Plane Law in Plain English ... 

April 22, 2013 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building - Suite 2W1 000 

Washington, DC 20591 

Attention: Hearing Docket Clerk- AGC-430 

Re: FAA v. Aviation Engineering Consultants, Inc. 

Docket# 2012CE440003 

Dear Sir/Mdm.: 

RECEIVED 

APR 2 ~ 2013 

HEARING DOCKET 

Please accept this correspondence as my client, Aviation Engineering 

Consultants Inc. ("AEC"), formal written request for a hearing in the 

above-referenced matter. 

AEL ~enies the allegations in the FAA's final notice of proposed civil 

penah. '1nd requests that a hearing in this matter be scheduled in 

Clearw,c:ier, Florida. Should that location be unavailable, we would 

request that the hearing be conducted in Tampa, Florida or in Atlanta, 

Georgia. 

AEC asserts that it did not willfully violate the provisions of 14 CFR 

21. 303(a) in that the company did not sell the parts alleged in the 

administrators final order nor intentionally place these parts in the 

stream of commerce. 

Accordingly, AEC requests that the administrators order be dismissed 

or in the alternative that AEC be allowed to present evidence in 

mitigation of the Administrator's allegations contained in their Final 

Notice of Proposed Civil Penalty dated April 08, 2013 (attached). 

Douglas J. Barnard, Esq.* 

*Also admitted to the District of Columbia 

AFFILIATES WORLDWIDE 

14695 Airport Parkway, 2nd Floor. 

Clearwater, FL 33762 

email: dougb@planelaw.com 

Office: (727) 259-0224 

Fax: (727) 259-0223 
Thank you for your urgent attention to this matter. Please direct all 

further correspondence and pleadings in this matter to the 

undersigned as counsel for Aviation Engineering Consultants Inc. 

I hereby certify that I have served a true and correct copy of the 

above upon Mark Camacho, Esquire as senior enforcement attorney 

for the FAA on Apri12_9, 2013 via overnight courier, f/5f5 frqc/(t1J#=-

[): 6 ~</- 70q O'L LU( > to: 

United States Department of Transportation, Federal Aviation 

Administration, Office of Regional Counsel, 901 Locust, room 506, 

Kansas City, MO 64106 . 

... 

s·····i···n· cerely, n,!V./ /;? _ _,/7/~~ t:. ~t/PJ. 

Douglas J. Barnard, Esquire 

Douglas J. Barnard, Esq.* 

*Also admitted to the District of Columbia 

AFFILIATES WORLDWIDE 

14695 Airport Parkway, 2nd Floor. 

Clearwater, FL 33762 

email: dougb@planelaw.com 

Office: (727) 259-0224 

Fax: (727) 259-0223 
US Dep<Jrr~~e~,! 

c.: :r(!'l--S~.:r::J~O~r:)': 

Federal Aviation 

Administration 

In Reply Refer To: ACE-7 

20 I 2CF440003 

Otlice of Reg1onal Counsel 

901 Locust. Room 506 

Kansas Crty MO &4106 

Telephone (81 6) 329-3765 

Facsimile: (816) 329-3771 

FEDEX 0\'ER:\'IGHT DELIVERY -liS Airbill No. 8698 1211 3850 

REGliLAR and CERTIFiED l\IAIL- RETURN RECEIPT REQUESTED 

Cert No. 7011 1150 0000 0337 0809 

AprilS, 2013 

Mr. Kamran Rouhani 

Aviation Engineering Consultants, Inc. 

2750 Sunset Point Road 

Clearwater, FL 33759 

FINAL NOTICE OF PROPOSED CIVIL PENALTY 

On !l·larch 28, 2012, /wiation Engineering Consultants, lnc. (AECI) was advised through a 

Notice ofProposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount 

of$44.000. \Ve have considered the infom1ation submitted in response to this Notice. 

A repon of an investigation, and the infom1ation submined at the informal conference on 

December 6, 2012, indicates that: 

1. On or about December 23, 201 0, AECI shipped eight elevator center hinge fittings, pan 

number 80-393103-405, and eight elevator outboard hinge tittings. part number 80-

393103-407,10 Avantair, Inc. 

