01/06/2015 12:55 FAX 3107256816 AWP-7 

U S. Department 

o' Transportation 

Western-P~cific Region 

Federal Aviation 

Administration 

J:l!luary 6, 2015 

Office of the Regional Counsel 

i;ERTIFIED MAlL- RETURN RECEIPT REQUESTED 

F<oderal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building"- Suite 2Wl000 

Re: In the Matter of Strujet, Inc.; Case No. 2014WP230019 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

(310) 725-7110 

(310) 725-6816 facsimile 

141 002 

Eo.closcd is a copy of a request for hearing dated December 21,2014, and the original and one 

wpy of the Complaint in the above-referenced proceeding. 

I ·equest that the hearing in this matter be held in the Los Angeles, California area, a.r<d expect 

tbat the hearing will last one (1) day. 

P<ease address all communications for the Regional Counsel of the Western-Pacific Region, to 

the undersigned, at: Office of the Regional Counsel, A WP-7, Federal Aviation Administration, 

Western-Pacific Region, P. 0. Box 92007, Los Angeles, CA 90009-2007, Telephone: (310) 

T'S-711 0, FAX: (31 0) 725-6816. 

Smcerely, 

Naomi Tsuda 

Regional Counsel 

Enclosures: Request for Bearing; Complaint; Certificate of Service 

NOTE TO RESPONDENT: SECTION 13.209 OF THE CP RULES OF PRACTICE 

Ri)QUlRE THAT A WRTTTEN ANSWER TO THE COMPLAINT BE FILED NOT LATER 

F:!AN 30 DAYS AFTER SERVICE OF THE COMPLAINT, AS AN ALTERNATIVE TO 

FILING AN ANSWER, A MOTION MAY BE FILED PlJRSUANT TO SECTION 13.208(D) 

OR SECTION l3.218(F)(l-4) OF THE RULES OF PRACTICE. 

cc A WP240, FSDO 
01/06/2015 12:55 FAX 3107256816 A\VP-7 liiJ 003 

. .. ~ . 

Decem bet 21, 2014 

REF: Case No. 2014WP230019, Starjet, Inc. 

F,U\ 

N:lOtni. Tsuda 

R<.•gional Counsel, Wesrem-Pacific Region 

---·--·---

Dear Ms. TBuda: 

We are only now .in receipt of yocu: letter dated December 10, 2014- we ilid not receive the earlier 

correspondence :regarding this tnatt~rH••.ving said that, we are requesting a hearing on the matter in gc<estion. Please ad,rise when/where 

to appear for the same. 

Tha.nk you in advo.nce, and have a great holiday season and a wonderful New Year. 

0~ely, 

~~P--------- Pek:ka Karu 

Pn:oidcm / Director of Operations 

Smrjet, Inc. 

Air Can1erJ8GA460L 

26 WASMINGiTGN SOULEVA.RD, 2NO f'I-OOR • MARINA, D~J.. REY • CA !:!Oi'.:i.IZ a TEL: (310) ~Ol•$3~5 a (::110) 301-1:!~6 o WWW . .STARJ~!INC,COM 
01/06/2015 12:55 FAX 3107256816 AlVP-7 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

In the Matter of: 

FAA DOCKET 

Starjet, Inc. 

FAA CASE NO. 20l4WP230019 

Respondent 

JlJDGE NOT ASSJGNED 

COMPLAINT 

The Complainant files its Complaint, pursuant to Rule 208 of the Rules of Practice (14 

C .F.R. 13.208), and states as follows: 

I. 

lilJ 004 

Respondent, Starjet, Inc. was advised thfl)ngh a Final Notice of Proposed Civil Penalty 

that the FAA proposed to assess a civil penalty in the amount of $13,200.00. On December 2 L 

2014, Respondent submitted a written request for a hearing. 

n. 

1 . Respondent is now, and at all times mentioJ}ed herein was, the holder of Air Carrier 

Certificate No. J8GA460L, issued under part 119 of Title 14 of the Code of Federal 

Regulations. Respondent was and is authorized to conduct operations Linder part 135 

of 14 C.F.R. 
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-2-

2. At all times relevant herein, Respondent's operations specifications authorized it to 

conduct operations under part 135 using civil aircraft N213BA, a Gulf.5tream GA 

1159-A. 

