April 4,2014 

Office of the Chief Counsel 

Attention: FAA Part 16 Airport Proceedings Docket, AC0-100, 

Federal Aviation Administration, 

800 Independence Ave., SW., Washington, DC, 20591. 

REF FAA Docket No.16·13·03 

Dear Sir or Madam. 

My mane is Hiroaki Nishio who Is complant of FAA Docket No 16·13·03. 

I am going to respond to Request for additional infrmatiotion for FAA Docket No 16-13-03. 

1.Provide evidence to the Record the Commplainnant has made an effort to obtain the 

required 10 M liadility insurance. 

I am going to attach letters of denial for $10M liability insurance. 

2.AIIeges that the cost to obtain the require liability is cost prohibitive. 

I am going to attach AOPA lnsrance Agency Catalog. 

3.The historical record of insurance. 

I am going to attach Aon lnsrance liability insurance payment record. 

I am going to attach an executed original and 3 Copies ofThis letter and USPS Certify 

receipt for the Respondent. 

Thank You. 

PO SOX 5910 CHRB 

Saipan MP 96950 

USA 

E-mail hiroaki230@gmail.com 

Cell 670 287 0464 

1 
1e1 Traders Insurance Company 

~I~. 1st Floor Alexander Building, Beach Road, San Jose Village 

P.O. Box 5024-73, Saipan, MP 96950 

Tel, (670) 234--778817789 Faxo (670) 234--8899 

\Vebsite: www .tradersinsco.com 

April 3, 2014 

Mr. Hiroaki Nishio 

President 

Coral Ocean Airways, Inc. Dba Saipan Flight Academy 

P.O. Box 5325 CHRB 

Saipan MP 96950 

Subject: Aviation Liability Insurance 

Dear Sir: 

Due to underwriting restrictions, we regret to advice that we are not on the position to provide 

coverage on the above captioned subject at this time. 

We hope you understand our position on this matter. 

Thank You. 

