 

maintenance, preventive maintenance, rebuilding, or alteration when the maintenance 

record entry required by§ 43.9 or§ 43.11 of the FAR, as applicable, had not been made. 

23 
(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. 

(g) Section 135.415(a)(16) in that Respondent failed to report the occurrence or detection 

of a failure, malfunction, or defect in an aircraft conceining an aircraft component or 

system that resulted in taking emergency action during the flight. 

24 

IV. SANCTION 

1. On October 20, 2010, in FAA Case NO. 2009AL030061, Respondent was found to 

have violated§§ 91.13(a) and 91.417(a)(2)(ii) by operating five Cessna Model CE-208-B 

aircraft in 2009 when Respondent had not kept an accurate reco~d of cycles, and was 

assessed a $12,000 civil penalty, which Respondent has, to date, failed to pay. 

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 of the FAR. 

3. Under the facts and circumstances of this case, a civil penalty of $50,000 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 $50,000. 

RESPECTFULLYSUBMITTEDthis {'f+~ of J}ce~k .... J0l2_. 

25 

HOWARD L. MARTIN, JR. 

Regional Counsel 

By: 

Glenn 

~(L H. Brown 

Senior Attorney 
26 
CERTIFICATE OF SERVICE 

Re: Grant Aviation, Inc. 

FAA Cases Nos. 2011AL030031, 2011AL030046, 2011AL030047, 2011AL030055 & 

2011AL030058 

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,AJ( 99501 

I ~rther 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, r~turn receipt 

requested, addressed as follows: 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

Office of the Regional Counsel 

222 West 7th A venue # 14 

Anchorage,Alaska 99513-7587 

27 

iJ;A. J.Lf QDI ~ Date I