U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

RECEIVED 

SEP 1 9 2013 

HEARING DOCKET 

In the Matter of Aero Micronesia, FAA Docket No.: Unassigned 

FDMS No.: FAA-2012-0468 :>~· 

Respondent. ',·'") FAA Region: Western-Pacifit-,"i 

Judge: Richard C. Goodwin ' ._ 

._l 

COMPLAINANT'S MOTION FOR DECISION 

01 

To: Honorable Richard C. Goodwin, Administrative Law Judge, and Respondent, .Aero 

Micronesia: 

Complainant, Federal Aviation Administration (FAA), Western-Pacific Region, by 

counsel, files this Motion for Decision pursuant to sections 13.218(a) and (f)(5) of Title 14 

of the Code of Federal Regulations, in that Complainant is entitled to a decision as a matter 

of law because there is no genuine issue of material fact disputed by the parties. 

I. FACTS 

On May 11, 2012, Complainant filed the Complaint in this action. The Complaint alleged: 

1. Aero Micronesia, Inc. d/b/a Asia Pacific Airlines ("Aero Micronesia") is now, 

and at all times mentioned herein was, the holder of Air Carrier Certificate No. 

I5PA400I, authorized to conduct flight operations, cargo only, under part 121 of 

the Federal Aviation Regulations ("F ARs"). 

2. On or about March 25, 2011, Aero Micronesia operated a Boeing 727-200 

aircraft, Civil Registration No. N319NE, on a cargo carrying flight from Majuro 

Atoll to Honolulu International Airport. 

3. Incident to the above operation, N319NE carried an item of cargo, which 

included an aircraft engine in zone 8. 
4. The "Load Planner- Weight Manifest" for the above flight showed that the 

weight ofthe cargo indicated in no. 3 above was distributed across zones 7, 8, 

and 9. 

2 

5. The weight of the cargo indicated in no. 3 above was not distributed across zones 

7, 8, and 9, but was instead limited to zone 8. 

6. As a result of allegations 3 - 5 above, the "Load Planner- Weight Manifest" was 

not accurate. 

7. The maximum allowable weight in zone 8 ofN319NE was 10,000 pounds. 

8. N319NE contained a placard indicating that the maximum allowable weight for 

zone 8 was 10,000 pounds. 

9. The weight of the cargo indicated in no. 3 above exceeded 10,000 pounds. 

10. Alternatively, if it is found that the cargo indicated in no. 3 above did not exceed 

10,000 pounds, then the "Load Planner- Weight Manifest" showing the total 

weight of said cargo did exceed 10,000 pounds is not accurate. 

By virtue of the foregoing, Complainant alleged that Respondent had violated the following 

Federal Aviation Regulations, and proposed to assess of civil penalty of$19,250: 

(a) 14 C.F.R. § 91.9(a), which states " ... no person may operate a civil aircraft 

without complying with the operating limitations specified in the approved 

Airplane or Rotocraft Flight Manual, marking, and placards ... " 

(b) 14 C.F.R. § 121.665, which states "[e]ach certificate holder is responsible for the 

preparation and accuracy of a load manifest form before each takeoff. .. " 

On June 15,2012, Respondent filed an Answer, in which Respondent admitted allegations 1 

-8 above. Respondent's Answer, page 1, 'ijl. That leaves allegations 9 and 10, and 

violations (a) and (b) as contested. However, Respondent has separately admitted to 

allegation 10 (and violation of (b), inaccurate manifest), leaving allegation 9 (and violation 

(a), overweight engine cargo) as the only truly contested matters. 
II. LEGAL STANDARDS. 

Title 14 ofthe Code ofFederal Regulations, section 13.218(:£)(5) states: 

A party may make a motion for decision, regarding all or any part of the 

proceedings, at any time before the administrative law judge has issued an 

initial decision in the proceedings. The administrative law judge shall 

grant a party's motion for decision if the pleadings, depositions, answers 

to interrogatories, admissions, matters that the administrative law judge 

has officially noticed, or evidence introduced during the hearing show that 

there is no genuine issue of material fact and that the party making the 

motion is entitled to a decision as a matter pf law. The party making the 

motion for decision has the burden of showing that there is no genuine 

issue of material fact disputed by the parties. 

14 C.F.R. § 13.218(:£)(5). 

III. ARGUMENT. 

As indicated above, the only allegations of the Complaint not admitted in 

3 

Respondent's Answer are allegations 9 and 10- and the only truly contested allegation is 

allegation 9 (the overweight engine cargo), since Respondent has actually admitted to 

allegation 10 (the inaccurate manifest). We will start by addressing Respondent's admission 

to the inaccurate manifest violation. 

a. The Manifest was Inaccurate (14 C.F.R. § 121.665). 

There are two issues regarding the inaccurate load manifest. One involves a 

violation for the load manifest showing an inaccurate distribution of the cargo (allegations 4 
4 

-6 of the Complaint), to which Respondent has admitted.1 Thus, a violation of 121.665 is 

not contested in that regard. 

The second issue regarding the load manifest is in regards to the engine cargo weight 

indicated on the load manifest (allegation 10 of the Complaint). Complainant will show 

later in this motion that the weight of the engine cargo did actually exceed 10,000 pounds, as 

depicted on the load manifest (and thus there is no second violation of 14 C.F.R. § 121.665). 

However, Respondent asserts that the engine cargo did not exceed 10,000 pounds- that 

instead "the load manifest had an inaccurate weight for the engine." Respondent's Answer, 

p. 1, ~ 3. Thus, Respondent has admitted to allegation 10 of the Complaint. Respondent is 

essentially arguing that it committed a second 14 C.F.R. § 121.665 violation (manifest error) 

rather than a 14 C.F .R. § 91.9(a) violation (overweight engine cargo). Thus, in an abundance 

of caution, Complaint alleged a second 14 C.F .R. § 121.665 violation. 

Respondent denies allegation 1 0 in its Answer simply based on the fact that this 

charge was "not mentioned in [Complainant's] original LOI [Letter oflnvestigation] or 

proposed civil penalty." Respondent's Answer, page 1, ~ 1. Allegation 10 was included, 

however, in Complainant's Amended Notice of Proposed Civil Penalty (NPCP) dated March 

1, 2012, Final NPCP dated April24, 2012, and Complaint, dated May 11, 2012. See Exhibit 

1, Amended NPCP, and Exhibit 2, Final NPCP. See also Complaint. Thus, Respondent has 

had ample notice of the inaccurate load manifest allegations. . 

Respondent further claims that the "the technical inaccuracy contained in the 'Load 

Planner-Weight Manifest' [doesn't constitute] a material violation." See Answer, page 1, ~ 

2. Such contention does not vitiate the violation, but is only relevant in determining the 

1 Respondent admits that the manifest showed the engine cargo distributed across three zones, when it was 

actually limited to a single zone (allegations 4-6 of Complaint). See Respondent's Answer, p. 1, ~ 1, 

admitting allegations 1-8. 
5 

appropriate sanction. See FAA Order 2150.3B. The uncontested facts show that 

Respondent violated 14 C.F.R. § 121.665 (manifest error) in at least one instance by 

showing an inaccurate distribution of the cargo, and either violated 14 C.F.R. § 121.665 a 

second time by showing an inaccurate weight on the manifest, or instead violated 14 C.F.R. 

§ 91.9(a), by carrying overweight engine cargo.2 

b. The Engine Cargo Exceeded 10,000 Pounds (14 C.F.R. § 91.9{a)) 

Respondent denies that the weight ofthe engine cargo exceeded 10,000 pounds, 

preferring to admit solely to errors in the manifest. However, the evidence shows that the 

engine cargo, which Respondent was shipping for Continental Airlines, did exceed 10,000 

pounds. 