2. On or about October 14, 2011, the Federal Aviation Administration (FAA), while 

conducting an inspection of the Avantair Repair Station, discovered that four of the pans 

described in paragraph I above (two elevator center hinge linings, pan number 80-

3931 03A05AEC, and two elevator outboard hinge finings, pan number 80-393103-

407 AEC) were installed on a Piaggio P-180 aircraft, Civil Aircraft N 134SL. 

3. The parts described in paragraph 2 above were marked "FAA-PMA." However, the FAA 

had not granted Parts Manufacturer Approval (PMA) to Aviation Engineering 

Consultants. Inc. to produce those parts. 
-+ B' reJson uf th~ foreL:oin~ facts •md circumstances. AYiatinn Eneineerlni:!: Cnnsu!Lant5. . - ~ .__ ' .... ._ 

Inc. ,·iolated section 21.303(a) of the Federal ,-\viation Regulations. which provides that. 

except as prO\idcd in paragmph (b) of this section. no person may produce a modificatiun 

or replacement pan for sale for installation on a type certificated product unless it is 

produced pursuant 10 a Parts i\1anufacturer Approval issued under this subpan [Title 14 

0f the Code of Federal Regulations (CFR). Section 21.303(a)]. 

t'ndcr Title 49 liSC 4630 I. AEC1 is subject to a civil penalty no I to exceed $11.000 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 S44,000. 

Unless AECI mails or personally delivers, in \\Titing, its request for a hearing in this rnaner. 

within 15 days after receipt of this Final Notice. we will issue an Order Assessing Civil Penalty 

and AEC1 will have no further right to a hearing. If AEC1 does not submit a \\Titten request for a 

hearing, it must pay the proposed civil penalty. 

AECI' s request for a hearing must be sent to the Hearing Docket Clerk at one of the following 

addresses: 

For service bv l!.S. Postal Sen·ice: 

Federal Aviation Administration 

Wilbur \\'right Building 

AGC-430/Room 924A 

Attention: Hearing Docket Clerk 

800 Independence Avenue, SW. 

Washington, DC 20591 

For service by personal deliven· or expedited courier such as Federal Express 

Federal Aviation Administration 

Wilbur \Vright Building 

Suite 2W 1 000 

600 Independence Avenue SW 

Washington, DC 20591 

A copy also must be sent to the undersigned FAA attomey. AECl's request must be dated and 

signed, in accordance with Section 13.16 of the Federal Aviation Regulations. sent with the 

Notice of Proposed Civil Penalty (14 CF.R. 13.16} 

AECI must pay the proposed penalty by submining a certi!kd check or money order payable 10 

the Federal Aviation Administration, to the undersigned. In the alternative, AECI may pay its 

civil penalty with a credit card over the Internet. To pay electronically. visit the website at 

https:l/www.pay.gov. Under the Search Public Forms option, type in "FCE-FINE1." Click on 

''FA:\ Civil Penalty Payments- Central Region." AEC1 must then complete the requested 
infnnnation and click "Continue." AlCI "·ill then be direued to enter its credit card or bank 

account debit inlom1ation. Tc' use the bank accoum debit AECl "ill need its bank routing 

number. "ccount number. and check number. TilE FAA WILL '\OT ACCEPT INTERNET 

PA YME'\TS FOR A'\ AMOU'\T LESS THAl\ THE Ai\10l'1\'T SHOWl\ IN THE FINAL 

1\'0TICE. 

A Lester Haizlip 

Regional Counsel 

By: 
:o 12CE4-l0003 ,\,iation Engineering Consultants. Inc. 

CERTIFICATE OF SERVICE 

I certif: thnt l have this date served this Final ;\lot ice of Proposed Ci,·il Penalty to the he lownamed addressees. via the methods listed: 

Mr. Kamran Rouhani 

Aviation Engineering Consultants. Inc. 

2750 Sunset Point Road 

Clearwater. FL 33759 

(Original via FedEx Overnight Delin~·; duplicate originals via next business 

da~· regular and certified mail) 

Douglas J. Barnard. Esq. 

I 4695 Airpon Pkwy Ste 6 

Clearwater. FL 33762 

(Copy via next business day regular mail) 

Dated this s"' day of April 20 I 3.