1

Shaun Christian

From: Shaun Christian <schristian@starmarianasair.com>

Sent: Monday, June 11, 2012 10:37 AM

To: Catherine.O'toole@dot.gov

Cc: 'Tim Bellas' (thbellas@gmail.com); Robert Christian; Paz Christian; Alma Canlas

Subject: DOT-OST-2010-0235 Response to 5.31.12 letter

Attachments: DOT response letter-6 11.pdf

Hi Katy,

Please see the attachment in response to your email dated 05/31/2012.  Be sure to let me know if you have any trouble

opening the attachments or if you have any questions.  I will be uploading a copy of this email along with the attachment

to the docket shortly.

Best regards,

Shaun R Christian

Executive Vice President

Star Marianas Air, Inc.

SMA Hangar ‐ Tinian International Airport

Tinian, MP 96952

Tel:  +1‐670‐433‐9989

Fax:  +1‐670‐433‐9990

http://www.starmarianasair.com
LawOfficesof

Timothy H. Bellas, LLC

A LIMITED LIABILITY COMPANY

_________________________________________________________________________________________________________ 

Cactus&BotonesSt.,GarapanTelephoneNo.(670)3232115

P.O.Box502845FacsimileNo.(670)3232116

Saipan,MP96950Email:tim@bellaslaw.net

June 11, 2012 

Ms. Catherine O'Toole 

Office of Aviation Analysis 

Air Carrier Fitness Division (x-56) 

Department of Transportation 

Washington D.C. 20590 

Re: Response to Your email dated May 31, 2012, Docket DOT-OST-2010-0235, Star 

 Marianas Air, Inc. Application. 

Dear Ms. O'Toole: 

It was gratifying to read that some progress has been made in the application process for Star 

Marianas, Air, Inc. ("SMA"). I have been asked by my client to respond to your above 

referenced email sent to Shaun Christian of SMA.

You have requested certain updated information from SMA, specifically: 

 1. Cost Forecast.

 SMA Response: The cost forecast previously provided remains consistent with 

current projections. Although the cargo market has shown minor changes, the prior 

projections were already based on SMA’s allocation of assets to the cargo market. In that 

regard, two other carriers provide cargo service to Rota from Guam and Saipan using 

larger aircraft and our understanding is that a third carrier may be initiating service 

sometime in the near future. SMA’s cargo operations have been relatively constant 

because generally customers charter the entire SMA aircraft to transport cargo that could 

not be accommodated on one of the larger carriers.

 On the contrary, there is a possibility that the cost forecast could decrease, if direct flights 

 to Tinian are initiated by other carriers. Therefore, the previously provided cost forecast 

 remains our best estimate of anticipated costs for SMA. 

 2. Financial Documents:

 SMA Response: Per your request recently updated financial statements for 

 SMA, from three local financial institutions, First Hawaiian Bank, Bank of Guam and 

 Bank of Saipan, are attached to this copy of this response. However, these documents 
DOT Response Letter-Ms. O'Toole 

June 11, 2012 

Page 2 

 will not be uploaded to the internet. 

 3. SMA Fleet and Corporate Changes.

 SMA Response: SMA added an additional PA32-300 aircraft to its fleet after its 

June 23, 2011 submissions to DOT. SMA’s latest OST Form 4507 and 6410 are provided 

as attachments.

 While the composition of the SMA board and the shareholders remain unchanged, Paz 

 Christian has been elected President and Shaun Christian is now Executive Vice 

 President of SMA. 

 SMA is not operating aircraft of another air carrier. 

 In addition, SMA has recently increased its insurance liability coverage from $2,000,000 

 to $10,000,000. 

Conclusion:

We hope that we have adequately addressed your request for updated information and that the 

process will continue to progress. 

Sincerely,

Timothy H. Bellas 

cc: 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 Paz L. 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 







Office of the Secretary

of Transportation

AGENCY DISPLAY OF ESTIMATED BURDEN 

The public reporting burden for this collection of information is estimated to average 30 minutes per response. If you wish to 

comment on the accuracy of the estimate or make suggestions for reducing this burden, please direct your comments to: U.S. 

Department of Transportation, Office of Aviation Analysis, X-56, 400 7th St., SW., Washington, D.C. 20590. According to the 

Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB 

control number.

NOTE: For information on where to file completed copies of this form, see FILING INSTRUCTIONS below. 

OMB No. 2106-0030 Expires 9-30-2007 

U.S. AIR CARRIERS - CERTIFICATE OF INSURANCE 

POLICIES OF INSURANCE FOR AIRCRAFT ACCIDENT BODILY INJURY 

AND PROPERTY DAMAGE LIABILITY 

FILING INSTRUCTIONS: File a signed original of this form with the Federal Aviation Administration, AFS-260, 800 Independence Ave., S.W., Washington, 

D.C. 20591. (See EXCEPTIONS 1 and 2 below.)

 EXCEPTION 1: If Block 2B on the reverse is filled in because the insured is a commuter air carrier, file a signed original of this form with the Department of 

Transportation, Air Carrier Fitness Division, X-56, 400 7th St., SW, Washington, DC 20590. 

 EXCEPTION 2: For any insured that is located in the State of Alaska (regardless as to whether Block 2A, 2B, or 2C is filled in), file a signed original of this 

form with the Federal Aviation Administration, Alaskan Region Hq., AAL-230, 222 W. 7th Ave., #14, Anchorage, Alaska 99513. 