First, Respondent's own "Load Planner- Weight Manifest" shows that the engine 

cargo exceeded 10,000 pounds. See Kanae Declaration Exhibit G. Respondent's "Load 

Planner- Weight Manifest" shows a weight of9450 pounds in zone 8, and 546 pounds in 

both zones 7 and 9. The total for these weights is 10,542 pounds. Respondent has admitted 

that "because the support for the engine was in zone 8 all of the engine weight was in zone 

8." Respondent's Answer, p. 1, ~ 4. Thus, according to the load manifest, the weight in 

zone 8 was 10,542 pounds, well in excess of 10,000 pounds. 

Second, Continental Airlines shipping documents show that the engine cargo 

exceeded 10,000 pounds. See Declaration of Catherine Flores, Declaration of Clarence 

Kanae, and Exhibits to the declarations, which also support a weight of 10,542 for the 

2 See also Respondent's Answer, p. 1, para. 3, wherein Respondent states" ... the error in the subject load 

manifest was inadvertent and immaterial. .. ". See also Respondent's Answer, p. 1, para. 4, wherein 

Respondent states "(t]he personnel who created the load manifest had an inaccurate weight for the engine," and 

it "contained some technical inaccuracies." 
6 

engine as shipped. As indicated in Ms. Flores's Declaration, Exhibit C (Continental Airlines 

"Air Waybill" for the flight) shows a total weight for the engine (in 3 pieces) of 10,400 lbs. 

Exhibit D (Asia Pacific's "Cargo Manifest") for the flight shows that the 3 pieces were split 

into two pallets for shipping, pallet PAG72083CO and PAG72217CO. Exhibit E 

(Continental Airline's "Unit Load Device I.D. Tag and Dispatch Record" for pallet "PAG 

72217") shows 316 lbs were placed on pallet PAG72217CO with some other items, for a 

total weight of 517 lbs. With 316 lbs removed from the original 10,400 lbs, the remaining 

engine cargo weight would have been 10,084 lbs. This remaining 10,084 lbs was placed on 

pallet PAG72083CO, with some other items, for a total weight of 10,542 lbs. See Exhibit F 

(Continental Airline's "Unit Load Device I.D. Tag and Dispatch Record" for pallet "PAG 

72083"). Thus, the Continental Airlines shipping documents also support the fact that the 

weight of the engine cargo as shipped exceeded 10,000 pounds. 

Respondent contends that the weights shown on the above documents were in error. 

In support of its contention, Respondent provided a letter dated April20, 2011, along with 

some documents. See Kanae Declaration Exhibit H. Although the documents provided by 

Respondent show the weight for a typical CFM56-7 engine (the type of engine in this case) 

as shipped, rather than the particular engine in this case, they are worth examining. Page 3 

ofKanae Declaration Exhibit H, is an April15, 2011 email from Ms. Lois Santos of 

Continental Airlines, showing the weight for a CFM56-7 in the shipping stand to be 9800 

pounds. Page 5 ofExhibit H shows the dry weight for a CFM56-7 is 5,216 pounds, and 

page 6 ofExhibit H shows the weight ofCFM-56-7B engine stand to be 4,620 pounds. 

When added together, the weight provided for the typical engine and typical engine stand is 

5,216lbs. + 4,620 lbs. = 9,836 pounds, which is relatively close to the 9800 pounds 
provided in the Lois Santos email. At first glance, these documents appear to support 

Respondent's contention that the engine cargo did not exceed 10,000 pounds. However, as 

stated above, these documents provide weights for a typical engine as shipped, not the 

engine in this case. 

The engine as shipped in the case at hand was different than the typical engine as 

shipped discussed above. As indicated in the Declaration of Ms. Catherine Flores of 

Continental Airlines, she witnessed the weighing of a typical CFM56-7 prepared for 

shipping, and it weighed 9,812 pounds. This figure is relatively close to the 9800 pounds 

provided in the Lois Santos email, and the 9,836 pounds provided in the other documents 

7 

with Respondent's April20, 2011, letter discussed above. However, in viewing the photo of 

the engine in the case at hand, Ms. Flores noticed a key difference. She noticed that the 

engine in the case at hand had something extra that the typical engine she weighed did not. 

The engine in the case at hand still had the casters (wheels) attached to the shipping stand, 

whereas the engine she weighed did not. Declaration of Ms. Catherine Flores, at 2:8-13. 

The casters weigh a total of 680 pounds. I d. When added to the weight of the typical 

CFM56-7 prepared for shipping, the total weight of the shipped engine would be 9,812lbs. 

+ 680 lbs. = 10,492 pounds. I d. Thus, the typical CFM56-7 engine as shipped with the 

casters (wheels) would have weighed approximately 10,500 pounds. This is relatively close 

to the 10,542 provided in Respondent's own manifest, and the Continental Airlines 

documents. Thus, not only do the actual shipping documents show that the engine shipment 

in this case exceeded 10,000 pounds, the typical engine as shipped with casters (like the 

engine in this case) also exceeds 10,000 pounds. Thus, Respondent violated 14 C.F.R. § 

91.9(a). 
8 

IV. SANCTION. 

As demonstrated above, Respondent operated a Boeing 727 from Majuro Atoll to 

Honolulu International Airport, while carrying an engine in a manner that exceeded the 

operating limitations ofthe aircraft, a violation of 14 C.F.R. § 91.9(a). Additionally, 

Respondent prepared an inaccurate load manifest, in that Respondent's manifest showed the 

engine cargo spread over 3 loading zones, when in fact the weight of the engine cargo was 

limited to a single zone. This is a violation of 14 C.F.R. § 121.665. Finally, even if 

Respondent were correct about the engine cargo weighing less than 10,000 pounds, the 14 

C.F.R. § 91.9(a) violation (overweight engine cargo) would simply be replaced by a second 

14 C.F.R. § 121.665 violation (inaccurate manifest) for showing the engine weighed more 

than 10,000 pounds on the manifest. 

Pursuant to 49 U.S.C. § 46301, Respondent is subject to a civil penalty not to exceed 

$27,500 for each violation. Respondent committed two violations: One 14 C.F.R. § 91.9(a) 

violation, and one 14 C.F.R. § 121.665 violation (or, alternatively, as Respondent contends, 

two 14 C.F.R. § 121.665 violations). Thus, Respondent is subject to a maximum civil 

penalty of $55,000. However, for this case, Respondent simply seeks a civil penalty of 

$19,250. This is an appropriate amount for a single violation of either 14 C.F.R. § 91.9(a) 

violation, or 14 C.F.R. § 121.665. Again, although a civil penalty of double this amount 

($38,500) would be appropriate because of the two violations committed by Respondent, 

Complainant is simply seeking an amount based on a single violation. 

A civil penalty of $19,500 for a single violation of either 14 C.F.R. § 91.9(a) or 14 

C.F.R. § 121.665 is consistent with the FAA's sanction guidance. The FAA's publicly 
9 

available sanction guidance table is contained in Appendix B ofF AA Order 2150.3B. 3 

Operation of an aircraft while exceeding the operating limitations (14 C.F.R. § 91.9(a) 

violation) is analogous to operation in non-conformity of the aircrafts type certificate, which 

may have an adverse effect on safe operation of the aircraft. The sanction guidance 

recommends a moderate to maximum civil penalty for such a violation.4 Similarly, the 

sanction guidance also recommends a moderate to maximum civil penalty for the inaccurate 

manifest (14 C.F.R. § 121.665) violation. 5 As Respondent is a Group II large business6

, 

the maximum civil penalty range is $17,875- $27,500, and the moderate civil penalty range 

is $9,625- $20,624.7 FAA Order 2150.3B, Chapter 7, Subparagraph 5-b(3) instructs to 

"begin with an amount in the middle of the range, and increase that amount toward the 

higher end of the range for aggravating factors or decrease that amount toward the lower end 

of the range for mitigating factors." The middle of the range between $9,625 and $27,500 is 

$18,562. The penalty could have been substantially increased by the fact that there were 

actually two violations, rather than a single violation, but it was not. The penalty could have 

been substantially increased by the fact that aggravating factors exceeded any mitigating 

3 FAA Order 2150.3B can be found at 

http://www. faa.gov/regulations policies/orders notices/index. cfrn/go/document.information/documentlD/1721 

3. 