"rely,. 

~~~ _/Licop 

Maf:~~~ I 

Cc: file 
03 April 2014 

SAIPAN FLIGHT ACADEMY 

P.O. Box 5325 CHRB 

Saipan MP 96950 

Gentlemen: 

Ao.n Insurance A1icronesia (SaitJan) lnc. 

Re : AIRCRAFT LIABILITY INSURANCE 

We are constrained to advise that due to underwriting restrictions, we are unable to support 

your need for a $10,000,000.00 Liability Insurance for your Cessna 172. 

We hope we can be of service in other ways. 

Thank you. 

Very truly yours, 

TOM BERNARDO 

Sr. Underwriter 

• 

P.O. Box 502177, Saipan, MP96950 

1st Floor, TSL Plaza, Beach Road, Garapan, Saipan 

Telephone: (670) 234-2811 • Facsimile: (670) 234-5462 
INSURANCi' S~RVICES 

Application for CFI 

Non-Owned Aircraft Insurance 

INSTRUCTIONS: Indicate which aircraft type you intend to fly by checking 

all that apply. 

OSing!e Engine land aMulti Engine Land ORotorwing OSeap!ane/ Amphib 

Note: For coverage in Hawaii, Alaska or Kentucky, please contact AOPA 

Insurance Services at 1~800-622-AOPA (2672] as the premiums listed do 

not apply. Coverage is not available to pilots under the age of 18. 

For Single Engine Land this insurance is for your personal and noncommercial and dual instruction use of non-owned, fixed wing, nonpressurized, aircraft having a non-turbine engine of 450 horsepower or less 

(including non-powered sailplanes), capacity of seven (7) or less total seats, 

and a standard, experimental, restricted, or light sport aircraft certificate, 

and not furnished to you for more than thirty (30) consecutive days. Multi 

Engine, Rotorwing and Seaplanes are not included in this coverage. If only 

applying for Single Eng;ne Land, continue to complete this application in 

its entirety. 

For All Other Aircraft Types, please cal! AOPA Insurance Services for a 

custom quote at l-800-622-AOPA [2672=. 

11 ~·.~~~ .. ~~!.~.~~~.t~.~.~···························································· ALL FIELDS must be completed One individual only_ No Corporations. 

Full Name 

Address 

AOPA Member No. 

Cell# 

Email 

Occupation 

Pilot Certificate: 

Home# 

0 Student 

0 Private 

0 Recreational 

0 Commercial 

DOB 

Work# 

0 Sport 

DATP 

Logged Hours: (Total) (Last 12 Months) 

Dual Flight Instruction Hours Given: (last 12 Months) 

Make/Model of aircraft you normally fly: 

Total Hours in Make/Model: 

Within the_ Last 36 Months Hqve You'": 

Be_en cited for ViOlation of an-y 

federal AViation R:egula~io'n? 

Had YO!.lr_pi!ot's/drlver's license 

surrendered, sus~nded or re-Voked? 

Been convicted of operating an aircraft or 

motor vehicle while under the influence 

of c;lrugs or alcohOl? 

B~n involved in any aircraft -a'ccident/incident 

or aviation insurance claim? 

0 No Cl Yes 

Cl No - DYes 

1:1 No, OYes 

0 No OYes 

Plet~se 

Mark 

Changes 

~ ·- ·- " ' ' " -- -- -' -

•Jf 'yoU answered ye'S to any of the <ibove questions. please. -call AOPA Insurance -services 

at 1·_800-622~AOPA [2672f Additional lnfon:nation may be required to determine your 

el!glbllity for insurance-in this program. 

II ~!.~~.~~~~ .. ~.~:!!.~~-~.!~ ... ~~~~~.:.~.~j-~~:.~:.~~-~~::.~~.~~~~-~i~?:~~t.: •• 

Protects against claims for Bodily Injury and Property Damage that you may become 

legally obligated to pay for arising from your operation of a non-owned aircraft 

Damage to the non-owned aircraft is not covered, but may be purchased in Section 3. 

Coverage is extended to a loss arising from professional malpractice as respects dual 

flight instruction, flight review or check rides conducted by you in a non-owned aircraft. 

• Optional Coverage: .... , .......................................................................................... . 

