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UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Star Marianas Air, Inc.,

Complainant,

v. Docket No. _________

A.B. Won Pat International Airport

Authority, Guam,

Respondent.

/

TITLE 14 CFR PART 16 COMPLAINT

Star Marianas Air, Inc. (“SMA”), by and through undersigned counsel, hereby files a 

Complaint pursuant to Title 14, Code of Federal Regulations, Part 16, against the A.B. Won Pat 

International Airport Authority, Guam (the “Authority”) and in support thereof, states as follows: 

THE PARTIES

1. Complainant SMA is a corporation incorporated in the Commonwealth of the 

Northern Mariana Islands (“CNMI”), which operates as a Federal Aviation Administration 

(“FAA”) certificated air carrier under FAA certificate no.: 1SMA230M. A copy of the certificate 

is attached hereto as Exhibit “A”. SMA is located at Hanger 1, Tinian International Airport, 

Tinian, MP 96952 and operates air charters between Tinian, Saipan, Rota, and Guam.

2. Respondent Authority is a public corporation incorporated in Guam and is the 

sponsor of an FAA assisted airport, namely the Guam International Airport (the “Airport”). The 

Authority is located at P.O. Box 8770 Tamuning, Guam, GU 96931 and may be served through 

its counsel, Janalynn Cruz Damian, Esq., Calvo Fisher & Jacob, 259 Martyr Street, Suite 100, 

Hagatna, Guam 96910; e-mail: jdamian@calvofisher.com.
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JURISDICTION AND STANDING

3. Jurisdiction to hear this matter is conferred upon the FAA by Congress through 

the Airport and Airway Improvement Act of 1982 (“AAIA”), 49 U.S.C. § 47101 et seq. The 

AAIA authorizes the FAA to grant federal funds to public airports for construction and other 

improvement projects via the AAIA’s Airport Improvement Program (“AIP”). Recipients of such 

AIP grants must provide written assurances that they will comply with numerous statutory 

requirements (“Grant Assurances”). 49 U.S.C. § 47107(a). The FAA has jurisdiction to hear this 

Complaint and to order the Respondent to comply with its Grant Assurances pursuant to 14 

C.F.R. Part 16. 

NATURE OF THE CASE AND BACKGROUND

4. In September 1975, Guam Public Law 13-57 created the Authority. The Authority 

was strictly the Guam International Air Terminal facility operator while the U.S. Navy operated 

the runways and conducted airway operations for all aircraft operators. In 1974, the Authority 

was granted joint use of the airfield under a Joint Use Agreement with the U.S. Navy. In April 

1995, the Base Realignment and Closure Act of 1993 slated the NAS Brewer Field for closure. 

Upon base closure, all runways became the operating responsibility of the Authority. 

Furthermore, the Authority became certified as the licensed civil aviation airport operator for 

Guam. One of the funding programs for the airport is the AIP. The source of the AIP funds is the 

Airport and Airway Trust Fund (“AATF”). Congress created the AATF in 1970 to provide 

funding for aviation capital investment programs. The AIP funds are discretionary and 

distributed each year by the FAA and are conditioned upon an airport sponsor’s adherence to the 

Grant Assurances. 49 U.S.C.A. § 48101, et seq.
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5. As the sponsor for federal grants received by the Airport as part of the AIP, the 

Authority is obligated to comply with federal law and related FAA sponsor assurances. 

6. After accepting an AIP grant, the Authority’s assurances are a binding obligation 

between it and the federal government. 

7. The Authority has breached the Grant Assurances by (a) providing preferential

and exclusive airport property rights to a direct competitor of SMA, and (b) making changes to a 

FAA-approved airport layout plan.

SPECIFIC ALLEGATIONS

8. The Airport has two terminals, the main terminal, and the commuter terminal (the 

“Terminal”).