4 See FAA Order 2150.3B, Appendix B, Figure B-1-1(2). 

5 See FAA Order 2150.3B, Appendix B, Figure B-1-k(l), which recommends a moderate to maximum civil 

penalty for any violation of subpart U of 14 CFR part 121. 14 C.F.R. § 121.665 is contained in subpart U of 14 

CFR part 121. 6 "In determining the concern's size, SBA counts the receipts, employees, or other measure of size of the 

concern whose size is at issue and all of its domestic and foreign affiliates, regardless of whether the affiliates 

are organized for profit." 14 C.F.R § 121.103. Asia Pacific Airlines is an affiliate of Tan Holdings. See 

http://www.tanholdings.com/index.php/sbu/. "Tan Holdings Corporation employs more than 4,000 people in 

the Western Pacific Region." See http://www.tanholdings.com/index.php/ourpeople/ under "Commitment." 

The maximum number of employees for an air transportation freight company to be considered a small 

business is 1,500 employees. See FAA Order 2150.3B, Appendix B, subparagraph 3-b. Thus, Respondent is 

considered a large business concern. 7 See FAA Order 2150.3B, Appendix B, Subparagraph 3-c(l). The amounts shown above are the amounts 

provided in FAA Order 2150.3B, as adjusted for inflation. See 75 FR 72935 (October 29, 2010) and 14 C.F.R. 

13.305. 
10 

factors, but it was not. Although a significant increase in the civil penalty would have been 

justified, the penalty was increased only slightly, to $19,250. The factors affecting the 

sanction are discussed in more detail below. 

"If a violation is deliberate or not inadvertent, a sanction at the upper end of the 

range or exceeding the range for that type of violation is generally appropriate." 8 By its 

own admission, Respondent claims that it knew of the manifest error, but attempts to justify 

the error by stating that "the flight was already late departing and we decided not to redo the 

... paperwork." See Kanae Declaration Exhibit H, p.1, ,-r 3 (Respondent's April20, 2011 

letter responding to Complainant's Letter oflnvestigation). However, as noted above, 

despite Respondent's deliberate operation with a known manifest error, the civil penalty 

amount was increased only slightly. 

Additionally, Respondent contends that Complainant "improperly considered prior 

alleged violations." (Respondent's Answer, p. 2, ,-r 5).9 However, the civil penalty amount 

was not increased due to prior violations. 

Another factor that can be considered in setting the penalty amount is the degree of 

hazard imposed by a Respondent's action. "[A ]n increase in the degree of hazard may form 

the basis for exceeding the sanction ranges." 10 Respondent argues that its manifest error 

regarding the engine weight was inadvertent and immaterial" and "did not ... represent any 

safety risk." However, recordkeeping violations are not trifling matters. On the contrary, 

they are significant. Complete and accurate recordkeeping is the linchpin ofF AA's 

8 FAA Order 2150.3B, Chapter 7, Subparagraph 4-b. 

9 See FAA Order 2150.3B, Chapter 7, Subparagraph 4-d(l) which states that "[a] prior violation history may 

suggest that a person has a poor compliance disposition, which is an aggravating factor." See also FAA Order 

2150.3B, Chapter 7, Subparagraph 4-h(l), which states that "a violation history can justify imposing a sanction 

at the higher end of the normal range or a sanction beyond the normal range." Thus, the FAA's sanction 

guidance provides for increasing the sanction when a respondent has a violation history. However, as 

indicated above, Complainant did not aggravate the sanction based on a violation history. 

1

° FAA Order 2150.3B, Chapter 7, Subparagraph 4-e(2). 
11 

oversight and enforcement. Complete and accurate recordkeeping is essential for the FAA 

to fulfill its mandate of assuring that operators comply with safety standards. See Watts 

Agricultural Aviation, Inc., d/b/a Growers Air Service, FAA Order No. 91-8 (April11, 

1991). Incomplete or inaccurate records compromise air safety. Such transgressions merit 

significant penalties. 

Additionally, the potential hazard created by exceeding weight limitations of an 

aircraft cannot be overstated. 

Compliance with the weight and balance limits of any aircraft is 

critical to flight safety. Operating above the maximum weight 

limitation compromises the structural integrity of an aircraft and 

adversely affects its performance. 

FAA Pilot's Handbook of Aeronautical Knowledge, Chap. 9, Weight and Balance, p. 

9-1 (http:/ /www.faa. gov /regulations _policies/handbooks _manuals/aviation/pilot _handbook/) 

"Because of abnormal stresses placed upon the structure of an improperly loaded aircraft, or 

because of changed flying characteristics of the aircraft, loss of life and destruction of 

valuable equipment may result." FAA Aircraft Weight and Balance Handbook, FAA-H8083-1A. p. 1-1 (http://www.faa.gov/regulations_policies!handbooks_manuals/aircraft/ 

Yet, despite the hazards imposed by Respondent's actions in this case, the amount of the 

civil penalty was increased only slightly. 

The sanction also could have been aggravated by the fact that Respondent is an air 

carrier, and "[a]ir carriers are held to the highest standard of care." 11 As discussed above, 

rather than correcting what Respondent claims was a known manifest error, Respondent 

attempts to justify its manifest error, stating that "the flight was already late departing and 

11 FAA Order 2150.3B, Chapter 7, Subparagraph 4-g. 
~ • n .. 

12 

we decided not to redo the ... paperwork." See Kanae Declaration Exhibit H, p.l, 4jl 3 

(Respondent's April20, 2011letter responding to Complainant's Letter of Investigation). 

This is hardly the actions of an air carrier exhibiting the highest standard of care. 

In summary, although Complainant could have doubled the sanction due to the fact 

Respondent committed two violations, Complainant did not do so. Although Complainant 

could have also used aggravating factors to significantly increase the amount ofthe penalty, 

Complainant did not do so. The sanction sought of$19,250 is only slightly above the 

midpoint ($18,562) of the recommended range for a single violation. Accordingly, 

Complainant's selected civil penalty of$19,250 is well within the range indicated in the 

sanction guidance table, and is not arbitrary, capricious, or otherwise not according to law. 

V. CONCLUSION. 

Based on the foregoing, Complainant is entitled to a decision in its favor that 

Respondent committed the violations charged and should be assessed a civil penalty of 

$19,250. 

Respectfully submitted, 

NAOMI TSUDA 

1 

By: 

Attorney 

Dated: September 13, 2013 
CERTIFICATE OF SERVICE 

I hereby certify that on this date I have placed in the United States mail, postage 

prepaid, the MOTION FOR DECISION, addressed as follows: 

And a copy to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1 000 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office ofHearings, M-20 

U.S. Dept of Transportation 

1200 New Jersey Avenue, SE (Ell-310) 

Washington, D.C. 20590 

I further certify that on this date I have placed in the United States mail, postage 

prepaid, certified mail -return receipt requested, a true copy of the above, addressed as 

follows: 

David Kirstein, Esq. 

