### Law Offices of 

# Timothy H. Bellas, LLC

A LIMITED LIABILITY COMPANY

_________________________________________________________________________________________________________ Cactus & Botones St., Garapan Telephone No. (670) 323

- 211 5

P.O. Box 502845 Facsimile No. (670) 323

- 2116

Saipan, MP 96950 Email: tim@bellaslaw.net

March 8 , 2012

Ms. Lauralyn J. Remo

Chief, Air Carri er Fitness Division

Office of Aviation Analysis

Department of Transportation

Washington D .C

. 20590

Re: Response to Your Letter of February 24th . 2012, Docket DOT

- OST

- 2010

- 0235

, Star

Marianas Air, Inc . Application

.

Dear Ms. Remo:

I n response to your letter of February 24th, 2012 (" February letter") Star Marianas, Air, Inc.

("SMA ") has draft ed and executed an Amendment to the Air Charter Agreement ("ACA") with

Tinian Dynasty Hotel and Casino ("TDHC") which is attached

. The Amendment addresses the

areas of concern expressed in the DOT's January 3rd, 2012 let ter.

DOT has now asked for fu rther information as to '... how many of the non

- TDHC charter flights

in this time frame were actually chartered by TDHC customers , separate from the arrangement

STAR has with TDHC? " That question is impossible to answer. Star ’ s normal rates are $175 for

a daytime charter and $250 for a night time charter . There are no inquiries made or records kept

of wheth er the Star ’ s charter customer s are also going to be a customer of TDHC. All that can

be reported is that th e numbers that were previously provided are for charter flights that were not

paid for by TDHC.

However, Star can also pr ovide other figures which represent flights which are definitely not

connected to TDHC because they are to the islands of Rota and G uam. The flights to Rota, for

example, are usually chartered for the transportation of goods and not passengers. T he rates for

the Rota charters are $500 for 1,000 pounds of capacity between Saipan and Rota, and Rota and

Guam

.

In the last quarter of 2011, the following numbers of such Rota charters were flown:

October

--------- 86

November

----- 110

December

---- 140Third DOT Response Letter

- Ms. Remo

March 8 , 2012

Page 2

SMA can attest that these charters have nothing to do with TDHC as it has no business interests

in Rota, to SMA's knowledge, nor does i t derive any customers from that island.

Lastly, SMA has experienced substantial growth in its charter business. Some of that increase is

due to market forces which have reduced the viable domestic air carrier service available to

residents and travelers alike. This has created a n environment in which SMA intends to expand

its operations by applying for authority to engage in additional air transportation services ; e.g.

scheduled service . These expansion plans will result in TDHC's air charters becoming a smaller

portion of SMA 's total business operations.

We hope that this addresses all of your concerns and that we can look forward to a favorable

response to SMA's commuter authority application.

Sincerely,

Timothy H. Bellas

cc: Hon. Gregorio C. Sablan, Representative

U.S. House of Representatives

Tinian Delegation, House and Senate

CNMI Legislature

Hon. Ramon Dela Cru z, Mayor of Tinian

Client

File

ATTESTATION

The factual contents of this letter are true and correct to the best of my knowledge and belief.

Pursuant to Title 18 United States Code Section 1001, I Shaun Christian, President of Star

Marianas Air, Inc., in my individual capacity and as the authorized representative of SMA, verify

that I have not in any manner knowingly and willfully provided any falsified, fictitious, or

fraudulent statement or knowingly used any documents which contain such statements in

connection with the preparation, of this letter. I understand that an individual who is found to

have violated the prov isions of the 18 U. S.C. S ection 1001 shall be fined or imprisoned for not

more than five years, or both.

Dated : 3

- 9

- 2012

____________________________ Shaun Christian, President