9. Cape Air has access to the main terminal at the Airport and is the only commuter 

airline providing commuter flights between the CNMI and Guam, namely routes between 

Saipan, Rota, and Guam.

10. All seats on Cape Air flights in this region are effectively United Airlines seats, as 

Cape Air flight reservations for this region can only be made through United Airlines.

11. The Terminal at the Airport is being used by United Airlines’ human resources 

department, which does not require airside access.

12. While the FAA-approved Airport Layout Plan (“ALP”) designates the Terminal 

as a commuter terminal, the Authority has effectively designated it as office space. 

13. Since 2012, SMA has attempted to gain access to the Airport so it could provide 

cargo, on-demand passenger, and commuter flights between Guam and the CNMI.
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14. SMA is presently limited to cargo and on-demand passenger flights and must 

arrange for third party handlers at an extra cost because the Authority has denied it self-access to 

the Airport.

15. Without the use of the Terminal, SMA cannot obtain Part 135 commuter 

operative status because it will not have station facilities as required by PTRS Code 1635.

16. On June 25, 2014, SMA sent a letter to the Authority requesting use of the 

Terminal, which set forth, among other things, that the use of the Terminal by United Airlines’ 

human resources department violates Grant Assurances 22, 23, and 24, and a request to meet

with the Authority to work towards resolving said violation. A copy of the June 25, 2014 letter is 

attached hereto as Exhibit “B”.

17. On July 22, 2014, SMA sent a second letter to the Authority requesting use of the 

Terminal, which again set forth the violations and a request to meet to resolve same. A copy of 

the July 22, 2014 letter is attached hereto as Exhibit “C”.

18. On July 25, 2014, the Authority replied to SMA’s correspondence to organize a 

meeting. A copy of the July 25, 2014 letter is attached hereto as Exhibit “D”.

19. On July 31, 2014, SMA replied in order to organize a meeting and to inform the 

Authority that the use of the Terminal by United Airlines’ human resources department also 

violates Grant Assurance 29, as the area designated by the Authority for the United Airlines’ 

human resources department is different than the designation set forth in the ALP, and the 

Authority implemented this change without FAA consent. A copy of the July 31, 2014 letter is 

attached hereto as Exhibit “E”.
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20. On August 5, 2014, SMA sent a letter to the FAA Airports Division Office 

requesting that the FAA investigate the Authority due to its breaches of the Grant Assurances. A 

copy of the August 5, 2014 letter is attached hereto as Exhibit “F”.

21. On August 19, 2014, SMA and the Authority met to discuss a resolution so that 

SMA may immediately commence commuter operations from the Airport.

22. On August 20, 2014, SMA sent the Authority a Notice of Intent to Conduct 

Scheduled Commuter and On-Demand Operation at the A.B. Won Pat International Airport 

Commuter Terminal, Guam with a detailed proposed flight schedule and requirements for 

operating facilities. A copy of the August 20, 2014 notice is attached hereto as Exhibit “G”.

23. On August 28, 2014, the Authority sent SMA a letter stating that SMA can use 

the Yellow Cargo Building (the “YCB”) as an interim location, but made no mention of the 

Terminal. A copy of the August 28, 2014 letter is attached hereto as Exhibit “H”.

24. On September 2, 2014, SMA’s reply letter stated that: 1) using the YCB as an 

interim location still meant space for SMA’s operational facilities is an issue as there was no 

specified resolution timeframe, 2) using the YCB would put SMA at a disadvantage with its 

competitor Cape Air, and 3) the Authority continues to erroneously allow United Airlines’ nonaeronautical use of the Terminal. A copy of the September 2, 2014 letter is attached hereto as 

Exhibit “I”.

25. On September 16, 2014, SMA sent a letter to the FAA Western-Pacific Region 

Airports Division requesting that the FAA investigate the Authority due to its breaches of the 

Grant Assurances. A copy of the September 16, 2014 letter is attached hereto as Exhibit “J”.
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26. On September 22, 2014, the Authority sent a letter to SMA stating that the 

Terminal was closed for security reasons and no aircraft could be parked on the adjoining apron. 

