Hangar 1 West Tinian International Airport PO BOX 520461Tinian, MP 96952 Page 1 of 5

May 5, 2011 

US Department of Transportation 

Air Carrier Fitness Division 

Attn: Ms. Laura Remo 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Letter dated April 18, 2011 

In reference to Docket DOT-OST-2010-0235

Application of Star Marianas Air, Inc. 

for Commuter Authority 

Dear Ms. Remo, 

I am in receipt of your letter dated April 18, 2011 wherein you request additional information in relation 

to Star Marianas Air, Inc’s request for Commuter Authority. I have reproduced the requests from your 

letter and included responses to those request below. 

GENERAL INFORMATION

1. Please submit a copy of Star’s current certificate of insurance (OST Form 6410).

RESPONSE: See Attachment Number 1 (OST Form 6410) 

2. Please place a copy of Star’s Preapplication Statement of Intent for commuter authority in the 

public docket of this proceeding, together with information on any changes that have been 

made to this filing since its original submission to the FAA. 

RESPONSE: See Attachment Number 2 (Form 8400-6) 

MANAGEMENT AND KEY TECHNICAL PERSONNEL

1. According to our records, several employees and/or shareholders of Star were once employed 

by Taga Air Charter, Inc., however this data is not reflected in Star’s application pursuant to 14 

CFR 204.3(f)(5) and 14CFR 204.3(g)(4). Please explain this discrepancy. 

RESPONSE: 

According to the guidance provided by the Department (Information Packet on How to Become 

a Certificated Air Carrier; 2002), the Department uses a “three-part test” to determine fitness; 

e.g. managerial competence, operating and financial plans, and the applicant’s compliance 

record (safety violations or fraud). It also states that the applicant must establish that it is 

owned and controlled by U.S. citizens. 
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Therefore, Star believed that the information requested pursuant to 14 CFR 204.3(f) (5) and 14 

CFR 204.3(g) (4), is required by the Department in order to evaluate the managerial competence 

of the Company and establish that it is owned and controlled by U.S. citizens. 

Since Star had been in operation for sometime (1 year & 6 months at the time of submission) 

and had demonstrated its managerial competence, Star interpreted the request for disclosure of 

any such interests by Star's employees or shareholders to be directed at ownership issues and 

therefore believed the disclosure was meant to include interest in existing carriers, etc. 

“...and other [existing] interests each holds or has held in any [existing] air carrier, [existing]

foreign air carrier, [existing] common carrier, [existing] person substantially engaged in the 

business of aeronautics...”

Additionally, the definition of “key personnel” contained in the DOT’s guidance (cited below) did 

not seem to require all stockholders but only those who are key officials and primary 

stockholders that could potentially influence the affairs of Star. 

‘Key personnel” refers to the President, Chief Executive Officer. Chief Operating Officer, 

General Manager, Chief Financial Officer, Vice President(s), the Director of Operations & the 

Director of Maintenance, the Chief Pilot, the Director of Safety, and the Chief Inspector, as well 

as the Chairman and members of the Board or other key officials who may not be involved 

with the day-to-day operation of the company but who are primary stockholders and/or 

whose influence on the actions or policies of the applicant is, or potentially could be, 

substantial. 

However, in view of the Department’s inquiries, Star may have misinterpreted the 

requirements. Star never intended not to disclose relevant information. Therefore, Star now 

provides the following supplemental disclosures: 

Mr. Alfred Yue –At the time of initial filing Mr. Yue held 25% of Star's stock and he was formerly 

the President of Taga Air Charter’s, Inc. 

On March 3rd, 2011, Mr. Yue notified Star that he was leaving the area and relocating due to 

taking a position with a Japanese Company. He offered to sell his 5,000 shares of stock in Star to 

Shaun R. Christian. Shaun agreed to buy the shares. On March 8, 2011, Shaun R. Christian 

purchased the shares from Mr. Yue. Shaun R. Christian held 75% of the Star’s stock and Paz L. 

Christian held the remaining 25% of the stock. On March 18, 2011, Paz L. Christian became a 

naturalized US citizen and on March 22, 2011, Shaun R. Christian sold 25% of his shares to Paz L. 

Christian. Star’s stock is now equally divided between Shaun R. Christian and Paz L. Christian; 

both of whom are US Citizens. (See stock transfer agreements attached.) 