Kirstein & Young PLLC 

1750 K Street, NW, Suite 200 

Washington, D.C. 20006 

Mr. Michael Quinn, President 

Asia Pacific Airlines 

156 Diablo Road, Suite 203 

Danville, CA 94526 

Dated: September 13, 2013 

Legal Technician 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Hawthorne, California 

13 
Western-Pacific Region AWP-7 

U.S. Deportment 

·of Tronsporiotion 

Office of The Regional Counsel P.O. Box 92007 

Los Angeles, CA 90009-2007 

Federal Aviation 

Administration 

March 1, 2012 Case No. 2011WP350018 

CERTIFIED MAIL- RETUR.t1>.J RECEIPT REQUESTED 

Aero Mkronesia, Inc. tl!b/a 

Asia Pacific Airlines, Jnc. 

Attn: Michael Quinn, President 

153 Diablo Road 

Suite 203 

Danville, CA 94526 

illld A~:w Micwuesia, Inc., d/b/a 

Asia Pacific Airlines, Inc., c/o 

Joanne \V. Young, Agent for Service 

1750 K Street NW 

.wZlshington, I)C20006 REcEIVED 

AMENDED NOTICE OF PROPOSED CIVIL PENALTY SEP 1 9 2013 

Based on a report of investigation, it appears that . HEARl NG DOCKET 

1. Aero Micronesia, Inc. d/b/a Asia Pacific Airlines ("Aero Micronesia") is now, and at 

all times mentioned herein was, the holder of Air Carrier Certificate No. I5PA400I, 

authorized to conduct flight operations, cargo only, under part 121 of the Federal 

Aviation Regulations ("F ARs"). 

2. On or about March 25, 2011, Aero Micronesia operated a Boeing 727-200 aircraft, 

Civil Registration No. N319NE, on a cargo carrying flight from Majuro Atoll to 

Ii:onolulu Intemational Airport. 

3. Incident to the above operation, N319NE carried an item of cargo, which included an 

aircraft engine in zone 8. 

4. The "Load P:lanner- Weight Manifest" for the above flight shO\ved that the weight of 

the cargo indicated in no. 3 above was distributed across zones 7; 8, and 9. 

5. The weight of the. cargo indicated in no. 3 above was not distributed across zones 7, 

8, and 9, but was instead limited to zone 8. 

6. As a result of allegations 3 - 5 above, the "Load Planner- Weight Manifest" was not 

accurate. 

7. The maxinwm allowable weight in zone 8 ofN319NE was 10,000 pounds. 

8. N319NE cqntained a placard indicating that the maximum allowable weight for zone 

8 \Vas 10,000 pounds. 
9. The \Veight of the cargo indicated in no. 3 above exceeded 10,000 pounds. 

10. Altematively, if it is found that the cargo indicated in no. 3 above did not exceed 

10,000 pounds, then the "Load Planner- Weight Manifest" shovving the total \Veight 

·of said cargo did exceed 10,000 pounds is riot accurate. 

2 

By reason of the facts and circumstances described above, Aero Micronesia failed to exercise the 

degree of care, judgment, and responsibility required of the holder of an air carrier certificate. 

By reason of the foregoing facts and circumstances, it appears that Aero Micronesia violated the 

following Federal Aviation Regulation(s): 

a. 14 C.F.R. § 91.9(a), vvhich states" ... no person may operate a civil ait~craft without 

complying with the operating limitations specified i11 the app.roved Airplane or 

Rotocraft Flight Manual, marking, and placards ... " 

b. 14 C .F .R. § 121.665, which states"[ e ]ach certificate holder is responsible for the 

preparation and accuracy of a load manifest fom1 before each takeoff. .. " 

Based on information on Aero Micronesia, Inc. and its affiliates, it does not appear that Aero 

Micronesia, Inc. is a small business concern as defined in 13 C.F.R. Section 121. Under Section 

4630l(a)(5)(A) of Title 49 of the United States Code, Aero Micronesia, Inc. is subject to a civil 

penalty for each of the violations noted. As adjusted under 14 CFR part 13, subpart H, the 

maximum penalty for each violation is $27,500.00. We propose to assess a civil penalty for the 

violations noted above in the total amount of$19,250.00. 

Enclosed is information on Aero Micronesia, Inc.'s options in responding to this Notice. The 

options include participating in an informal conference with an FAA attorney, and submission of 

information to the FAA for consideration. Aero Micronesia, Inc. must submit, in VvTiting, its 

choice of the alternatives explained on the enclosed information fonn, on or before 30 days after 

it receives this Notice. If Aero Micronesia, Inc. ·rails to submit ·its choice within that time, it \viii 

have no further right to participate in the infmmal procedures. 

In the alternative, Aero Micronesia, Inc. may pay its c.ivil penalty with a credit card over the 

Internet. To pay electronically, visit the web site at http://www.pav.gov. Under the "Search 

Public Fonns" option located on the left side of the page, type F\VP-FINEl and click "Go". 

Click on "FAA Civil Penalty Payments- Westem Pacific Region", complete the requested 

information and click "Submit" to pay by credit card. 
3 

Please direct all communication in tlus matter to Don Bobertz, Attorney, A WP-7. 7, FAA, Office 

of Regional Counsel, P.O. Box 92007, Los Angeles, CA 90009-2007. Telephone number (31 0) 

725-3454. 

NAOMI TSUDA 

Regional Counsel 

By: 

Attorney 

Enclosures 

~)1.. \ J (' '3 
RECEIVED 

SEP 1 9 2013 

HEAAJNG DOCKET 

U.S. Department 

of Transportation 

Western-Pacific Region P.O. Box 92007 

Office of the Regional Counsel Los Angeles, CA 90009-2007 

Federal Aviation 

Administration 

Telephone: (310) 725-3454 

Fax: (310) 725-6816 

April24, 2012 Case No. 2011WP350018 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Aero Micronesia, Inc. dJb/a 

Asia Pacific Airlines, Inc. 

and Aero Micronesia, Inc., d/b/a 

Asia Pacific Airlines, Inc., c/o 

Jomme W. Young, Agent for Service 

1750 K Street NW 

Attn: Michael Quinn, President 

153 Diablo Road 

Suite 203 Washington, DC 20006 

Danville, CA 94526 

FINAL NOTICE OF PROPOSED CIVIL PENALTY 

On March 1, 2012, Aero Micronesia, Inc. was advised through an Amended Notice of Proposed 

Civil Penalty that the Federal Aviation Administration (FAA) proposed to assess a civil penalty 

in the amount of$19,250.00. We have considered Aero Micronesia's response to the Amended 

Notice. 

A report of investigation indicates that: 

1. Aero Micronesia, Inc. d/b/a Asia Pacific Airlines ("Aero Micronesia") is now, and at 

all times mentioned herein was, the holder of Air Carrier Certificate No. I5PA400I, 

authorized to conduct flight operations, cm·go only, under part 121 ofthe Federal 

Aviation Regulations ("F ARs"). 

2. On or about March 25, 2011, Aero Micronesia operated a Boeing 727-200 aircraft, 

Civil Registration No. N319NE, on a cargo carrying flight from Majuro Atoll to 

Honolulu International Airport . 

. :.~ . 

3. Incident to the above operation, N319NE carried an item of cargo, which included an 

aircraft engine in zone 8. · 

4. The "Load Plmmer- Weight Manifest" for the above flight showed that the weight of 

the cargo indicated in no. 3 above was distributed across zones 7, 8, and 9. 

5. The weight of the cargo indicated in no. 3 above was not distributed across zones 7, 8, 

and 9, but was instead limited to zone 8. 
6. As a result of allegations 3 - 5 above, the "Load Planner- Weight Manifest" was not 

accurate. 

7. The maximum allowable weight in zone 8 ofN319NE was 10,000 pounds. 

2 

8. N319NE contained a placard indicating that the maximum allowable weight for zone 

8 was 10,000 pounds. 