A copy of the September 22, 2014 letter is attached hereto as Exhibit “K”.

27. Despite this statement, SMA aircraft have been directed to park on the adjoining 

apron of the Terminal and other third-party aircraft regularly operate from said apron.

28. The YCB, a cargo building, does not comply with the requirements for a 

passenger terminal, including the absence of certain facilities, including but not limited to, access 

for handicapped persons. See 49 C.F.R Part 27.

29. To date, the Authority continues to refuse SMA’s requests to use the Terminal for 

SMA’s aeronautical operations.

30. The Authority also continues to permit United Airlines the exclusive use of 

Airport property for non-aeronautical activity in the Terminal. 

31. SMA is forced to acquire the services of third party ground handlers for all its 

operations at significant additional cost because the Authority continues to deny SMA selfaccess at the Airport, while Cape Air has been given self-access at the main terminal to conduct 

its operations, including the ground handling of its flights with its own staff.

32. The Authority has thus taken numerous steps, whether by action or inaction, 

resulting in unfair and discriminatory economic treatment against SMA.

SMA HAS BEEN DIRECTLY AND SUBSTANTIALLY HARMED

33. SMA is entitled to institute this Part 16 Complaint because it was, is and 

continues to be directly and substantially affected by the Authority’s noncompliance with legal 

duties under the AIP and applicable federal law.
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COUNT I

(Violation of Grant Assurance No. 22: Economic Nondiscrimination)

34. SMA re-alleges paragraphs 1 through 33 as if fully set forth herein. 

35. Grant Assurance 22 provides that an airport sponsor must provide equal access to 

all companies providing aircraft services.

36. The Authority is obligated, as a sponsor receiving AIP funding, to make the 

Airport available for public use on reasonable terms and without unjust discrimination to all 

types, kinds and classes of aeronautical activities, including commercial aeronautical activities 

offering services to the public at the airport. 

37. The Authority, by allowing the Terminal to be used for United Airlines’ human 

resources department instead of SMA for an aeronautical use is impeding upon SMA’s right to 

nondiscriminatory economic competition. 

38. The Authority, by allowing Cape Air access to the main terminal as the only 

commuter airline between the CNMI and Guam is impeding upon SMA’s right to 

nondiscriminatory economic competition.

39. The Authority, by requiring SMA to use the YCB as an interim terminal is 

impeding upon SMA’s right to nondiscriminatory economic competition because the YCB does 

not comply with the requirements for a passenger terminal, including the absence of certain 

facilities, including but not limited to, access for handicapped persons. See 49 C.F.R Part 27.

40. As a result of the Authority’s economic discrimination, SMA’s ability to operate 

as a competitive and profitable business is suppressed to the benefit of Cape Air and United 

Airlines.
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41. The Authority’s failure to allow SMA use of a passenger terminal while allowing 

Cape Air and United Airlines access to same is a violation of Grant Assurance 22. 

COUNT II

(Violation of Grant Assurance No. 23: Exclusive Rights)

42. SMA re-alleges paragraphs 1 through 33 as if fully set forth herein.

43. Grant Assurance 23 provides that an airport sponsor cannot grant any one

company the exclusive right to use the airport and its property.

44. The Authority has provided assurances that it would not permit exclusive rights 

for the use of the Airport by any person providing, or intending to provide, aeronautical services 

to the public.

45. The Authority may not, either directly or indirectly, grant or permit any person, 

firm, or corporation, the exclusive right at the Airport to conduct any aeronautical activities. 

46. The Authority has denied SMA’s request to use the Terminal for its commuter air 

carrier operations.

47. The Authority has granted special rights or privileges to Cape Air and United 

Airlines, and has denied this same right to SMA.