Shaun R. Christian – Although not employed by Taga Air Charters, Inc., Shaun R. Christian 

temporarily held the position of President of Taga Air Charters, Inc. (February and March 2008) 

as well as 90,000 shares of the Taga's stock. However, the stock purchase agreements were 

contingent on representations that the transfer of ownership would allow continued operation 

of Taga’s business. On March 18, Taga suspended all flight operations and subsequently 

voluntarily surrendered its air carrier license at the recommendation of an outside consultant 
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who was brought in to assess Taga's compliance with various regulatory requirements. 

Therefore, the stock sale was annulled and all stock was returned to the previous owners of 

Taga Air Charters, Inc. 

Robert F. Christian – In his role as a consultant for CCI Corporation, represented himself as the 

managing director of Taga Air Charters, Inc. solely for the purpose of communicating with the 

FAA regarding Taga's compliance issues. The communication with the FAA resulted in Robert F. 

Christian notifying the FAA that Taga Air Charters, Inc. was stopping its flight operations on the 

18th of March 2008. Subsequent to that action, Shaun R. Christian resigned as President and 

returned the stock to Taga’s previous shareholders. On March 31, 2008, Mr. Alfred Yue in his 

capacity as Taga Air Charters, Inc.’s President surrendered Taga Air Charter, Inc.’s, Air Carrier 

certificate to Mr. Chris Collins of the FAA's Honolulu office at a meeting in Saipan. Mr. Christian 

was never a paid employee of Taga Air Charters, Inc. 

James Bell – Was formerly employed by Taga Air Charters, Inc. as a line pilot for the period from 

June 2007 to October 2007 (This information is disclosed in his resume which was previously 

attached to Star's filing). 

Manny Gabor – Manny Gabor was the Director of Maintenance for Taga Air Charters, Inc. (This 

information was also disclosed in his resume which was previously attached to Star's filing). 

2. Star’s application notes that Chief Pilot, James Edward Bell has an unresolved letter of 

investigation pending with the FAA. Please provide further information regarding the status of 

this letter. 

RESPONSE:

Mr. Bell joined the Tinian Dynasty Hotel and Casino’s (TDHC) corporate flight department 

October 2008. The FAA took the position that certain flights being conducted by the TDHC 

required certification under 14 CFR 119. Three weeks after starting employment with the TDHC 

Jim Bell was the pilot on one of those flights. The FAA’s position has been appealed to the NTSB 

and remains open. No safety issues are involved. 

OPERATIONS AND FINANCIAL POSITION

1. Exhibit 4C of Star’s application states that Star has entered into leases for four aircraft. Please 

clarify. In addition, please provide a copy of the aircraft lease agreements. 

RESPONSE: See Attachment Number 3 (Lease Agreements) 

At the time of filing, Star had entered into a lease agreement for a C402 aircraft. The lease was 

submitted to the FAA and the aircraft’s maintenance was approved by the FAA. However, the 

lessor failed to meet Star’s delivery conditions and the lease was terminated. The aircraft has 

since been sold to a third party. Star did not have any further interest in leasing the aircraft and 

notified the FAA in November, 2010. 
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2. Please provide a copy of Star’s Articles of Incorporation and by-laws which reflect its current 

ownership structure. 

RESPONSE: See Attachment Number 4 (Articles of Incorporation, By-Laws, and Annual Report) 

3. Please provide stockholder agreement that pertain to the acquisition of company stock. 

RESPONSE: See Attachment Number 5 (Stock Transfer Agreement) 

4. Please provide third-party verification of all lines-of-credit available to support Star’s proposed 

operations. This verification should include the total line-of-credit being made available, the 

amount such credit line has been drawn down to date, any conditions that must be met before 

funds will be advanced, the terms of repayment, and the expiration date. Further, if the line of 

credit is being supplied by an individual or organization (other than a recognized financial 

institution) copies of the personal or corporate financial statements of the individual or 

organization should also be provided. 

RESPONSE: Star is currently sufficiently capitalized and does not require a line of credit. (Latest 

Star financial records will be provided upon request to substantiate this statement. See 

response to #5). 

 

Since many of the flights being chartered are for one-way transfers, SMA has many open seats 

on repositioning flights that could be used for individual seat sales. For this reason SMA is 

seeking to gain the authority to offer scheduled flights (by announcing relocation departure 

times) to the general public. No material additional capital, equipment, and/or personnel are 

required to begin scheduled flights. 