3. At all times relevant herein, Respondent's operations specifications required that 

Respondent maintain each aircraf1 in accordance with the continuous airwfJrthiness 

1naintemmce program ("CAMP"). 

141005 

4. At all times relevant herein, Respondent's operations specifications rcquir,od that 

Respondent maintain each aircraft andl its component parts, accessories, ad 

appliances in an airworthy condition in accordance with the time limits fo1· tl1e 

accomplishment of the overhaul, replacement, periodic inspection, and rotJtine checks 

of the ab~craft and its component parts, accessories, and appliances. 

5. The CAMP document identit1ed in Respondent's operations specificmiom for the OA 

1159-B is "GA-1159-B (G-Il-B) MM as revised, Gulfstream CMP, ancl!CA's for 

STC's and Field Approvals as listed on FAA Form 337's." 

6. At all times relevant herein, as per its CAMP program, Respondent used Oulfstream 

CMP (Computerized Maintenance Program) for managing compliance with aircraft 

maintenance, including tracking the life limited components of its aircraft. 
01/06/2015 12:56 FAX 3107256816 A\VP-7 141006 

-3-

7. Rcspodcnt failed to track total time in service of the engines on N2l3BA fmd 

maintain records of the cmrent status of the life-limited components of the engines. 

8. The following are examples, not exclusive, of information .from records pertaining to 

E ngiue 

P<J sition 

1 

2 

2 

2 

---

---

the Rolls Royce Model Spey 511-8 engines currently on N213BA. "N/S'' stands for 

not specified. 

'Record 'Date IE:ngine Time ! Cycles 

Serial Since I Since 

Number New New 

(hours) 

Engine loebook 08/15/2005 9817 8989.7 5477 

Engine logbook 08/27/2009 N/S 10599.9 6320 

Starjet Gulfstream 06/29/2012 N/S R372.0 4724 

Computerized 

Maintenance Program 

(SGCMP) - SGCMP ll/12/2013 N/S 8740.3 4998 

SGCMP 12/05/2013 N/S ] 1622.6 6971 

-

Engine logbook 08115/2005 8989 9996.7 5972 

Eng:inc logbook 07/0112008 N!S ] 1318.9 6697 

SGCMP 09/!5/201 0 NIS 8774.2 4852 __ , 

. SGCMP 07/22!2011 N/S 9015.4 4979 

SGCMP 08/26/201] ''-J/S 9023.5 4988 

SGCMP 06/29/2012 N/S 9259.2 5152 

SGCMP __ _.,,.. 11112/2013 N/S 9627 5 5426 

SGCMP 12/05/2013 N/S 12629.6 7466 "'•' 
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-4-

9. The above records re±1ect that the engine at Position 1 had fewer total hours and 

fewer total cycles than it had at a prevcous date. For example, compare the: Time 

Since New and Cycles Since New on 06/29/2012 and 11/12/2013 with the Time 

Since New and Cycles Since New on 08/27/2009. 

10. The above records also reflect an impossible accumulation of time for the engine al 

Position 1. Compare the Time Since New on 11112/2013 with the Time S'-nce New 

on 12/05/2013; the records reflect tha1 the engine at Position 1 accumulatecl2882.3 

hours in only 23 days. 

11. The above records re±1ect that the engine at Position 2 had fewer total bou-s and 

fewer total cycles than it had at a previous date. For example, compare th'= Time 

Since New m:td Cycles Since New on 09/15/2010,07/22/2011,08/26/2011, 

06/29/2012 and 11/12/2013 with the Time Since New and Cycles Since New on 

07/01/2008. 

lill 007 

12. The above records also reflect an impossible accumulation of time for the engine at 

Position 2. Compm:e the Time Since New on 11112/2013 with the Time Since New 

on 12/05/2013; the records reflect that the engine at Position 2 accmnulated 3002.1 

hours in only 23 days. 
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-5-

13. The records demonstrate that the actual engine total times and actual total :yde~ 

cannot be determined_ 

IE. 