48. The Authority has not demonstrated that the limitation directed at SMA is

necessary for the safe operation of the Airport or necessary to serve the civil aviation needs of 

the public. 

49. The Authority’s refusal to permit SMA to use the Terminal at the Airport is a 

violation of Grant Assurance No. 23.

COUNT III

(Violation of Grant Assurance No. 29: Airport Layout Plan)

50. SMA re-alleges paragraphs 1 through 33 as if fully set forth herein.
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51. Grant Assurance 29 provides that an airport sponsor may not make changes to 

airport property without the approval of the FAA.

52. The Authority has provided assurances that it would not make or permit any

changes or alterations in the Airport or any of its facilities that are not in conformity with its 

FAA-approved ALP.

53. FAA Order 5190.6B states that an FAA-approved ALP is a prerequisite to the 

grant of AIP funds for an airport as it reflects the agreement between the FAA and the sponsor 

regarding the proposed allocation of airport areas to specific operational and support functions. If 

the sponsor makes a change in the airport or its facilities that is not reflected in the ALP, and the 

FAA determines the change will adversely affect the safety, utility, or efficiency of any federally 

owned or leased or funded property on or off the airport, the FAA may require the airport to 

eliminate the adverse effect or bear the cost of rectifying the situation.

54. The Authority may not erect any structure or make any alteration in conflict with 

the plan as approved by the FAA as such change may constitute a violation of the federal 

obligation under Grant Assurance 29 according to FAA Order 5190.6B. 

55. The Authority has denied SMA’s request to use the Terminal for its air carrier 

operations.

56. The Terminal is designated for aeronautical use only according to the ALP, yet

the Authority has allowed United Airlines’ human resources department, a non-aeronautical 

operation with no need for airside access, exclusive use of the Terminal. 

57. The Authority’s alteration in the ALP by changing the Terminal to a human 

resources office is a violation of Grant Assurance No. 29.
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LIST OF EXHIBITS

58. Pursuant to 14 C.F.R. Section 16.23(b), the documentary support for the 

allegations contained in this Complaint that is presently available to Complainants, in the 

exercise of reasonable diligence, are served concurrently with this Complaint, are incorporated 

herein by reference as though fully set forth, and are identified as follows:

Exhibit A: SMA FAA Certificate. 

Exhibit B: Correspondence to the Authority, dated June 25, 2014.

Exhibit C: Correspondence to the Authority, dated July 22, 2014.

Exhibit D: Correspondence from Authority to SMA, dated July 25, 2014.

Exhibit E: Correspondence to Counsel for the Authority, dated July 31, 2014.

Exhibit F: Correspondence to FAA Airport Divisions Office, dated August 5, 2014.

Exhibit G: Notice of Intent to Conduct Scheduled Commuter and On-Demand 

Operation at the A.B. Won Pat International Airport Commuter Terminal, Guam, 

dated August 20, 2014.

Exhibit H: Correspondence from the Authority, dated August 28, 2014.

Exhibit I: Correspondence to the Authority, dated September 2, 2014.

Exhibit J: Correspondence to FAA Western-Pacific Region Airports Division, dated 

September 16, 2014.

Exhibit K: Correspondence from the Authority, dated September 22, 2014.

CORRECTIVE ACTION

59. SMA respectfully requests that the FAA issue an order: (1) denying the Authority 

future federal AIP grants and suspending current grant fund payments for 6 months or until the 

violations alleged herein are rectified, whichever period is longer; and (2) requiring the 

Authority, within twenty (20) days of an adverse Director’s Determination, to submit a 

corrective action plan demonstrating how it intends to eliminate the violations.

SECTION 16.21 CERTIFICATION

The undersigned counsel certifies that substantial and reasonable good faith efforts to 

resolve this disputed matter informally prior to filing this Complaint have been made on behalf 

of SMA and there is no reasonable prospect for timely resolution. The extensive efforts taken by 

SMA to obtain resolution are detailed above and, among other efforts, include: (1) sending 
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numerous letters to the Authority in efforts to resolve the issues; (2) holding meetings with the 

Authority in efforts to resolve the issues and (3) informally requesting FAA intervention.