• Liability Limit Desired for Damage to NonMOwned Aircraft 

Protects ag~inst claims for damage to the non-owned aircraft, including its loss of use 

and $5,000 each occurrence of no-fault deductible coverage. May be purchased only if 

required coverage above is also purchased. 

. ·. 

·· -Limit of No_n~ "AOPA 

Member Mernber_ 

L!abl!!til Rate Rate.;..;_ __ : ·:. -~~mrtOf NonMember" LiabilitY Rate 

CJ $5,000 $99 $94 CJ $60,000 $600 

CJ $10,000 $175 -$166 CJ $80,000 $775 

CJ $20,000 $250 $238 CJ $100,000 $975 

CJ $30,000 $350 $333 CJ $150,000 $!,425 

CJ $40,000 $450 $428 CJ $200,000 $1,goo 

CJ I declme Phys1cal Damage Coverage 

• Employer as Additional Insured Coverage 

Cl I hereby elect to purchase Employer Additional Insured Coverage 

Employer Name 

Employer 

Address 

AOPA I Mefnber · 

Rilte 

$570 

$736 

$926 

$1,354 

$1,8p5 

$50/yr 

Coverage shall not apply to any loss arising out of the Additional Insured's activities 

Involving the manufacture, sale, repair or service of aircraft or aircraft parts, components 

or accessories, or operations of any airport, hangar facility, flying service or pilot activity, 

• Civil Air Patrol Coverage 

Includes Civil Air Patrol missions defined as flights In conjunction with or on behalf of the 

Civil Air Patrol. Civil Air Patrol uses include search & rescue missions, aerial 

photography, courier, and aerial surveillance flights ordered by a corporate officer of the 

Civil Air Patrol or their designee. 

Cl I hereby elect to purchase Civil Air Patrol Coverage $50/yr 

• Premium Calc:ulatlon 

II <;:overage-underwrit_t~n by: AIG Aerospace· insurance Services,- Inc. 

Payment lnformatic:»n - .......... ; ....... · ....................................................... -........ , ........................................................................................................................................ . 1 wlsh_to_ have my c;overage become effective on 0 'MM/DD/YY 

Cl ASAP 

!_acknowledge that -mY _policy will become effective upon AOPA InsUrance Services· 

_receiPt and acceptance of this application; my medjcal and pilot certificates -are current 

with-necess.:iry ratings required by the FAA; -and when I have paid the premium In fulL 

PremiUm is 50% fully earned Upon the 'lncepti<ih date of the-policy; _ ihe maximum 

that can be returned is 50% of_the total annual premium if the policY. is :eancelle:d. 

0 Enclosed is a check for-the total premium, payable to: ,A.,OPA Insurance Services 

0 I will be calling AOPA Insurance Services at i·S00·622·AOPA t26721 to pay bY 

credit card. 

0 ·Please e)Tiail my policy to me at (if different from above). 

I hereby certify_ that all inform;;~tion provided in this a'pplicatibn is true and ·complete to 

the best of my knowledge_ -and no _information has been withheld. ! agree that this 

application and the·terms and conditions of the-policy to be>·issued shall be the basis of 

the contract between the insuraf_lce company and me. ! understand that no insurance_ is 

in force unleSs_and until the insurance company or Its aUthorized represent~tive effects a 

binder· of- insurance or issues the policy. I authorize- the insurance company or its 

aUthorized repro;;!sentative -to investigate the statements contained herein. I have read 

and understand the FRAUD WARNINGS on the reserve side_ of this application. 

Date 

Priority Code: L14XXWCFI 
Cover Note No DX0510861 

Aviation 

MICROL INSURANCE 

P.O BOX 2177 CK 

8 Devonshire Sguare 

London EC2M 4l'L 

tel: 020 7623 5500 

fax: 020 76211511 

GROUND FLOOR LIM'S OFFICE BLDG 

CORN BEACH ROAD AND AIRPORT ROAD 

SAN JOSE 

HCR 

SAIPAN 

MP96950 