9. The weight of the cargo indicated in no. 3 above exceeded 10,000 pounds. 

10. Alternatively, if it is found that the cargo indicated in no. 3 above did not exceed 

10,000 pounds, then the "Load Plru.mer- Weight Manifest" showing the total weight 

of said cargo did exceed 10,000 pounds is not accurate. 

By reason of the facts and circumstances described above, Aero Micronesia failed to exercise the 

degree of care, judgment, and responsibility required of the holder of a11 air carrier certificate. 

By reason of the foregoing facts and circumstances, it appears that Aero Micronesia violated the 

following Federal Aviation Regulation(s): 

a. 14 C.F .R. § 91.9( a), which states " ... no person may operate a civil aircraft 

without complying with the operating limitations specified in the approved Airplane 

or Rotocraft Flight Manual, marking, and placards ... " 

b. 14 C.F.R. § 121.665, which states "[e]ach certificate holder is responsible for the 

preparation and accuracy of a load manifest form before each takeoff. .. " 

Under Title 49 U.S.C., Section 46301(a)(5)(A), Aero Micronesia is subject to a civil penalty not 

to exceed $11,000.00 for each of the violations noted. By reason of the foregoing facts and 

circumstances, we propose to assess a civil penalty in the amount of $19,250.00. 

Unless a request, in writing, for a hearing in this matter is mailed or personally delivered, on or 

before 15 days after you receive this Final Notice, we will issue an Order Assessing Civil Penalty 

and Aero Micronesia will have no further right to a hearing. If a written request for a hearing is 

not received, Aero Micronesia must pay the proposed civil penalty. 

Your request for a hearing must be sent to: (1) For U.S. mail or certified mail- Federal Aviation 

Administration, 800 Independence Avenue, SW, Washington, DC 20591, Attention: Hearing 

Docket Clerk, AGC-430, Wilbur Wright Building-Room 2W1000; (2) for commercial 

expedited courier (overnight mail)- Federal Aviation Administration, 600 Independence 

Avenue, SW., Wilbur Wright Building, Suite 2W1 000, Washington, DC 20591, Attention: 

Hearing Docket Clerk, AGC-430; (3) a copy MUST be sent to the undersigned FAA attorney in 
3 

the Office ofthe Regional Counsel, P.O. Box 92007, Los Angeles, CA 90009-2007, (310) 725-

3454. Your request must be dated and signed, in accordance with Section 13.16 of the Federal 

Aviation Regulations, sent to you with the Amended Notice of Proposed Civil Penalty (14 C.P.R. 

13.16). 

You may pay the proposed penalty by submitting a certified check or money order payable to the 

"Federal Aviation Administration," to FAA!MMAC, AMZ-310-WP/NM, PO Box 25770 

OklahomaCity,OK 73125. 

In the alternative, you may pay your civil penalty with a credit card over the Internet. To pay 

electronically, visit the web site at http://www.pay.gov. Under the "Search Public Forms" 

option located on the left side of the page, type FWP-FINEl and press "Go." On the page 

entitled "Search Public Forms," scroll to the bottom of the page and enter "Next Page." Click on 

"FAA Civil Penalty Payments- Western-Pacific Region," follow the prompts to complete the 

requested information and click "submit" to pay by credit card. Please advise me of the date of 

any payment made over the internet. 

Naomi Tsuda 

Regional Counsel 

For the ~estC\-Pacifi~gL/r::-n71/r---- . 

By: ~\; \ 

Don Bobertz \. 

Attorney 
2 

3 

4 

5 

6 

7 

RECEIVED 

Srp ... 1 9 &:vi "~. 11 i3 

m~ITED STATES OF AMERICA DEPA~TMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC H.E;ARING DOCKET 

In the Matter of AERO MICR PNESIA, 

Respondent. 

FAA Docket No.: unassigned 

FDMS No.: FAA-2012-0468 

FAA Region: Western-Pacific 

Judge: Richard C. Goodwin 

8 DECL \.RATION OF CATHERINE FLORES 

9 I, Catherine Flores, heret y declare and state: 

10 L 1 am over 18 year of age and the following is within my own personal 

11 knowledge. If called as a witnes , I could and would competently testify thereto . 

12 2. . I have been eni.pl yed by United Airlines since February 24, 1997. My current 

13 position is Warehouse Superviso . In that capacity, my duties include overseeing the daily 

14 operations of the Guam Stores V. are house. 

15 3. Exhibit A is a phc to graph taken in May, 2011, of a CFM56-7B26 engine as . 

16 typically prepared for shipment. The components of the shipment consist of a CFM56-7B26 

17 engine, an AM2811 engine stan< , 1 pallet, 10 straps, and 3 spreader boards. I witnessed the 

18 weighing of these components ir May, 2011, and the total weight was 9,812lbs. 

19 4. Exhibit B is a phctograph provided to me by Don Bobertz of the Federal Aviation 

20 Administration. Mr. Bobertz tal j me that this was also a photo of a CFM5 6-7B26 engine as 

21 loaded on an airplane for shipmt: nt on March 25, 2011. Mr. Bobertz stated that he was trying to 

22 ascertain the correct weight of tl: e engine shipment. He provided me copies of Continental 

23 Airline's and Asia Pacific Airlin~s shipping records for this engine, included as Exhibits C- F. 

24 Exhibit C shows a total weight~ r the engine (in 3 pieces) of 10,400 lbs. It appears from Exhibit 

25 D that the 3 pieces were split int ~ t\VO pallets for shipping, pallet PAG72083CO and 

26 PAG72217CO. Exhibit E show 316lbs were placed on pallet PAG72217CO with some other 

2 7 items, for a total weight of 517 l ps. With 316 lbs removed from the original 1 0,400 lbs, the 

28 remaining engine weight would ~ave been 10,084 lbs. Exhibit F shows this remaining 10,084 

FDMS No. F.M-2012-0469: DECLARiATION Of CATHERINE FLORES 
lbs of the engine placed on pallet PAG72083CO, with some other items, for a total weight of 

2 10,542 lbs. 

3 5. Mr. Bobertz inqui ed ao:; to the discrepancy between the weight of9,812 lbs. that I 

4 provided for the typical CFM56- B26 shipment (Exhibit A), and the weight of 10,542 lbs. 

·s indicated in the shipping docume ts as discussed above. My original thought was that the 

6 shipping weight of 10,542 pound indicated in the shipping documents was wrong. I believed 

7 that th.e weight o~the engine asp cpared for shipping should be closer to 9,812 pounds like it 

8 was when I weighed the similar gine in May, 2011. However, when Mr.·Bobcrtz provided me 

9 with the photograph of the engin as shipped (Exhibit B), I noticed that the engine shown in 

10 Exhibit B still had the casters (wl eels) attached to the shipping stand, whereas the engine shown 

11 in Exhibit A did not. All four ters weigh a total of 680 pounds. If the four casters had been 

.12 left on the t)rpic~l shipment sho in Exhibit A, the shipment would have weighed 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27. 

28 

approximately 9,812 l~s plus 68 lbs, for a total of 10,492 lbs. 

I declare under penalty o pcijury that the foregoing is true to the best of my knowledge 

and that this declaration was exe utcd at Barrigada,!.:: on September 12,2013. 

. c~G~\i~ CATH~E FLORES 

2 

FDMS No. FAA-2012-0469: DECT..A.R TION OF CATHERINE FLORES 
. ' 

i 

Actual Scale Weight 

Engine Model: CFM56-7B26 

Engine Stand: AM2811 

1 pallet 

10 straps 

3 spreader boards 

Total Weight: 9,812 lbs. 