CERTIFICATE OF SERVICE

I hereby certify that I have this 9th day of October 2014 served the foregoing Part 16 

complaint on the following persons at the following address by electronic mail:

Janalynn Cruz Damian, Esq. 

Calvo Fisher & Jacob 

259 Martyr Street, Suite 100 

Hagatna, Guam 96910

jdamian@calvofisher.com (by consent)

&

FAA Docket Clerk

9-AWA-AGC-Part-16@faa.gov

RICHARDS & ASSOCIATES

Attorneys for Star Marianas Air, Inc. 

232 Andalusia Avenue, Suite 202

Coral Gables, Florida 33134

Telephone: (305) 448-2228

Facsimile: (305) 448-2229

E-mail: rrichards@richpa.net

E-mail: jgoldstein@richpa.net

s/Richard L. Richards 

RICHARD L. RICHARDS

Florida Bar No.: 9415

JASON GOLDSTEIN

Florida Bar No.: 91113
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Exhibit “A”

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Exhibit “B”
LAW OFFICES

RICHARDS & ASSOCIATES

Richard L. Richards * 232 Andalusia Avenue, Suite 202 

Email: rrichards@richpa.net Coral Gables, Florida 33134 

Jason Goldstein Telephone: (305) 448-2228 

Email: jgoldstein@richpa.net Facsimile: (305) 448-2229 

*Board Certified in Aviation Law www.richpa.net 

June 25, 2014 

Via Email & 

Facsimile No.: (671) 646-8823 

A.B. Won Pat International Airport Authority, Guam 

c/o Mr. Charles H. Ada II, Executive Manager 

P.O. Box 8770 

Tamuning, GU 96931 

 Re: Star Marianas Air, Inc. 

 Issues Pertaining to the Non-Compliance with 

 Federal Law regarding the A.B. Won Pat 

 International Airport Authority, Guam 

Dear Mr. Ada: 

This letter revises and replaces the letter sent earlier today. Star Marianas Air, Inc. 

(“SMA”) has retained the law firm of Richards and Associates regarding its rights under 

applicable federal law.1 All communications regarding this matter should from hereon be 

delivered upon the undersigned and Timothy H. Bellas, Esq. 

SMA is the holder of Air Carrier Certificate Number 1SMA230M as issued by the 

Federal Aviation Administration (“FAA”). A copy of the Air Carrier Certificate is attached as 

Exhibit “A”. The Air Carrier Certificate allows SMA to conduct operations including commuter 

operations in common carriage pursuant to Title 14 Code of Federal Regulations (CFR) Section 

119.21(a)(4) and on demand operations in common carriage pursuant to Title 14 Code of Federal 

Regulations (CFR) Section 119.21(a)(5). 

As you know, the A.B. Won Pat International Airport Authority, Guam (the “Authority”) 

is the sponsor of the international airport (“Guam International Airport”). SMA desires to 

immediately commence commuter and on demand operations at Guam International Airport’s 

commuter terminal. However, the commuter terminal is currently being used by United Airlines 

and, rather than being used for its intended purpose as a commuter terminal, it is being used for 

United Airlines’ human resources department. This is obviously problematic in that a human 

resource department does not require airside access and this use is preventing aeronautical 

activities at the Guam International Airport. 