5. Please provide third-party verification of all cash deposits available to support Star’s proposed 

operations. 

RESPONSE: See Attachment Number 6 (Bank Statements as of 12/31/2010)

The company is sufficiently capitalized and does not require a credit line. Bank statements 

attached. 

OWNERSHIP

1. For all persons who are not citizens of the United States as defined in 49 U.S.C. 40102(a)(15) and 

who directly or indirectly hold a debt or equity interest in the air carrier, describe the nature of 

the interest and the particular rights and liabilities of the parties. 

a. Detail any actual or potential ability on the part of the non-citizen entities to influence 

control, directly or indirectly, the affairs of the air carrier. Provide any documents describing 

the rights or obligations of such entities. 

RESPONSE:

No non citizens directly or indirectly hold a debt or equity interest in Star. 

Attachment Number 1

OST Form 6410



Attachment Number 2

Form 8400-6


Attachment Number 3

Lease Agreements





























Attachment Number 4 

Articles of Incorporation, By-Laws, and Annual Report






























INITIAL REPORT: _

CHECK ONE: (XX) Domestic Corporation

REPORT FOR THE YEAR 2011

( ) Foreign Corporation

Filing Fee $50.00 I Make check Payable to: CNMI TREASURER

File Original and One Copy

FILING: THE INITIAL REPORT MUST BE FILED WITHIN 60 DAYS OF INCORPORATION.

ANNUAL REPORT MUST BE FILED ON OR BEFORE MARCH 1ST OF EACH YEAR

FILE WITH REGISTRAR OF CORPORATIONS

Office of the Attorney General

2nd Floor, Memorial Bldg./Capitol Hill

Saipan, MP 96950

Name, Mailing Address & Telephone No. of Corporation: (Attached map showing location if address is only P.O. Box)

STAR MARIANAS AIR, INC. Tel.No. 433-9998

P.O. Box 520461 Location: San Jose Village

Tinian, MP 96952 Tinian, MP 96952

Name, Mailing Address & Telephone No. of Registered Agent: (Attached map showing location if address is only P.O. Box)

G. Anthony Long Tel.No. 235-4802

PO Box 504970

Saipan, MP 96950

LIST OF DIRECTORS:

Name Nationality Address

Shaun R. Christian USA P.O. Box 520461, Tinian MP 96952

Paz L. Christian USA P.O. Box 520461, Tinian MP 96952

Robert F. Christian USA P.O. Box 520461, Tinian MP 96952

LIST OF OFFICERS: ,

Name Position Nationality Address

Shaun R. Christian President/Secretary USA P.O. Box 520461, Tinian MP 96952

Paz L. Christian Vice-President USA P.O. Box 520461, Tinian MP 96952

DESCRIPTION OF BUSINESS ACTIVITIES· List all lines of business

To provide charter services in the Mariana Islands as well as engage in any lawful business, trade

investment, transaction, venture or enterprise for which the corporation may be formed under CNMI law & regulations.

and see ARTICLE IV Purposes and Powers of Articles of Incorporation.

STOCK ISSUED AND OUTSTANDING

Number of Shares Class of Shares Amount Paid for Shares

100000 Common $ 100000,00

NAME OF SHAREHOLDERS IMMIGRATION STATUS NATIONALITY NUMBER OF SHARES HELD

Shaun R. Christian USA 10000

Paz L. Christian USA 10000

~nr;<€l/~ )ate: 05.06.11 SHAUN R. CHRISTIAN, President

PRINT NAME & TITLE OF PERSON SIGNING

(Must be Director or Officer of the Corporation)
Attachment Number 5

Stock Transfer Agreement 







Attachment Number 6 

Financial Statements & Bank Statements 
Dec. 31, 2010 Dec. 31, 2009

Current Assets

Cash on hand and in banks 204,834 39,580 

Receivables 274,431 195,128 

Inventory 84,890 85,131 

Prepaid expenses 16,408 5,947 

Total Current Assets 325,545 580,803 

Improvements and equipment 247,753 203,548 

Accumulated depreciation and amortization (41,605) (15,372) 

Other assets 5,957 6,791 

Total Assets 793,741 519,677 

Current Liabilities

Current portion of long-term debt 51,821 62,876

Payables 123,974 84,005

Accrued expenses 89,201 78,587

Total Current Liabilities 264,997 225,468

Long-Term Debt, Exclusive of Current Portion 44,331 83,142

Total Liabilities 309,328 308,610

Stockholders' Equity

Capital Stock 20,000 20,000

Retained Earnings 464,413 191,068

Total Stockholders' Equity 211,068 484,413 

Total Liabilities And Stockholders' Equity 519,677 793,741 

 - - 

Star Marianas Air, Inc.

