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JEFFREY M.HARJTXR 

FAA OFFICE OF REGIONA;. COUNSEL 

1601 Ll>nD AVENXTI SOUTHV/EST 

RENTON, WASHINGTON 9S0S1 

TELEPHONE: (425)227-216 1 

FACSIMILE: (42?) 227-1007 

JER^RTMhNT OF 

RANSPOHTATION 

CKET OPERATIONS 

2uii CC! 13 P 2- 0 1 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C 

In the Mancr of; 

Comersione Aviation, Inc 

FAA Ca5e No. 201INM070021 

DMS No. FAA-2011-0484 

Motion for Decision 

Judge Richard C. Qoodwia 

To the Honorable Richard C. Goodwin: 

MOTION FOR DECISION OR. IN THE ALTERNATIVE 

MOTION FOR SUMMARY JUDGMENT 

HEREAFTER LCVnTCSG HEARING TO SANCTION 

In accordance v.'ith 14C.F.R. § 13.218(f)(5) (Rule 13.218(f)(5)), the Administrator brings this 

Motion for Decision. Tliere are no genuine issues of material fact, as Rcppondent has admitted all 

relevant facts eiiher ic its Answer or in its responses to Requests for Admissions. The 

Administrator is entitled to a decision as a matter of law. 

Facts 

The Complaint in this case was served on May 26, 2011, The Complaint alleges Comersfone 

Aviation, Inc. (Kespondent) violated 14 C.F.R. §§ 14L77(a)(l), 141.77(h), 141.83(a)(1), and 

141.101(a). These violations relate to Respondent's failure to maintain accurate training records 

for an instrument student, Ms. Haley Wilson. Respondent filed jtg Answer on June 12, 2011.' 

The Answer admitted all ;he factual allegations in the Complaint, with the exception of . 

paragraph 5.^ 

Complaini. 

^ Answer, 

•' Answer. 

ComplflJnwifs Motion For Decision 

Comer,<lone Aviation. Tnc. - FA^-201 N04W 

20iiNMC'7ao:r 

Page J of^ 

JEITREY M. HAP-PEF, ¥AA ATTOilNEY 

7£L:(4:5}2;7-2161;KAX:(425):;27-1007 

ELO/SOOl g SVJQ - VVJ Zt>i9ZQ\>Z0Z XVd 95:21 Lt02/ei/0L 
ia/13/2B:J 09:35 4252271007 ANM7 rft(^ 03/13 

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Paragraph 5 of the Complaint, alleged that Ms. Wilson was enrolled in the InstmmeDt - Airplane 

rating coTiTse of training on Jiine 10, 2010, and that she did not receive credit for any prior 

instrument airplane rating ground training. 

However, Respondent's discovery response admitted every underlying fact of the Complaint's 

paragraph 5. Respondent admitted Ms. Wilson was enrolled in the Instrument course of training.'* 

Respondent admitted Ms. Wilson's training record shows "0" hours of credit for previous ground 

training. Respondent admitted Ms, Wilson did not receive any credit for previous training, and 

even acknowledges that Ms. Wilson only would have been allowed partial credit for any previous 

training received. Respondent admitted Ms. Wilson actually received ground training from 

another institution, which was not a Part 141 school.^ 

In brief, Respondent has admitted every factual allegation of the Complaint. 

Argument 

Standard for Decision 

"The administrative law judge shall grant a party's motion for decision if the pleadings, 

depositions, answers to interrogaiories, admissions, matters that the administrative law judge has 

officially noticed ... show that there is no genuine issue of material fact and that the party niaking 

the motion is entitled to a decision as a matter of law. The party making the motion ... has the 

burden of showing tliai there is no genuine issue of material fact disputed by the parlies.'' 

14 C.F.R§ 13.21 srf)(5). 

Merits 

a. Graduation & Graduation Certificate— 14 C.F.R.§§ 141.77(a)(1) and 141.77(b) 

The Administrator alleges Cornerstone issued a graduation certificate to a student who had not 

completed the training specified in its course of training. Respondent is authorized to provide 

training for tlie Instrument rating using the Jeppesen Sandersoni Inc Instrument / Commerctal 

Course Syllabus (Syllabus). Complaint II.3, Answer 3. The Syllabus, in turri; requires that 

students complete 30.0 hours of ground training. 