 

1

 Richards and Associates’ representation of SMA is limited to rights afforded under applicable federal law that are 

enforceable by the Federal Aviation Administration. All rights of SMA as they may pertain to the laws of the Guam 

are exclusively represented by Timothy H. Bellas, Esq., who presently serves as SMA’s local counsel. 
June 25, 2014 

Page 2 

 

Moreover, as you know, the FAA provides monetary grants to “airport sponsors,” or 

public agencies that own and operate airports, through the FAA's Airport Improvement Program, 

authorized under the Airport and Airway Improvement Act of 1982 (“AAIA”), 49 U.S.C. § 

47101 et seq. Congress has required that grant applications contain certain written assurances 

that an airport sponsor seeking federal funds will abide by a variety of requirements. 49 U.S.C. § 

47107(a). Under the AAIA, the Secretary of Transportation is responsible for ensuring 

compliance with these assurances, 49 U.S.C. § 47107(g), and is authorized to approve grant 

applications only if the airport sponsor's assurances are “satisfactory to the Secretary.” 49 U.S.C. 

§ 47107(a). Accordingly, the Secretary of Transportation has promulgated and revised a set of 

standardized grant assurances (“Grant Assurances”), including the three at issue in this case. 

The three Grant Assurances of concern are: 

Grant Assurance 22, entitled “Economic Nondiscrimination”. This 

grant assurance requires the airport sponsor to make its airport 

available for public use “without unjust discrimination to all types, 

kinds and classes of aeronautical activities.” 64 Fed.Reg. 45,008, 

45,011 (Aug. 18, 1999); 62 Fed.Reg. 29,761, 29,766 (June 2, 

1997); 

Grant Assurance 23, entitled “Exclusive Rights,” requires the 

airport sponsor to assure that “[i]t will permit no exclusive right for 

the use of the airport by any person providing, or intending to 

provide, aeronautical services to the public.” 62 Fed.Reg. at 

29,766. Further, the airport sponsor must agree that “it will not, 

either directly or indirectly, grant or permit any person, firm, or 

corporation, the exclusive right at the airport to conduct any 

aeronautical activities.” Id.; and 

Grant Assurance 24, entitled “Fee and Rental Structure,” requires 

an airport sponsor to assure that it “will maintain a fee and rental 

structure for the facilities and services at the airport which will 

make the airport as self-sustaining as possible under the 

circumstances existing at the particular airport, taking into account 

such factors as the volume of traffic and economy of collection.” 

62 Fed.Reg. at 29,767. 

The Authority has violated each of these assurances by in effect preventing SMA, a 

commuter airline, from having airside access through the Guam International Airport’s 

commuter terminal. 

The FAA enforces compliance with these and other Grant Assurances by applying 

procedures delineated in the Rules of Practice for Federally–Assisted Airport Enforcement 

Proceedings. 14 C.F.R. § 16.1(a)(1), (5). 14 C.F.R. Part 16 permits a person “directly and 
June 25, 2014 

Page 3 

 

substantially affected” by an airport sponsor's alleged noncompliance with a Grant Assurance to 

file a formal complaint with the FAA. 14 C.F.R. § 16.23(a). 

However, SMA desires to resolve this matter prior to a complaint being filed. Therefore, 

SMA requests that the Authority grant SMA access to Guam International Airport’s commuter 

terminal. Moreover, SMA requests a meeting with the Authority in order to have substantial and 

reasonable good faith efforts to resolve the foregoing disputed matters informally pursuant to 14 

C.F.R. Section 16.21. SMA reserves all rights, whether in law or equity. 

We look forward to the Authority’s swift and favorable response. 

 

Respectfully submitted, 

 Richard L. Richards 

 

cc: 

Mr. Robert Christian, Star Marianas Air, Inc. 

Mr. Shaun Christian, Star Marianas Air, Inc. 

Jason Goldstein, Esq. 

Timothy H. Bellas, Esq. 