Balance Sheet

Assets

Liabilities And Stockholders' Equity
Year Ended Year Ended

Dec. 31, 2010 Pct Dec. 31, 2009 Pct

Revenues

Charter revenues 2,625,096 99.31 1,211,875 100.08 

Cargo revenues 10,467 0.40 0.00 18

Others 0.30 7,869 0.07 827

Commissions - - (0.15) (1,872)

Total 2,643,432 100.00 1,210,848 100.00 

Direct expenses

Maintenance 210,472 7.96 59,037 4.88 

Fuel 324,100 12.26 89,791 7.42 

Customs and immigration 0.31 8,075 0.02 207

Ground rentals 32,979 1.25 14,599 1.21 

Landing fees 75,127 2.84 24,209 2.00 

Facility charges 133,769 5.06 39,247 3.24 

Other direct 13,319 0.50 0.32 3,923

Total 797,840 231,014 30.18 19.08 

Gross Margin 1,845,591 979,834 69.82 80.92 

Operating Expenses

Salaries and wages 939,515 35.54 448,395 37.03 

Advertising and promotion 0.34 9,023 - -

Bank charges 0.03 899 0.02 300

Dues and subscriptions 0.14 3,623 0.25 3,024

Employee benefits 103,816 3.93 114,005 9.42 

Insurance 89,403 3.38 33,628 2.78 

Miscellaneous 0.23 6,051 0.31 3,712

Office supplies and expense 20,470 0.77 13,876 1.15 

Payroll taxes 43,255 1.64 14,878 1.23 

Professional fees 107,586 4.07 77,808 6.43 

Promotion and entertainment 23,479 0.89 11,586 0.96 

Taxes 0.08 2,143 0.00 6

Telecommunications 18,047 0.68 0.82 9,961

Travel and transportation 24,218 0.92 0.81 9,832

Utilities 11,534 0.44 0.43 5,176

Vehicle expense 0.37 9,657 0.27 3,262

Total 1,412,719 749,447 53.44 61.89 

EBITDA 16.38 432,872 230,387 19.03 

Depreciation, amortization & aircraft leases 133,483 5.05 15,372 1.27 

EBIT 299,389 215,015 11.33 17.76 

Interest income 0.01 155 0.00 46

Interest expense (0.19) (5,098) (0.66) (7,994)

EBT 294,446 207,068 11.14 17.10 

Income tax (21,100) (0.80) (16,000) (1.32) 

Net Income/(Loss) 273,346 191,068 10.34 15.78 

Retained Earnings

Beginning Of Period 191,068 -

End Of Period 464,413 191,068

Star Marianas Air, Inc.

Income Statement
Year Ended Year Ended

Dec. 31, 2010 Dec. 31, 2009

Cash Flo s From Operations

Star Marianas Air, Inc.

Statement Of Cash Flows

Cash Flows From Operations

Net Income 273,346 191,068

Adjustments to reconcile net income to net cash provided by operating activities:

Depreciation and amortizaton 26,233 15,372 

Changes In Current Operating Items Changes In Current Operating Items

Receivables (79,303) (195,128)

Inventory (240) (84,890)

Prepaid expenses (10,461) (5,947)

Payables 39,970 84,005

Accruals 10,614 78,587

Total Adjustments (13,187) (108,001)

Net Cash Provided By/(Used For) Operations 260,158 83,067

Cash Flows From Investing Activities

Capital expenditures (44,205) (203,548)

Deposits made (834) (5,957)

Net Cash Provided By/(Used For) Investing Activities (209,504) (45,039) 

Cash Flows From Financing Activities

Long-term borrowing - 189,000

Principal payments on loans (49,865) (42,982)

Capital invested - 20,000

Net Cash Provided By/(Used For) Financing Activities (49,865) 166,018

Net Increase/(Decrease) In Cash And Cash Equivalents 39,580 165,254 

Beginning Cash And Cash Equivalents 39,580 - 

Ending Cash And Cash Equivalents 204,834 39,580 

Cash And Equivalents

Cash on hand and in banks Cash on hand and in banks 204 834 204,834 39 580 ,

Total 39,580 204,834