Ms. Wilson was enrolled in Respondent's Instrument- Airplane course of training. Admission to 

Request for Admission 3. Respondent's records mdicate Ms. Wilson did not receive any of the 

•" Recju95t for Admission No. 3. 

^ Request far Admission. No. 4, 

' Request for Admission No. 5. 

RcaiiBsts for AdmiK!:)on NOP. 6 and 7. 

Complainant'i V[Qtion For DeciEion 

Comcrnonc Aviation, Iijc. - f A.^-20^-O4g4 

20nt{M070071 

Pege 2 of 8 

jEm»£Y ML H\RPEll, FAA ATTOK^EY 

TEL: (425) 227-2161: TAX f425) 227-JO07 

eio/eoo swo VVJ 2frLSS6t30S XVd L9'Z\ . LLO^/Cl/O L 
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ground training required by the syllabus- Complaint 117, Answer 7. Additionally, Ms. Wibon did 

not receive any credit for previously received ground training, as permitted by 14 C-F,R, 

§ 141.77(cX4). Admission to Request for Admission No. 4, Admission to Request for Admission 

No. 5. The lack of Part 141 ground training is corroborated by Ms. Wilson*? Jugbook^ wliich does 

not show the completion of any required ground trainLig. Complaint II.6, Answer 6. 

Ms. Wilson did receive ground training under Part 61 from Utah Valley Universit>'. Admission to 

Request for Admission No. 6. However, Utah Valley University is a Part 141 school. Admission 

to Request for Adnussion No. 7. As a result, at most 25% of the required 30 hours of training 

under the Syllabus could have been credited to Ms. Wilson for her training at Utah Valley 

Unlvcrsiry. 14C.F.R§ 14l,77(cK4). 

R.espondcnt graduated Ms. Wilson from respondent's Instrument - Airplane course, issuing her a 

graduation certificate on November 17, 2010. Complaint II.8, Answer S. A graduation certificate 

constitutes certification that a student has completed the required training. 14 C.F.R. § 141,95. 

Unquestionably J Respondent issued a graduation certificate to an individual who had not 

completed the training specified for Rospondem's students. Specifically, Ms. Wilson did not 

complete the ground training required for the Instrument - Aiiplane iciting. Sections 141.77(a)(1) 

and 141.77(b) prohibit a holder of a pilot certificate from issuing a graduation certificate to a 

smdent unless the student has completed the training/cum"cuJum specified in the pilot school's 

course of training. Respondent has done precisely the thing the regulation prohibits— graduated 

a student who had not received all required training. There is no genuine issue regardinf; these 

facts; the Administrator h entitled to a decision as a matter of law. 

b. Comphance with Approved Training Course — 14 C.F.R. § 141.83(a)(1) 

The Administrator alleges Cornerstone did not comply with its approved training course. As 

discussed in subparagraph (a), Respondent was required to provide Ma. Wilson with 30 hours of 

ground training to complete the Instrument- Airplane course under the approved Syllabus. 

Respondent failed to provide Ms. Wilson the required training, thereby deviating from its 

approved training course. 

c. Maintenance of Current and Accurate Records— 14 C.F.R, § 141.101(a). 

Secu'on 141.101(a) requires theholder of a pilot school certificate to establish and maintain a 

current and accurate record of the participation of each student enrolled in an approved course of 

training that includes, at a minimum, the date the student enrolled, a chronological log of the 

student's couj-se artCTidEince, and the date the student either graduated, lenninated L-aining, or 

transferred. 