16th September 2005 

GUAM 

Dear Sirs, 

In accordance with your instructions we have effected the following Insurance for 100% of Limits. 

TYPE: 

FORM: 

INSURED: 

ADDRESS: 

PERIOD: 

INTEREST: 

SUM INSURED: 

02805097 

AVIATION LIABILITY INCLUDING PREMISES LIABILITY 

INSURANCE 

J(A) form with wording as expiring policy number DX041 0861 except as 

amended below. 

SAIP AN FLIGHT ACADEMY and/or Associated and/or Affiliated and/or 

Subsidiary Companies apd/or other entities as may be required including 

Officers, Servants, Employees thereof for their respective rights and interests. 

PO Box 5910 CHRB, Saipan, MP96950 Micronesia. 

From 23'• August 2005 to 23'• August 2006 both days at 00.01 hours local 

standard time at the address of the Insured. 

The Insured's Legal Liability for Third Party Liability (Property 

Damage/Bodily h1jury), Passenger Legal Liability (including passenger 

baggage/personal effects), in respect of all aircraft owned, operated or used 

by the Insured or for which the Insured has agreed to be responsible, as 

detailed in the Schedule of Aircraft including Premises Legal Liability. 

(a) AIRCRAFT LIABILITY: 

Combined Single Limit USD 1,000,000 each occurrence with 

Passenger Legal Liability limited to USD 100,000 any one person 

within Combined Single Limit. 

Page I of5 

Please ex:unine the terms, conditions and security shown on this Cove1· ::.iote and advise us i.tnmediarely if anr of rhese arc not in 

accordance v.-ith your requirements. 

A on Liwited 
•• 

Aott Limited 

Continuation of Cover Note No. DX051 0861 

PAYMENT TERMS: Premium payable in full at inception. 

INFORMATION: SCHEDULE OF AIRCRAFT 

Registration Passenger Seating 

1. Cessna 172M N-13230 3 

Placed With: 

100.0000% ALLlANZ MARINE & AVIATION VERSICHERUNGS AG, MUNICH, 

GERMANY* 

100.0000% 

* Alhanz 

2 Minster Court, Mincing Lane, London, EC3R 7XA 

Duty to Disclose Material Information 

Material Information is information that would influence an insurer in deciding whether a risk is 

acceptable and, if so, the premium, terms and Ci\llditions to be applied. Failure to disclose such 

information could result in the policy being rendered void so that claims would not be paid. 

The duty of disclosure is re-imposed when there are changes or variations in cover and when the 

policy is renewed or extended. In addition, changes which substantially increase the risk, or relate to 

compliance with a warranty or condition in the policy must be notified at once. 

To ensure that cover is not prejudiced, please refer to Aon if there is any doubt as to what 

information needs to be disclosed. 

LSW 1001 Several Liability Notice (Insurance) 

The subscribing insurers' obligations under contracts of insurance to which they subscribe are several 

and not joint and are limited solely to the extent of their individual subscriptions. The subscribing 

insurers are not responsible for the subscription of any co-subscribing insurer who for any reason does 

not satisfy all or part of its obligations. 
SITUATION: 

CONDITIONS: 

Continuation of Cover Note No. DX051 0861 

(b) PREMISES LIABILITY: 

USDl,OOO,OOO any one occurrence 

Property Damage Deductible USDSOO each and every loss. 

Saipan and Neighbouring Islands. 

Uses: Commercial 

Pilots: Mr. Hirokai Nishio 

Baggage 

Deductibles: USD750 each and every Joss (not applicable in the event of 

an accident to the aircraft). 

Automatic pro rata additions and deletions as per Additions and Deletions 

A VN18A (liability) amended to include additions of any type of aircraft up to 

the maximum seating capacity stated in the Schedule of Aircraft. 

