Law Offices of

Timothy H. Bellas, LLC

A LIMITED LIABILITY COMPANY

_________________________________________________________________________________________________________

Cactus & Botones St., Garapan Telephone No. (670) 323-2115

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 Carrier 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:

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

("SMA") has drafted 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 letter.

DOT has now asked for further 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 whether the Star’s charter customers are also going to be a customer of TDHC. All that can 

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

paid for by TDHC. 

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

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

example, are usually chartered for the transportation of goods and not passengers. The 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 ---- 140
Third 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 it 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 an 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 Cruz, 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 provisions of the 18 U.S.C. Section 1001 shall be fined or imprisoned for not 

more than five years, or both. 

Dated : 3-9-2012 ____________________________

Shaun Christian, President