ComplaiTiant's Motion For Decision 

Cornerstone A-vit^ion, tnc - FAA-;0 1 1-0484 

Paee 3 gf B 

LO/tOOE swa VVJ 

JEFFREY R HAWEB- FA A ATTORKEY 

TtL: (425) 227-2161; FAX; (425) :;7-)007 

3tL5EBtS02 XVJ i5 Zi LLO^/SL/OL 
10/13/2011 09:35 4252:^7100 7 AfJM7 PAGE 0?/1 3 

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The Certificate of Graduation for Ms. Wilson is inaccurate in that it states she completed all the 

course requirements. As discussed above, she had not — her records show no ground training 

received. The record of ground training is itself inaccurate. Ms. Wilson received ground training 

from Utali Valley University. Admission to Request for Admission No. 6. Her record shows "0'' 

hours credit for that training. Admission to Request for Admission No. 4. As Respondent admits 

to inaccuracies in Ms. Wilson's Part 141 records, there is no genuine issue of ihc material facts 

related to whether Respondent maintained accurate records as required by 14 C.F.R. 

§ 141.101(a). 

d. Merits — Conclusion 

In conclusion, thei« ar? no genuine issues of material fact in this case — all material facts have 

been admitted by Respondent in either the Answer or as a resuJt of Requests for Admission 

propounded in discovery. The facts establish the alleged violations occurred. The .Administrator 

is entitled to a decision as a matter of law by 14 C.F.R § 13.218(f)(5). 

Sanction 

a. Standard 

Under 49 U.S.C. § 46301(a)(5)(A). a "small business concern is liable to the Government for a 

civil penalty of not more than $10,000..." The maximum penalty was adjusted to $11,000 on 

June 15, 2006. 14 CF-K- § '3-305 (Table).^ 

In determining an appropriate civil penalty, the Agency considers seven factors. In fhe Matter of 

Warbelo^v 's Air Ventures. Inc., FAA Order No. 2000-3 at 16-17 n. 22 and 21 (February 3, 2000). 

The Agency has the burden of justifying the amount of civil penalty sought. 14 C.F.R. 

§ 13.224(a); In the Matter of Luxemburg, FAA Order 1994-18 (June 22, 1994) at 4. To guide the 

FAA's prosecutorial discretion^ the Agency has promulgated penalty guidelines, which are found 

in FAA Order 2150.3B Chapter 7 and Appendix B dated October 1, 2007 (Sanction Guidance). 

The Sanction Guidance contains tables that establish specific penalty ranges for different types of 

violatioiis.^ The starting point for a sanction determination is the middle of the sanction range. 

Sanction Guidance, Appendix B, Paragraph 3,c. The FAA's sanction determination does not, 

however, reflect a fixed mathematical computation; in addition to the published penalty ranges, it 

takes into account thirteen factors set forth in Chapter 7, paragraph 4 of the sanction guidance, 

" 2 ? U.S.C. §246 1 (Note), 

' Sarctian Guidance, Appepdix B. 

ComplHinajirs Motion For Decision 

ComcrsTone Aviarion, Inc. - f AA-2011-048-i 

;onNNio7oo2i 

JEFFPXY M . HAWER, FA A ATTaRNBY 

TEL: (425) 22-;.2] 61, FAX : (425)227-1007 

CLO/SO O syjQ VVJ Ztii^ZQHO Z XVJ L<;-Zl [lOZ/Zi/O l 
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which address the issues set forth in Warhelo'^J'^ These factors are used to adjust the sanction 

upward or do^^nward from the middle of tbe recommended range. 

The FAA Order reflects the Administrator's general views about appropriate civil penalties; civil 

penalties must reflect the totality of the circurastances surrounding ihe \ToIation5. Folsom's Air 

Service, Inc., FAA Order No- 2008-11 (November 6, 2008). TTie weight to be given to each of 

these factors is within the discretion of the Complainant; "the Complainant maintains relative 

prosecutorial discretion in determining the case's final, aggregate weight in proposing the level of 

civil penalty." In the Matter of William A. Luker, Jr., FAA Docket No. CPO9SWOO0S, 2010 WL 

1989430 (May 13, 2010) (Order of Chief Judge Yodcr Granting Coroplainanfs Motion for 

Summary Judgment). Although a Department of Transportation Administrative Law Judge is not 

statutorily bound to follow the Administraior's guidance, "[a]n administrative agency is entitled 

to substantial deference in assessing the civil penalty appropriate for a violation of its tegulations. 