War, Hi-jacking and Other Perils Exclusion Clause A VN48B writing back all 

paragraphs except (b) per Extended Coverage Endorsement (Aviation 

Liabilities) A VN52E subject sub-limit ofUSDl,OOO,OOO any one occurrence 

and in the annual aggregate except with respect to passengers, baggage and 

personal effects to whom full policy limit(s) shall apply. This sub-limit shall 

apply within the full policy limit and not in addition thereto. In respect of 

Aircraft Liability only. 

Nuclear Risks Exclusion Clause- A VN38B. 

Noise and Pollution and Other Perils Exclusion Clause A VN46B (not 

applicable to Passenger Bodily Injury). 

Search and Rescue Extei'!sion Clause (Limit USDJ 00,000) sny one 

operation/aggregate) A VN62. 

Cross Liability Clause A VN63. 

Date Recognition Exclusion Clause A VN2000A. 

The Contracts (Rights of Third Parties) Act 1999 Exclusion Clause A VN72 

Notwithstanding anything contained herein to the contrary, it is understood 

and agreed that the term "passengers" shall be deemed to include: 

I() I db I 
' . 

Aon!Jmited 

Continuation of Cover Note No, DX051 0861 

Remuneration 

Aon Limited, Specialty is committed to a remuneration model that is transparent for the client, fair to 

all parties and regulatory compliant Full disclosure of all remuneration received by Aon Limited, 

Specialty is fundaments) to this approach and is detsiled on the attached debit note. 

Yours faithfully, 

Aon Limited, Aviation 

As part of our commitment to continual improvement, we welcome any comments you may have on 

the service provided, Please contact Aviation at: avqm@aon.co.uk 
Name 

Attn 

Street 

City 

Zip 

Hdg 

Saipan Flight Academy 

P.O. Box 5325 CHRB 

Saipan 

96950 

Hiroaki Nishio 

St MP 

Csr 

Client # SAIP-36 

Conglom# 

Agency 1 

Branch 1 

Broker 

Code CL Pr 

Note 

Ph-R 

Ph-B 

Ph-F 

Ocp 

Item # Date Trn Type Due Date B I? Description 

16936 

17024 

17852 

17853 

18 681 

20087 

21428 

22662 

24134 

36322 

36917 

37204 

38 62 4 

38651 

40062 

41346 

424 94 

44017 

45818 

53974 

54570 

56123 

57 68 0 

59187 

60593 

62174 

63394 

65238 

67163 

68328 

70140 

73161 

73546 

75308 

75309 

76993 

78385 

79840 

81523 

83121 

84 663 

86016 

90407 

91367 

92313 

93640 

94585 

96408 

08/25/2000 

08/25/2000 

09/14/2000 

09/14/2000 

09/28/2000 

10/30!2000 

11/29/2000 

12/28/2000 

01/30/2001 

09/13/2001 

09/24/2001 

10/03/2001 

10/29/2001 

10/31/2001 

11/28/2001 

12/31/2001 

01/26/2002 

02/27/2002 

03/25/2002 

08/22/2002 

08/30/2002 

09/30/2002 

10/31/2002 

11/27/2002 

12/30/2002 

01/30/2003 

02/24/2003 

03/25/2003 

04/28/2003 

05/20/2003 

06/26/2003 

08/22/2003 

08/28/2003 

09/29/2003 

09/29/2003 

10/29/2003 

11/25/2003 

12/29/2003 

01/28/2004 

02/26/2004 

03/25/2004 

04/21/2004 

07/23/2004 

08/13/2004 

08/31/2004 

09/28/2004 

10/20/2004 

11/30/2004 

NEW AVIA 

PAY 

-EN AVIA 

NEW AVIA 

PAY 

PAY 

PAY 

PAY 

PJ\Y 

REN AVIA 

PAY 

+EN AVIA 

PAY 

-EN AVIA 

PAY 

PAY 

PAY 

PAY 

PAY 

REN AVIA 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

REN AVIA 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

PAY 

REN AVIA 

PAY 

PAY 

PAY 

PAY 

08/25/2000 A 1973 CESSNA 172M 

08/28/2000 A Y OR#23097 /UBC1650 

09/14/2000 A Reverse Entry Error 

09/14/2000 A Aircraft Insurance 

09/29/2000 A Y OR#23654/UBC1656 

10/30/2000 A Y OR#24131/BOG1688 

11/30/2000 A Y OR#24579/BOG1696 

12/28/2000 A Y OR#24991/BOG1702 

01/30/2001 A Y OR#25495/BOG1709 

09/13/2001 A Aircraft Liability renewal 

09/26/2001 A Y OR#30036/Amex 

10/03/2001 A War Risk Buy Back 

10/31/2001 A Y OR#30778/Amex 

10/31/2001 A Y2k Profit Commission 