(Please type information, except signatures.)

THIS CERTIFIES THAT: _______________________________________ has issued a policy or policies of Aircraft Liability Insurance to 

 (Name of Insurer) 

 _______________________________________________________________________________FAA Certificate Number_______________

 (Name, address of Insured U.S. Air Carrier) 

effective from _________________ until ten (10) days after written notice from the insurer or carrier of the intent to terminate coverage is received by the 

Department of Transportation.

NOTE: Part 205 of the Department’s Regulations does not allow for a predetermined termination date, and a certificate showing such a date is unacceptable. 

1. The Insurer (Check One): 

 X is licensed to issue aircraft insurance policies in the United States; 

  is licensed or approved by the government of _______________________ to issue aircraft insurance policies; or 

  is an approved surplus line insurer in the State(s) of _________________________

2. The insurer assumes, under the policy or policies listed below, aircraft accident liability insured to minimums at least equal to 

 the following during operation, maintenance, or use of aircraft in “air transportation” as that term is defined in 49 U.S.C. 40102. 

(Complete applicable section(s) A, B, or C below): 

A. U.S. AIR TAXI OPERATORS (EXCLUDING U.S. COMMUTER AIR CARRIERS) WITH PART 298 AUTHORITY ONLY: 

The aircraft covered by this policy are SMALL AIRCRAFT (i.e., with 60 or fewer passenger seats or with a maximum payload capacity of 18,000 

pounds or less). (Complete separate or combined coverage as appropriate): 

 Separate Coverages:

 

Minimum Limit 

Policy Number Type of Liability Each Person Each Occurrence 

Bodily Injury Liability 

(Excluding Passengers) $75,000 $300,000

Passenger Bodily Injury $75,000

$75,000 x 75% of total number 

of passenger seats installed in 

aircraft

Property Damage $100,000 

X Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required 

minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury. 

Policy Number UA00007129AV12A Amount of Coverage $10,000,000 

 This policy covers CARGO operations only and excludes passenger liability insurance. 

OST Form 6410 

B. U.S. COMMUTER AIR CARRIERS OR CERTIFICATED AIR CARRIERS OPERATING SMALL AIRCRAFT 

XL Specialty Insurance Company 

Star Marianas Air, Inc., 4335 Glendale-Milford Road, Cincinnati, OH 54242 ISMA230M 

May 1, 2012 
The aircraft covered by this policy are SMALL AIRCRAFT (i.e., with 60 or fewer passenger seats or with a maximum payload 

capacity of 18,000 pounds or less). (Complete separate or combined coverage as appropriate): 

 Separate Coverages: 

Minimum Limit 

Policy Number Type of Liability Each Person Each Occurrence 

Combined Bodily Injury (Excluding Passengers other than cargo 

attendants) and Property Damage Liability $300,000 $2,000,000 

Passenger Bodily Injury $300,000 

$300,000 x 75% of total 

number of passenger 

seats installed in aircraft 

 Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required 

minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury. 

Policy Number Amount of Coverage 

 This policy covers CARGO operations only and excludes passenger liability insurance. 

C. U.S. CERTIFICATED AIR CARRIERS OPERATING LARGE AIRCRAFT 

The aircraft covered by this policy are LARGE AIRCRAFT (i.e., with more than 60 passenger seats or with a maximum payload capacity of more 

than 18,000 pounds). (Complete separate or combined coverage as appropriate): 

 Separate Coverages: 

 Minimum Limit 

Policy Number Type of Liability Each Person Each Occurrence 

Combined Bodily Injury (Excluding Passengers other than cargo 

attendants) and Property Damage Liability $300,000 $2,000,000

Passenger Bodily Injury $300,000

$300,000 x 75% of total 

number of passenger 

seats installed in aircraft 

 Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required 

minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury. 

Policy Number Amount of Coverage 

 This policy covers CARGO operations only and excludes passenger liability insurance. 

3. The policy or policies listed in this certificate insure(s) (Check One): Make and Model FAA or Foreign Flag 

 Registration No. 

 Operations conducted with all aircraft operated by the insured Piper PA-32-300 Cherokee N4254R

 Operations conducted with the following types of aircraft: Piper PA-32-300 Cherokee N4089W 

X Operations with the following aircraft: (Use additional page if necessary) Piper PA-32-300 Cherokee N4127R 

 Piper PA-32-300 Cherokee N4267R 

 Piper PA-32-300 Cherokee N4599X 

 Piper PA-32-300 Cherokee N8639N 

 Piper PA-32-300 Cherokee N166CB 

4. Each policy listed in this certificate meets or exceeds the requirements in 14 CFR Part 205. 

XL Specialty Insurance Company 

(Name of Insurer) (Name of Broker) 

One World Financial Center – 200 Liberty Street, 3rd Floor 

(Address) (Address) 

New York, NY 10281 

(City, State, Zip Code) (City, State, Zip Code) 

Richard DeMicco 

(Contact person who can verify the effectiveness of the coverage) (Officer or authorized representative) 

212-915-6829 / 212-945-0829 

(Area Code, Phone Number) / (Area Code, Fax Number) (Area Code, Phone Number) / (Area Code, Fax Number) 

(Signature, if applicable) (Signature) 

May 9, 2012 

(Date) (Date) 

PhoneNumber) / (Area Code, Fax