TO . .~ BY f.IRST CARRIER 

1 .... ~ . CO*'IINENTAUt.: 

AIRPORT OF DESTINATION 

HANDUNG INFORMATION 

NO. OF 

PIECES 

RCP 

8

' DANGEROUS 

GROSS 

WEIGHT 

uuo U0~0 UUf:J. 

continental ~~ Airlines~" 600 JEFFERSON 

HOUSTON, TEXAS 77002 

Received In good order and condition at---,---- on __________ _ 

Place Oaterome 

Signature o'i Consignee or his agent 

ALSO NOTIFY NAME AND ADDRESS (OPTIONAL ACCOUNTING INFORMATION) 

NATURE AND OUANllTY OF GOODS 

ONCL. DIMENSIONS OR VOLUME) 

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cM'Bition 'except ashoted )'lere~! / ·.. !/' 7 

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AI~"'J'-

Oi' DESTINA110M 005. 0075 
3-25-11; 11: 19AM; 

Asia Pacific Airlines 

P.O. Box 24858 

Barrigada, Guam 96921 

Tel: 1-671-647-0050/51 

Fax: 1-671-647-1086 

www.flyapa.com 

( ; 671 647 1086 

Flight No: Magellan 319 

Aircmft Registration No: N319 N E 

Date: March 25, 2011 

Point of Lading: Guam 

PointofUnlnding: Honolulu 

ETD: 

GUM-HNL IS! 

PAG72083CQ. 

IZ10506950075P 1 

PAG72217CO 

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ACFT ENG IN 

ACFT ENG IN 

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315L CONTINENTA GUMLAX P 

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• 6497635 CMICARGO 

Conti!Je.ntal q Airltnes ~ ® 

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CMI CARGO 01 ;25;46 p.m. 03-25-2011 1/2 

UNIT LOAD DEVICE 

f.D. TAG and DISPATCH RECORD ..... Origin CONTAINER NUMBER Flight II Date }Jt!Y v1st Transfer 

/lhl L mrPfl/ 

2nd Transfer .~ .((t I ~I PAC1 77.-?.--(/ Destination . -- DOCS SPECIAL 

COMPLETE AIR WAYBILL NUMBER WEIGHT· Speclry 

Y/N PIECES Pounds or Kilos SHIPPER COMMODITY DSTN SRTY CODE 

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C') • No more than 2 holes on any side, notto exceed 3-inches long (7.62cm). co 

E - No holes or obvious cr~cks in the base, top or interior support brackets 

co • No more than 2 holes in the curtain. Holes cannot exceed 2-inches in length {5.08 em) and holes must be at 

Qrn least 20 inches (50.80 em) or more apart ~~ -All curtain strap clips and lock-down points are present and serviceable =E - No more than 1 rivet missing per base side .c·- ·-

m....l 

(1) Pallets r&,i•!rs· ~~kJf'tr~c~··.o - No holes or obvious cracks in the base or broken or 1 ]$~(hg. t'6m rs ; l; (,) 

-~ • Netting is in serviceable condition (no breaks, cuts or!ft?~bmd less thao 3:y~-- C1) - All net lock clips are presEI'iti<Bhd servlcea61e Z!UJ;;;~nta: tn - Net attachment points must have at le¢'3 serviceable lock-tracks on each side of the_attach point 

Verify ULD Net Weight ,uut!S uLu uvernang'? ?es Ll f\l6~~ ;.;--w 

T L6 jl'll U 

Does ULD Exceed 64"/162cm in ~~iQf.if fti.'!~ N ILl n· Yt:~, DO NOT LOAD ON AIRCRAFT 

SIGNATURE OF LOADING AGENT EMPLOYEE# I EJ.t:!~L DESTINATION OUJ.l.O----·-

~- ...zt:.? '1_,.(. ·"· ~ I -~ 

[TOTAL NET WEIGHT OF ULD 

FS-503A (OCT 201 0) 

M&E 00-0734-3-0030 

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( 

• 6497635 CMICARGO 

Continental~~ 

Airlines~~ 

( 

CMICARGO 12:26:00 p.m. 03-25-2011 2/2 

UNIT LOAD DEVICE 

f.D. TAG and DISPATCH RECORD 

Origin Flight Date CONTAINER NUMBER 

~------+----4----~--~ 

1st ll"anafer 

2nd Transfer 

Deatlnation 

DOCSYIN COMPLETE AIR WAYBILL NUMBER PIECES WEIGH't. Sptcity Pounds or Knos 

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SPECIAL 

SHIPPER COMMODITY DSTN SRTY 

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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

RECEIVED 

SEP f 9 2013 

HEARING DOCKET 

In the Matter of AERO MICRONESIA, FAA Docket No.: unassigned 

FDMS No.: FAA-2012-0468 

Respondent. FAA Region: Western-Pacific 

Judge: Richard C. Goodwin · 

8 DECLARATION OF CLARENCE K. KANAE 

9 I, Clarence K. Kanae, hereby declare and state: 

10 ]. I am over 18 'years of age and the following is within my own personal 

1 1 knowledge. If called as a witness, I could and would competently testify thereto. 

12 2. I have been employed by the Federal Aviation Administration since August 20, 

1J 1995. My current position is an Aviation Safety Inspector. More specifically, I'm an Air Carrier 

14 Principal Operations Inspector in the Honolulu Certificate Management Office. In that capacity, 

15 my duties include oversight for the operation of Aero Micronesia Inc. (also known as Asia 

16 Pacific). Oversight of Aero Micronesia and other operators includes evaluation of airmen, 

1 7 training programs, equipment (aircraft) and facilities. I also conduct investigations of incidents 

18 and accidents for potential violations of the Federal Aviation Regulations. . 

19 3 .. Prior to working for the FAA, I spent time as a first officer for a part 121 air 

20 carrier, and as president/CEO and owner of a helicopter company (accredited for part 135, part 

' 21 141, and part 61 operations). lhave over 41 years of military service. 

22 4. I have air transport pilot ratings for fixed wing multi-engine land airplanes and 

23 rotocraft. I am a certified flight instructor for multi-engine and single-engine airplanes l;ind 

24 rotocraft. I am type rated in the B~727, SD-3;SK-I, artd S-70 aircraft. I am a certified flight 

25 engineer for turbojet. I have a total of approximately 16,200 pilot hours. Of these, I ,500 are 

26 multi-engine airplane, 2,700 are single-engine airplane, and 12,000 are helicopter, including 

. 27 5,000 hours in military helicopters, 590 of which were combat flight hours in Iraq. 

28 

FDMS No. FAA-2012-0469: DECLARATION Of CLARENCE KANAE 
5. As the FAA's Principle Operations Inspector over Aero Micronesia (a.k.a. Asia 

2 Pacific Airlines), I conducted a ramp inspection on Asia Pacific's Boeing 727-200, Civil 

3 RegistrationNo. N319NE at the Honolulu International Airport (HNL) on March 25, 2011. 

4 During the ramp inspection, I photographed the engine cargo, and I obtained several documents 

5 in relation to the flight. Statements 6- 10 below refer to the photograph and documents as the 

6. Exhibits are identified in the Declaration of Catherine Flores: 

7 6. Exhibit B is a true and correct copy of a photograph that ltook of the engine 

8 cargo on the aircraft, upon arrival of the flight in Honolulu. 

9 7. 

1 0 the flight. 

11 

12 flight. 

13 

8. 

9. 

Exhibit C is a tr:ue and correct copy of the Continental Airlines "Air Waybill" for. 

Exhibit Dis a true and correct copy of Asia Pacific's "Cargo Manifest" for the 

Exhibit Eisa true and correct copy of Continental Airline's "Unit Load Device 

14 I.D. Tag and Dispatch Record" for pallet "PAG 72217" for the flight. 

. . 