By reason of the foregoing facts and circumstances, Respondent violated the lollowing 

S-ections of the f edcral Aviation Regulations (Title 14, Code of Federal Regulations) 

141008 

a. Section l35.43l(a), which states: Each certificate holder shall establish and maintai.n 

a system for the continuing analysis and surveillance of the perfom1ancc snd 

effectiveness of its inspection program and the program covering other maintenance_ 

preventive maintenance, and alterations and for the correction of any deficiency in 

those programs, regardless of whether those programs are carried out by the 

certificate holder or by another perso11; and 

b. Section l35.439(a), which states: Each certificate holder shall keep (using the system 

specified in §135.427) the following records for the periods specified in paragraph (b) 

of this scctionc (1) All the records necessary to show that all requirements for the 

issuance of an airworthiness release under § 135.443 have been met. (2) Records 

containing the following information: (i) The total time in service of the airfi'ame, 

engine, propeller, and rotor. (ii) The current status oflife-limited parts oi· each 

airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of 

each item installed on the aircraft which are required to be overhauled on a specified 
01/0612015 12:56 FAX 3107256316 AWP-7 141009 

time basis. (iv) The identification of the current inspection status of the aircra't 

including the iime since the last inspections required by the inspection pro gran under 

which the aircraft and its appliances arc maintained. (v) The current status of 

applicable airworthiness directives, including the date and methods of complimcc, and, if 

the airworthiness directive in.volves recurring action, the time and date when the next 

action is required. 

IV. 

l. Pursuant to Title 49 U.S.C. Section 46301 (a)(S)(A), Respondent is subject to a 

civil penalty not to exceed $11,000.00 for each ofthe violations alleged. 

2. Under the facts and circumstances of this case, a civil penalty of$1 3,200.00 is 

appropriate. 

WHEREFORE, the Complainant, respectfully requests that the Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amount of$13.200.00. 

Re$pectfully submitted, 

Lisa~ ~r· .. ~ f?eJIZ- A;;torney 

Office of the Regional Cotmsel 

Federal Aviation Administration 

V.estem-l'acific Region 

DI\TFD: January 6, 2015 

. 

. 
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CERTIFICATE OF SERVICE 

I hereby certify that on this date I have sent by facsimile and placed in the llni ted States 

mail, postage prepaid, certified mail-return receipt requested, the executed original of the 

C.nnplaint, addressed as follows: 

F cderal Aviation Administration 

800 Independence Avenue,. SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl000 

Facsimile: 202-267~1293 

l further certify that on this date l have placed in the United States mail, postage prepaid, 

certified mail-retum receipt requested and regular mail, a true copy of the Complaint addressed 

aO' follows: 

PekkaKaru 

President/J)imctor of Operations 

Starjet, lnc. 

26 Washington Blvd, 2"d Floor 

Marina Del Rey, CA 90292 

])ated: January 6, 2015 

_,({tq!Jk~ Agnes Ebilane 

Legal Technicia1.1 

Office of the Regional Counsel 

Federal Aviation Administration 

'i>/estern-Pacific Region 

Lawndale, California 
01/06/2015 12:55 FAX 3107256816 A\VP-7 

--=--- ----------··-· To: HearinQ Docket Clerk, AGC-430 

Company: 

Phone: 

Fax: ----'--='------- --..1.Q?:.f.?.Z ;,129~ .. 

From: Lisa J. Toscano 

Title: Attorney 

1/6/2015 

Date: 

Pages wlcover: 10 

---------·---·-· ----------------

li!J 001 

Federal Aviation 

Administration 

Office of the Regional counsel, AWP-7 

PO Box92007 

Los Angeles, CA 90009-2007 

Telephone: (310) 725-7100 

Facsimile: (310) 725-6816 

Email: 

Facsimile 

Description of item being transmitted: 

Complaint and Request for Hearing 

Starjet, Inc. 

Case No. 2014WP230019 

0 Pe,· your Request 0 For Review D Please Comment 0 For Coordination tJ Hard Copy to Follow via US Mail 

~--~=======~~~-~=========== 

NOTES/COMMENTS: 

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The information transmitted may be subject to the attorney-client privilege or may be protected under the Privacy 

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COMMUNICATION IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY TELEPHONING (31 0) 725-

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0 U.S. D"1P<'.tllrn8nl Of Transportation