Ms. K.C. Yanamura – Mamager, Honolulu Flight Standards District Office 

Mr. Gordon Wong - FAA Honolulu Airports District Office 

Mr. Samuel Iskander, Airports Division, FAA Western-Pacific Region 
June 25, 2014 

Page 4 

 

Exhibit “A” 
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Exhibit “C”




15

Exhibit “D”


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Exhibit “E”










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Exhibit “F”







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Exhibit “G”
P.O. Box 520461, San Jose Village, Tinian, MP 96952

Tel.: 670-433-9989 Fax.: 670-433-9990 Web site: www.starmarianasair.com

Marianas Air 

August 20, 2014

A.B. WON PAT International Airport Authority, Guam

c/o Mr. Charles H. Ada II, Executive Manager

P.O. Box 8770, Tamuning

Guam, GU 96931

SENT VIA EMAIL & Facsimile No.: (671) 646-8823

Notice of Intent to Conduct Scheduled Commuter and On-Demand Operation at the A.B. Won Pat 

International Airport Commuter Terminal, Guam

Dear Mr. Ada:

Thank you for taking time to meet with SMA’s representatives Tuesday. As discussed, SMA intends to 

conduct scheduled commuter and on-demand flight operations to and from A.B. Won Pat International 

Airport’s Commuter Terminal utilizing PA31-350 Super Chieftains; gross take-off and landing weight 

7,300 lbs, 8 or 9 passenger seat configurations. 

The initial schedule for flight operations is listed below and SMA would like to commence operations by 

the 15th of September at the latest. SMA expects to expand its operations to hourly arrivals and 

departures within 6 months after commencing operations. Accordingly, SMA will need adequate space 

at the commuter terminal to conduct its operations. Additionally, any other space that will be needed 

for local requirements, such as customs and agriculture inspection, will also need to be identified so that 

it can be incorporated into the Station Operations Manual that SMA is required by the FAA to maintain 

under its authority to conduct operations as an Air Carrier.

PROPOSED SCHEDULE FLIGHT - EFFECTIVE SEPTEMBER 15, 2014

ROTA-GUAM-ROTA SCHEDULE FLIGHT

ROUTES DEPARTURE ARRIVAL FREQUENCY

ROP-GUM 8:00AM 8:30AM Daily

GUM-ROP 9:00AM 9:30AM Daily

ROP-GUM 11:0AM 11:30AM Mon., Tue., Wed., Thur., Fri.

GUM-ROP 12:00NN 12:30NN Mon., Tue., Wed., Thur., Fri.

ROP-GUM 4:00PM 4:30PM Daily

GUM-ROP 5:00PM 5:30PM Daily

SAIPAN-GUAM-SAIPAN SCHEDULE FLIGHT

ROUTES DEPARTURE ARRIVAL FREQUENCY

SPN-GUM 8:00AM 9:00AM Daily

GUM-SPN 9:30AM 10:30AM Daily

SPN-GUM 4:00PM 5:00PM Daily

GUM-SPN 5:30PM 6:30PM Daily

TINIAN-GUAM-TINIAN SCHEDULE FLIGHT

ROUTES DEPARTURE ARRIVAL FREQUENCY

TIQ-GUM 8:00AM 9:00AM Daily

GUM-TIQ 9:30AM 10:30AM Daily

TIQ-GUM 4:00PM 5:00PM Daily

GUM-TIQ 5:30PM 6:30PM Daily
P.O. Box 520461, San Jose Village, Tinian, MP 96952

Tel.: 670-433-9989 Fax.: 670-433-9990 Web site: www.starmarianasair.com

Marianas Air 

Per the FAA’s requirement, the facilities must be adequate to provide safe operating conditions for both 

aircraft and personnel, and SMA must be able to establish procedures for assisting handicapped 

passengers.

SMA will need access to the following at the terminal in order to meet its requirements:

1. Check-in counters with weighing scales, electrical outlets to power computers and printers, and 

telephone/internet connections.

2. Ramp access for loading baggage and cargo as well as passenger boarding and deplaning.

3. An area for delivering arriving baggage

4. Adequate parking for passengers and staff at the commuter terminal

SMA will also need preferential use space (approximately 400 sq. feet) to conduct flight dependent 

operations including load control, weather information, flight planning/filing, and other flight dispatch 

functions.