15 10. Exhibit F is a true and correct copy of Continental Airline's "Unit Load Device 

16 I. D. Tag and. Dispatch Record" for pallet "PAG 72083" for the flight. 

17 

18 

12. 

13. 

Statements 13 & 14 refer to documents attached to my Declaration. 

Attached-hereto as Exhibit G is a true and correct copy of Asia Pacific's "Load 

19 Planner- Weight Manifest" ("Load Manifest") for the flight. 

20 14. Attached hereto as Exhibit H is a true and correct copy of a letter dated April 20, 

21 2011, with attachments; which I received from Mr; Michael R. Quinn, President of Asia Pacific 

22 Airlines. 

23. I declare under penalty of perjury that the foregoing is true to the best of my knowledge 

24 and that this declaration was executed at Honolulu, Hawaii (city, state) on September 12,2013. 

25 

26 

27 

28 

A~~~~K;);;· ~~·'-:::::::::::::::?-- - CLARENCE K. KANAE 

2 

FIJMS No. FAA-2012-0469: DECLARATION OF CLARENCE KANAE 
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c:;71siR pneifie c:;71irlines 

156 Diablo Road, Suite 203 

Danville, CA 94526 

Tel: 925-362-4430, Fax: 925-362-4432 

April 20, 2011 

Mr. Clarence Kanae 

Principal Operations Inspector 

Federal Aviation Administration 

135 Nakalo Place 

Honolulu, HI 96819-1845 

RE: F'ilc No. 2011WP350018 

Dear Mr. Kanae: 

... ~ •! .... , ·-----·-·-··""-"'._. .... ..._ .... !,., : ..• '· 

' .... f ,, ... 

We are in receipt ofyour letter dated April 7, 2011 regarding the carriage of an engine on our 

aircraft N319NE. Over the years, Asia Pacific has carried several Continental CFM engines and we 

consider this an essential piece of business for both our airlines to be able to efficiently serve the 

Pacific and Micronesian markets. We are also fully aware of the zone weight restrictions on all our 

aircraft as >veil as the fact that the engines in question together with their engine stands weigh close 

to 10,000 lbs. The specific problem on this flight began when we received an A WB from 

Continental that showed the engine and stand weighing 10,400 lbs. We knew this to be incorrect, 

however while our operations people were filling out the preliminary W & B fonns using that 

figure, others were contacting CO to get the paperwork and weights conected to what we knew they 

should be. 

I have attached an email from CO showing the conect weight of the engine as 9,800 lbs. 1 have 

also attached 2 other documents, one showing the weight of the engine as 5,216lbs. and the other 

showing the weight of the engine stand as 4, 620 lbs. These independently verify the weight of the 

engine supplied to us in the attached CO email. But prior to loading the engine when we were still 

attempting to get the cmTect paperwork, we requested that some of the weight of engine be 

removed. 2 pieces were removed weighing a total of 316 lbs. and our records show this amount 

placed on the pallet weighing 737lbs that was placed in zone 10. Removing 316 lbs. reduced the 

actual overall weight of the engine and stand to 9,484 lbs. The LD7 and assorted material used to 

secure the engine weighed 458lbs bringing the total actual weight in Zone 8 to 9,942 lbs. 

Unfortunately, by the time this was accomplished, the flight was already late departing and we 

decided not to redo the W & B and associated Hazmat paperwork. It should also be noted that it is 

a conm1on practice throughout the cargo industry to average weights across more that one zone 

when carrying engines and other large objects that actually extend across more than one zone. This 

is indicated by various STC restrictions placed on how much weight can be placed across two zones 

in some cases and on how much running weight can be placed across multiple zones in others. 
.. 

Mr. Kanae letter 

April 20, 20 11 

Page 2 

( r ' ( 

So aside from the fact that the actual weight carried in this particular circumstance was less than the 

limitation for the zone involved, had the weight been a few hundred pounds over the limitation, 

because the 2 zones on either side were empty, no real harnJ or violation occurred. 

As always, we are available at any time to discuss these matters. 

Sincerely, 

~-;;? f/0· ~/ 0-:ff. ,.. /'~--·~..__...-- / .~··,'""' -"\ 

Michael It' Q~1im1 President 

Enclosures: 

Cc: Joe San Agustin 

Mike Daniel 

Robert Walker 

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Santos, Lois [lois.Santos@coair.com] 

Friday, April i 5, 2011 3:35 PM 

'BATALIG@Fl YAPA.COM' 

GUM Materials; Crisostomo, Raymond 

ENGINE CMF56-7 

( 

Here are the dims and the weight for the CFM56-7 in the shipping stand. 

LIE_ng~in_e_s_iz_e_i_n_sh~ip~p_in~g_s_ta_nd __________ ~l · 

lcFM56~7 

Brgds, 

Lois Santos 

GUM AOG Desk 

lasH 

Phone: (671) 645-8868 

Fax: (671) 479-8747 

Email: Lois.Santos@coair.com 

19800WEIGHT 

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CFM56-7/CFM56-7B, CFM56-7B Evolution, CFM56-7BE Page I of 5 

, .• SHflRE f1 : · · 

CFM56 

JOC: 1974 

Total Production: 21,154 

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roc: .t997 

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contract worth $360 million was linked to the purchase of 30 firm order 

Next-Generation Boeing 737 with options on 10 more jets. The second 

contract came from lndia's newest start-up, low-cost carrier SpiceJet which 

ordered 10 firm order 737-800s with option on 10 more. The 20 firm order 

engines were valued at $120 million. Both carriers will take delivery of their 

firsts CFM56-7B powered aircraft in 2006. 

Ryanair selected the CFM International CFM56-7 engine to power 70 Boeing 

737-BOOs with options on 70 additional aircraft In February 2005. The Arm 

engine order for approximately 140 engines was valued at $900 million. 

L" '•.7 ' On 14 June 2005, CFM International was awarded purchase orders for up to 

· .. ~·--~~~-- ... --·.---.... ·- ~ ..... :""·~~:~r.tS: ------rr-2;;,uoFr"t-:~F;:;M~5~6;.,_~,B engines to power 10 8737-BOOs ordered by Jet Airways; 20 

B737s ordered by GECAS; and another 20 B737-700s/-800s ordered by 

TLFC. The 120 engines estimated value was $600 million . 

.. ...... ---··-------~ ---- -·-------------- On 15 June 2005, US carrier Alaska Airlines ordered up to 100 Boeing 737-

. ---~·--·--~---·-~-----------"!I!'!'I01TIJ!r'!'l!~!"'"(3'!"5~+1!'11";:,~:;.so) powered by CFMS6-7B engines. Tile firm engine order to 

power 35 aircraft was valued at $420 million. 

. --- --·- ...... ··--------------------,f'!'lti;-'J'ITuTiill'l!\!,.,.2urTO~S, lLFC placed an order for 20 CFM56-7B-powered Boeing 737-

----------·.:.?.;;:0~bo;;s/~-,;;;8~0~0;;.s::-;.-iThe engine _were_ valued.· at $240 million. Jet Airways also 

• ·-... ··" .. _ ---~ .. - ...... ~ ....... -----10" • p~rchased 10 .. Boeing 737-800s powered by ~he sarne engine with the 

.. ·b\ · · e·nuin~·or,de~ yalued at $120 million. . . · 

. ~.:16 :lJq COU,!DIG'& CO ·1\ OL QihJi!C9iG C~ On 16 June 2005, .Spanish carrier Air Europa ordered 18 Boeing 737-800s 

plus 12 aircraft opt.io.ns powered by CFM56-7B engines. The engines order 

ht!p://www.deageLcom/lllrbofan-engines/cfm56-7 __ aOO I 7 38006.aspx 4/l/2011 

S){. ~, p.· 
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CFM56-7/ CFM56-7B, CFM56-7B Evolution, CFM56-7BE Page 2 of 5 

was valued at $220 million. 

