12-13-2012 3:28 PM 18482603565 12024935142 Pg 1/2 

December 12, 4012 

Honorable Richard C. Goodwin 

Office of Hearings M-20 

1200 New Jersey Avenue, S.E. 

Fl.lGHT SCHOOLS 

East Building Ground Floor, Room E12·320 

Washington, D.C. 20590 

Honorable Richard Goodwin: 

/,.,) .. } 

As the Respondent , it is my duty to file a response to this Order to Show Cause stating why the relief 

requested in Complainant's Motions should not be granted. 

On December S, 2.011, I submitted a letter to Mr. Harper requesting that we deal with the issues ln this 

Complaint along with the other Complaint issues in the same hearing which was held on March n, 

2012. 

Mr. Harper, Ignoring my request, did not combine all the issues and thus has caused more time and 

effort be taken on the part of the FAA, Department of Transportation and Cornerstone Aviation to have 

to deal with these very minor issues separately. 

He is costing the government more expense by this proceeding then the government can hope to 

recover. Since he is even appealing the fine from the last hearing, I believe he has lost sight of the real 

reason for violations. To make sure an operator is aware of what is going an at thefr flight school and to 

put a policy in place sa it does not happen again. 

Cornerstone Aviation on the other hand, has spent a good sum of money, investing in a software 

program that has the many "fixes" so as not to repeat any of the prior violations. Our current FAA 

inspector has seen the program and will be doing a full Inspection of our paperwork and "paperless'' 

software program. Mrs. Carlson has set the appointment date of January 9/2012. 

I did answer the Complaint, as a copy of the response I submitted can be found on regulations.gov. 

Mr. Harper even sent a letter out in response to my answer stating that I cannot use the FAA FSDO 

personnel as witnesses. 

337 North 2370 West, Salt Lake City, Utah 84116 801-355-2244 

www.tornerstoneaviation.com 
12-13-2012 3:28PM 18482603565 ., 12024935142 Pg 2/2 

In my December 5, 20111etter I explained the circumstances of the two issues. I am still without proof 

from the side of the FAA that states that the graduation Cl:!rtificate and the ''records certified correct" 

signature must be done simultaneously. My guess is this is subjective. So I still feel CSA does not 

warrant a violation for this. 

Mr. Harper, sometimes gets his facts wrong. In his prior letters he kept saying that SLCC was just an 

associate of CSA, so their record keeping was Irrelevant- only the operator's records counts. If he 

bothered to look at CSA's official Training Course Outline, SLCC is listed as a satellite base of CSA, thus a 

part of the operator- why else would the FAA require that a letter of Part 141 certification (Air Agency 

Certificate) be displayed at the college? They also do official inspections of CSA at the SLCC campus, as 

they do at all satellite bases. 

With regards to the Graduation Certificate that omitted the "cross country training"; the regulation 

141.95(b)(7) states: the graduation certificate ... must contain at least the following Information: "a 

statement showing the cross-country training that the student received in the course of training''. I 

explained in my previous letter what happer~ed, but did you know that CSA can also get violated If we 

excluded #7 in a graduation certificate for a student graduating from our Part 141 approved Ground 

School courses? Now, this Is an illustration of where, even the FAA, doesn't have It correct. How can a 

ground school student (all training done in a classroom) do cross country training? Answer: he/she 

cannot and does not, but the FAA still wants an operator to put that statement on the certificate when 

it doesn't even apply to their training. Just another example of someone doing incorrect paperwork -

only this was put into an FAA regulation and even though all the operators know it should not need to 

be on a ground school graduation certification, we have to do it because it is in the regulations, right or 

wrong. 

My suggestion is for Mr. Harper to withdraw the Complaint as per the regulation below, and save the 

government time to handle more important issues. 

l.J C.JI-:R. § 13.215 states: At any time bejo1·e o1·duringahearing, an agency attorney may withdraw a 

Cl?mplaint c11' party may withdrav.• a request for a hearing without t,lte oonstmt of the administrative lav., 

judge. Jj'(:(ll agrt.m.y attorney withdraws the com plat/It or a parry withdraws the reque.vt.fbr a hearing and lh;: 

answer, the administrativ(f law judge shall dismiss the proceedings under this subpart with P''ejudlce. 

If you require additional information or have questions please feel free to contact me at any time. 

Respectively you

1

rs1 I ,/ 

-~: \.. .. ~. ,'\ .,, ~~(· ~::·--" . . . ~~ ... --- ···r \N .. ,;;-~<o- ._>( ~ 

.... Susan J. Horstman 

CEO/Chief Instructor 

shorstm an@ cornerstoneaviation.com 

337 North 2370 West, Salt Lake City1 Utah 84116 801·355-2244 

www.cornerstoneaviation.com