The agency's choice of a sanction is not to be overtumed unless it is unwarranted in law or 

^viThoViX }\xsXif:cdlionm fact.''' NL If-idustries, Inc. v. Dept of Transportation, 90\ F.2d 141» 144 

(D.C. Cir. 1990). 

Further, the Administrator has the ability to impose the Agency's sanction policy on appeal if the 

assessed civil penalty is net consistent with the policy./JJ the matter ofWarbclo-^'sAir Ventures, 

Inc., FAA Order No. 2000-3 (February 3,2000) at 20; In the matter of Northwest Airlines, FAA 

Order No. 1990-37 (November 7, 1990) at 8-9. 

b. MultiplicityComplainant has charged respondent with violating 14 C.F.R. §§ 141.77(a)(1), 141.77(b), 

14J,83(a)(1), and 141.101(a). Complainant concedes, however, tliat sections 141.77(a)(1) and 

141.770^) require proof of the same facts and therefore should be considered as one violation 

under ± e Blockburger test. Ball v. U.S., 470 U.S. 856, 861 (1985); Bhckburger v. U.S, 284 U.S. 

Thoso fecwre arc: 

a. Nature of tbe violation; 

b. Whether the violoiion *a£ inadvertent and not dclibfirate; 

c. The certificate holder's level of experience; 

d. The anitude of the violator; 

e. The degree of hazard; 

f. Whether there was nccion taken by the employer or oihtr authority a&aiasi ihc employes that committd the 

vio}ation(s); 

g. Use of the certificate; 

h- Violation history-; 

1. Decijional law; 

j . Ability to absorb the sancticm; 

k. Con51 stemcy of Sanction; 

1. Whether the violation was reported volunrarity: and 

m. Contctive Action. 

Complainant's Motion For Decfpion 

ComerjiKjne Avjtiion, Inc. - f AA-2011-0i84 

;onNM070021 

Pace s of 8 

.TFJFRT-YM HAJPER, FAA ATTOPJJEY 

TEL: (425) 227-21 e]; F.OC: (425) 227-1007 

e:L0/900ia SWQ - VVJ z\?i9ZGi>z(iz r a i<iz [ LLOS/CL/O I 
lQ/13/2011 09:35 d25227ia0" flNM7 PAGE 07/13 

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2P9, 304 (1932); /n the Matter of James Walsh, 200S WL 926620 at 9 (March 31, 2008); In the 

Matter of Folsom's Air Service, 7«c.,2006 WL 1316970 at 11 (May 3,2006) (staling that one 

violation that incorporates the others may not be considered as a separate violation for 

dererminiag the amount of the sanction). The Administrator thus considers tJxis case as having 

three violations, each of which is subject to the maximum $11,000 civil penalty. The 

Administrator seeks a total penalty of $5,000. 

c. Sanction Guidance 

As discussed, the Sanction Guddance establishes penalty ranges for different types of violations. 

Figure B-3-d lists penalty ranges. The listed penalty ranges are: 

Citation Penalt>' Range 

B-3-d(5)(b) Improper graduation of student 

(inadvertent) 

(14 C.F.R. §§ 141.77(a)(1) & 141.77(b)) 

B-3-d(8) Failure to maintain training record 

(14 C.F.R. § 141.101(1)) 

B-3-df7) Unauthorized instruction 

(14 C.F.R-§ 141.83(a)(1)) 

Moderate to Maximum 

Moderate to Maximum 

Moderate to Ma.ximum 

For a small business concern holding an Air Agency certificate, a moderate penalty is in the 

range of $3,950 - $7,149; a maximum penalty is in the range of $7,150 - $11,000. Sanction 

Guidance, Appendix B, Paragraph 3.c(4). The starting point of a sanction calculation is the 

midpoint of these ranges, $7,425. At the low end of the range, an appropriate sanction would he 3 

>: $3,950 = $11,850. The Administrator seeks a total of S5;000. less than half of the low end of 

the sanction guidance range, reflecting the application of a number of mitigating factors. 

