1 

## Shaun Christian

From: Shaun Christian <schrist ian@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)3232115P.O.Box502845Fa csimileNo.(670)3232116Saipan,MP96950Em ail: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 inOffice of the Secretary of Transportation AGENCY DISPLAY OF ESTIMATED BURDEN
The public reporting burden for this collect ion of information is estimated to aver age 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 7 th St., SW., Washingt on, D.C. 20590. According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of informa tion 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 Av iation Administration, AFS-260, 800 Independence Ave., S.W., Washi ngton, 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 Ca rrier Fitness Divis ion, X-56, 400 7 th St., SW, Wash ington, 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 si gned original of this form with the Federal Aviation Administrat ion, Alaskan Region Hq., AAL-230, 222 W. 7 th 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 allo w 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 capaci ty 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 t o the required minimums stated above for bodily injury (excluding pa ssengers), 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 Glendal e-Milford Road, Cincinnati, OH 54242 

### ISMA230M

May 1, 2012The 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 t o the required minimums stated above for bodily injury (excluding pa ssengers), 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., wi th more than 60 passenger seats or with a maximum payload cap acity 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

Passeng er 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 t o the required minimums stated above for bodily inju ry (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 li sted 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 N4 089W X Operations with the following aircraft: (Use additional page if necessary) Piper PA-32-300 Cherokee N4127R Piper PA-32-300 Cherokee N4267R
Pi per PA-32-300 Cherokee N4599X
Pi per PA-32-300 Cherokee N8639N
Pi per 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, 3 rd 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) Pho ne Num ber ) /

(A rea Code, Fa x