On 29 March 2006 General_ Electric Commercial Aviation Services (GECAS) 

placed ~n order With Boemg for 30 firm and 30 option Boeing NextGeneration 737 valued approximately at $4 billion. The firm aircraft were 

~et to be delivered to GECAS between 2008 through 2010. This contract 

Included the Boeing 737-900ER and 737-800 models powered by CFM56-7B 

engines valued at $400 million. 

On 20 April 2006 Southwest Airlines converted options into firm orders for 

79 Boeing 737-700 airplanes worth $4.5 billion. Aircraft deliveries were 

expected to start in 2007 and will continue until 2012. In Parallel Southwest 

Airlines announced the selection of the CFMS6-7B engine to power its 

newest 79 Boeing 737-700 airplanes. The engine contract was valued at $1 

billion. 

On 25 April 2006 Boeing and Singapore Aircraft Leasing Enterprise (SALE) 

announced an agreement for 10 firm order next-Generation 737-800s plus 

10 options and 10 purchase rights. The order was valued at $675 million 

and aircraft deliveries were scheduled to run from 2009 through 2010. SALE 

selected the CFM56-7B engine to power its 737 airplanes. The deal with 

General Electric was for 20 firm order engines, 10 options and another J.O 

purchase rights. The firm order engines were valued at $140 million list 

price. 

On October 11, 2006, California-based Willis Lease Finance Corporation and 

CFM International announced a purchase agreement on 45 CFJV\56-SB and 

CFJV\-56-7B spare engines worth $540 million. Engine deliveries were 

scheduled to begin in 2007 and continue through 2011. The contract 

included an option for an arJditional 30 engines. 

Di!ll'Wiii.OI.~; Fan Dipme-ter 1,550 mm, Length 2.5 m 

// 

l!.Y.Qi.!Jl!L5.: Dry 1eight 2,366 kg.(5,21G'Ib) 

fl1!JIIlf!!!i.EJ:JJ.9.J~cg; Thrust 27,300 lb (12,383 kg) 

------- !'2.9.mf_aJ~>_2uJ.x 19 Jit.tQ GECAS firm order for 40 Boeing 737-800 jetliners valued at $3 bilfion. Deliveries are expected to 

begin in 2013. These aircraft will be powered by CFM International CFM56-7B engines valued at $560 million. The deal was 

announced on July 19, 2010, at the Farnborough air show. 

II BJ.?b'S ... 1JL.Qp_Jj.f)J.§;_() ....P..<J rc l.wse .Bi!JJJ1.?.Lf! 

M.Q!'iSlJ:li~J.rif 05, :?OIQ Virgin Blue order placed with CFM International CFM56-7BE engines to power 50 firm order Next 

-Generation Boeing 737 airplanes. The order also includes options for 25 airplanes and pruchase rights for another 30 

jetliners all of them pof.ier.etl b'{~\t~.etqf-~(l"-\1'!3;''engine. The firm order engine cteal Is valued at $700 million. The deal was 

announced on April 5, 2910. D,ehveries b're'cl~u~'to commence in the mid-2011. 

JJ..~!,L!.Lfi;._J.QQ.._QR.fion!ifL"fr.t •. eurclwse RiJl.!J1?:.. 6Q · r· . -:)t· .._ ....... _ . .. ..... -~·,..to..............,- .......... ~ ... ~,... 

·' · Wegn§'.iiMY~J.!ill.t_..LQ, __ fu~q{l. · ;JVl~f'a'ysia Airlines order for 35 Boeing 737-800s plus purchase rights for 20 aircraft to replace 

aging Boeing 737·400s. These aircraft will be powered by CFf\1 International CFMS6-7B engines. The engine contract for 

---~·--·..tl:!.ao.firm..or.der...aitcr.aft • .w.as..v.al.u.ruL~I!ml:..:!Jl!t..!i~<JJ.Lv.t.Q;> announced at Farnborough International Airshow on July 

16, 2008. 

,. 

t!.Qt1J!.?!.'LJ.t,JlJL1-~.Q!I Low-cost carrier FlyDubai order for 50 Next-Generation Boeing 737--800 airliners valued at $3.74 

··---·-'"biHion:-Fiyl3ubai-has..-!<t~bst~t1>!t;ie!.l•t-iflh~nv.er.t.itG..l3.7...SOQ.ar.ders to 737-900ERs. First deliveries are scheduled for mid2009 and w(ll continue through 2016. The'CFM56-7B engine contract wa·s valued at $700 million. The deal was announced 

· ... · ~·--aTFal'IiDbrtr01,11'i-rntematitma1"orr:Jt11v-1"4~0~--~- "·---' 

)lern§;__?-Q..... · · 

·w<\dn~~£!s;Lja;0~~~~;~ i~ii/:i~·ll:~~i\t:£1\}~-~~r 'Siacecl "'~·jlth Boeing for the supply of 70 Next-Generation 737s, 15 

787s, 10 777.~_300ERs and five 7~2'.::.~-~~.,worth $10.9 billion. The aircraft deal was announced on January 2, 2008. DAE 

4/1/2011 http://rvww.deagel.com/turhofan-engines/cfm56-7 _aOO 1738006.aspx p){ ~ f JJ· s -
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AGSE ·· Engine Stands- AM-2811 & AM-2563-200 CFM56-7B engine stand 

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: I HAZARDOUS MATERIALS PILOT-IN-COMMAND 

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I DANGEROUS GOODS 03/25/11 

I Departure ---·--- A I .. ..,u., As1a Pacif1c A;rlrnes 

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A:rway Bill Numn:er Oeslmauon UN OR ID No 

005 0695 0075 HNL UN3166 

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PO Box 24858, Barrigada, Guam 96931 

Tel: 1·671-647-0050151 Fax: 1-671-647-1086 

Prop:::r Name 

Engines, Internal Combustion, 

flaplmable pquid Powered 

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___________________________________________

312512011115 PM 
.. 

UNIT LOADDEVlt.;t 

1.0. TAG and DISPATCH RECORD 

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, Destination 

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ll> Containers 'I 

g> - No more than 2 holes on any side, not to exceed 3-inches long (7.62cm). 

E - No holes or obvious cracks in the base, top or interior support brackets · m - No more than 2 holes in the curtain. Holes cannot exceed 2-inches in length (5.08 em) and holes must be at I 

C 0 least 20 inches (50.80 em) or more apart . · · 1 

~~E -All curtain strap clips and lock-down points are present and serviceable 

:0 ·- - No more than 1 rivet missing per base side 

m ..J Pallets ~ - No holes or obvious cracks in the base or broken or missing corners i 

~ - Netting is in serviceable condition (no breaks, cuts or frays) and less than 3-years old I 

ll> - All net lock clips are present and serviceable . I' 

~-__c_-~et attachme~_oints must hav.~ -~- ~~ se~yiceable lock-tracks on_each,:.~ide of ;he_:~ttach point 

Verify ULD Net Weight Y~~1...: 1 oes ULD Overhang? Yes t.....l No 0 ~ 

"iJ~es ULD Exceed 64"/162cm in Height Y LJ N !ZlitF YES, DO NOT LOAD ON AIRCRAFT _ __j 

. SIGNATURE OF LOADiNG AGE~~= '1--f ' -~OY:J FINAl DE~T:AT:: 0: .jlD -====== __ =_==-ll 

rQTAL NET WEIGHT OF ULD r.; y V" 

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I CONSIGNEE'S ACCOUNT NUMGER "1• I 

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