Please contact me if further information would be helpful. Also please let me know when and where we 

can next meet.

Best regards,

Robert F. Christian

Chairman Board of Directors

Director of Flight Operations

cc: Mr. Shaun Christian, Star Marianas Air, Inc.

Richard L. Richards, Esq.

Jason Goldstein, Esq.

Timothy H. Bellas, Esq.

Janalynn Cruz Damian, Esq.

Ms. K.C. Yanamura – Manager, Honolulu Flight Standards District Office

Mr. Ron V. Simpson – Manager, FAA Airports Division

Mr. Frank Atalig
19

Exhibit “H”

20

Exhibit “I”
sr 1e 

Marianas Air 

September 2, 2014 

A.B. WON PAT International Airport Authority, Guam 

c/o Mr. Charles H. Ada II, Executive Manager 

P.O. Box 8770, Tamuning 

Guam, GU 96931 

Dear Mr. Ada, 

P.O. Box 520461, San Jose Village, Tinian, MP 96952 

First, I want to thank you for working on the issues we have been raising for the past 2 years and most 

recently in our meeting August 19, regarding access to Guam's airport. SMA supports any initiative 

presented by GIAA that will allow self-access to conduct its commuter and on-demand air carrier 

activities at the A.B. Won Pat International Airport without the requirement to use third parties. 

Your letter however, confirms that space for our operation remains an issue that continues to require 

unspecified time to resolve and ambiguous security concerns. Additionally, there is no mention of 

GIAA's intent to allow the use of the commuter terminal for SMA's operations and instead GIAA 

mentions the interim use of a portion of a cargo building as a solution. 

The use of the cargo building for commuter passenger operations conducted by SMA in its efforts to 

bring competitive service into the Saipan Guam and Rota Guam markets, which are currently being 

served exclusively by UA/Cape Air, places SMA at a distinct and obvious disadvantage. SMA's customers 

are relegated to using a facility designed for cargo while United's Express (Cape Air) has the use of a 

modern passenger terminal. At the same time, GIAA has leased the commuter passenger terminal 

(designated on the ALP) to UA's human resources (a non-aeronautical activity) and continues to deny 

SMA the use of the commuter passenger terminal for its aeronautical use. 

SMA recognizes that UA and GIAA have some form of residual-cost financing in place for financing the 

A.B. Won Pat International Airport but do not believe that the financing issues outweigh the 

responsibilities to comply with the sponsor's assurances. 

Therefore, whereas SMA is again thankful for the efforts being made by GIAA to allow SMA to obtain at 

least some form of self-access to the A.B. Won Pat International Airport, SMA will continue its efforts to 

seek an objective determination from the FAA regarding its use of the A.B. Won Pat International 

Airport, and GIAA's compliance with its responsibilities as the airport's sponsor. 

Please contact me directly when progress is made regarding the interim use of the cargo building so that 

we can plan promotion of our service in the communities we serve. 

Sincerely, 

Robert F. Christian 

Chairman- BOD 

Director of Flight Operations 

Tel.: 670-433-9989 Fax.: 670-433-9990 Web site: www.starmarianasair.com 
sr ;e 

Marianas Air P.O. Box 520461, San Jose Village, Tinian, MP 96952 

cc: Mr. Shaun Christian, Star Marianas Air, Inc. 

Richard L. Richards, Esq. 

Jason Goldstein, Esq. 

Timothy H. Bellas, Esq. 

Janalynn Cruz Damian, Esq. 

Ms. K.C. Yanamura- Manager, Honolulu Flight Standards District Office 

Mr. Ron V. Simpson- Manager, FAA Airports Division 

Mr. Frank Atalig 

Tel.: 670-433-9989 Fax.: 670-433-9990 Web site: www.starmarianasair.com 
21

Exhibit “J”































22

Exhibit “K”