11/29/2001 A Y OR#31230/Amex 

12/31/2001 A Y OR#31712/Amex 

01/28/2002 A Y OR#32172/Amex 

02/28/2002 A Y OR#32823/Amex 

03/28/2002 A Y OR#33475/Amex 

08/23/2002 A Aircraft Liab yr 2002-03 

08/31/2002 A Y OR#36844/Amex 

09/30/2002 A Y OR#37455/Amex 

10/31/2002 A Y OR#38041/Arnex 

11/29/2002 A Y OR#38570/Amex 

12/31/2002 A Y OR#39090/Amex 

01/31/2003 A Y OR#39685/Amex 

02/25/2003 A Y OR#40177/Amex 

03/26/2003 A Y OR#40807/Amex 

04/29/2003 A Y OR#41538/Amex 

05/22/2003 A Y OR#42006/Amex 

06/27/2003 A Y OR#42659/Amex 

08/23/2003 A 'ilircraft Liability yr 2003-04 

08/29/2003 A Y OR#43886/Amex 

09/30/2003 A Y OR#44487 /Amex 

09/30/2003 A Y OR#44488/Amex 

10/30/2003 A Y OR#45216/Amex 

11/26/2003 A Y OR#45701/Amex 

12/30/2003 A Y OR#46232/Amex 

01/27/2004 A Y OR#46730/Amex 

02/27/2004 A Y OR#47292/Amex 

03/29/2004 A Y OR#47866/Amex 

04/22/2004 A Y OR#48380/Amex 

07/26/2004 A Y OR#50054/Amex 

08/23/2004 A Hull Liability 

08/31/2004 A Y OR#50751/Amex 

09/29/2004 A Y OR#51302/Amex 

10/20/2004 A Y OR#51705/Amex 

11/30/2004 A Y OR#52309/Amex 

287-0464 

Amount 

10000.00 

-1700.00 

-10000.00 

10000.00 

-1750.00 

-1700.00 

-1850.00 

-1700.00 

-1300.00 

4500.00 

-1000.00 

1005.00 

-1000.00 

-340.00 

-800.00 

-800.00 

-800.00 

-321.00 

-444.00 

9750.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

-800.00 

-802.00 

-800.00 

-348.00 

11000. DO 

-1000.00 

-1000.00 

-500.00 

-1500.00 

-1500.00 

-1500.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

-1000.00 

10500.00 

-1500.00 

-1500.00 

-2000.00 

-1500.00 
Item# Date Trn Type Due Date B !? Description Amount 

97328 12/21/2004 PAY 12/21/2004 A y OR#52629/Amex -1000.00 

99064 01/31/2005 PAY 01/31/2005 A y OR#53282/Amex -1000.00 

100505 02/28/2005 PAY 02/28/2005 A y OR#53796/Amex -1000.00 

108143 08/01/2005 PAY 08/02/2005 A y OR#56682/Amex -1000.00 

109113 08/24/2005 REN AVIA 08/24/2005 A Aviation Renewal 2005-2006 10500.00 

109445 08/29/2005 PAY 08/30/2005 A y OR#57397 /Amex -1000.00 

110873 09/28/2005 PAY 09/29/2005 A y OR#57986/Amex -1500.00 

112420 10/31/2005 PAY 10/31/2005 A y OR#58561/Amex -1000.00 

113582 11/28/2005 PAY 11/29/2005 A y OR#59067 /Amex -1000.00 

115222 12/29/2005 PAY 12/30/2005 A y OR#59642/Amex -1000.00 

116848 01/30/2006 PAY 01/31/2006 A y OR#60226/Amex -1000.00 

118303 02/27/2006 PAY 02/28/2006 A y OR#60790/Amex -1000.00 

120233 03/30/2006 PAY 03/30/2006 A y OR#61493/Amex -1000.00 

122152 05/02/2006 PAY 05/05/2006 A y OR#62234/Arnex -200.00 

125079 06/28/2006 TRN 06/28/2006 A y Client Transfer from CORAL-2 -800.00 

Balance: 0.00 

• 
Certificate of service. 

I hereby certify that I have this day served the foregoing formal complaint on the following 

Persons at the following addresses and by the United States mail (certified Mail) 

Executive Director 

Commonwealth Port Authority 

PO BOX 501055 Saipan, MP96950-105S 

Respondent 

Office of the Chief Counsel 

Attention: FAA Part 16 Airport Proceedings Docket, AC0-100, 

Federal Aviation Administration, 

800 Independence Ave., SW., Washington, DC, 20591. 

FAA 

April4,2014 

Hiroaki Nishio 

PO BOX 5910 CHRB Saipan 

MP 96950 USA 

1 
1£1.8. Rastal 

' 

- "'' "' ~ ~ 

Se'ftl1JCer~ , , ' i • ! rr 

6ER!T11EIEID 1\ll~m;,. REBEI~!ilt (Domestic Mail Only; No Insurance Coverage Flro)ijded) rn 

, ru 

,r'l 

I ru 

I rn 

U1 

SAil!)tlf 'f'51 

Postage $ 

i ....n 

! Certified Fee $3~30 1-<.•:i" 

r'l "" 

CJ 

'CJ 

Return Receipt Fee Postmark 

(Endorsement Required) $1). (ll) liere 

'CJ Restricted Delivery Fee 

(Endorsement Required) $1),00 

I CJ 

,ru 

i :;:: 

I 

Total Postage & Fees $ H.21 04/0412014 

rn 

:1 r-=1 

'CJ 

t'-