.\ny deviation from th.e Sanction Guidelines lias been to Respondent's benefit. The 

Administrative Law Judge should defer to the Administrator's selection of sanction under ML 

Industries. Inc., 901 P.2d at 144, and enter an Order assessing the full $5,000 penaJty sought in 

the complaint. 

Conclusion 

For the reasons stated above, the F-^A respectfully requests that this Court grant this Motion for 

Decision. There are no genuine issues of material fact; the sanction sought is appropriate undo: 

the facts. In the alternative, if further litigation is wananted, the pleadings estabHsh that any 

Complainant's Motjon For Dcoijion 

CorncTstane Aviaiior, Inc. —FAA-2Q1 l-O-vfi* 

:OJINM07OQ2I 

Pace fi ftf ft 

JEFFREY M . HArj^p, FAA ATTOBK^Y 

TEL: (425) 227.216]; FAX: (425) 227-1007 

£ L 0 / i 0 0 SWG - VVj SfrLSCetJ^OS XVJ L^-Z i LL02/CI/0 L 
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hearing in this case be limited to the sajiction, as all the substantive facts of tliis case have been 

established. 

DATED t^s 13th day ofOctober, 2011. 

Je^ey M. Harper 

FAA Attorney 

Enclosures: (1) Respondent's Discover^' Response 

Complainant's MoT^n For DcdsiOTi 

Cornerstone Aviation, Inc.-FAA-ZOI 1-0484 

20UNM07002I 

Bin - 7 n^ S 

JEFFREY M . HAWEP.. F.AA ATTCRMTI' 

TF.L. (-125) 227-2161; FAX: (425) 22-7-1007 

SLO/80 0 s w a ^ VVJ SfrLSSetJ^OS XVJ 8S.SL Li02/EL/0 L 
ig/13/2011 09:35 425227100? ANM7 PAGE P9/-13 

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S3 

CERTIFICATE OF SERVICE 

I hereby certify thai the foregoing Motion for Decision has been served via facsimile aud 

Certified Mail - Return Receipt Requested this date, to the fallowing: 

Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersev Avenue, S.E. 

East Building Ground Floor, Rm E12-320 

Washington, D.C, 20590 

FAX: 202.366.7536 

Ann: Hearing Docker Clerk. AGC-430 

Wilbur Wright Building - Siute 2W1000 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington. D.C. 20591 

FAX: 202.493.5020 

Susan Horstman 

Chief Executive Officer 

Comerstone Aviation, Inc, 

337 North 2370 West J^130 

Salt Lake City, UT 84116 

FAX; (800 355-2754 

Dated this 13 ^ day of October, 2011. 

MOIF.MRCHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Rcnton,WA 98057 

425.227.2160 

ComplainanT's Morion For Decision 

Comersione Aviation, Inc. - FAA-2011-0484 

2011NM070021 

JEFFP£Y M. MAW-ESI, FA A ATTOTtNTiV 

TEL: (423) 227-2161: F.'VX: C«:5) 227-1007 

ELO/GOOl g SI'iQ ^ VVJ 3t?LSGGt?202 XVJ 85:6 L LlOS/ei/O L 
lG/13/2ei l 09:35 d2ii2271007 ANM7 PAGE lEi/13 

FAA Correspondence Complainant's Initial DiscovQry Request ^^'^W^SPfi Aviation 

IWTERR06ATPMES ^EP J g «. 

Since complaints are consolidated into one letter, the responses have also been consolida^^^ft|flJe 

refer to Initial iBttar to CSA for details of item numbers. 

1. Names, Addresses and Telephone Numbers (see attachment) 

2. All correspondence from FAA is In the possession of Susan Horstman, including all copies of 

documents sent to her by Jeffrey Harper. 

3. Names, Addresses and Telephone Numbers of persons wrfiom CSA intends to have testify as a 

factual or expert witness in CSA's defense at the hearing of this matter (see attacliment) 

4. The documents CSA anticipates offering into evidence at the hearing of this matter are the some 

CSA offered to the FAA FSDQ, all of which were sent to Jeffrey Harper The matters concerning 

SLCC records will be addressed by either Susan Horstman or Fiona Silcox. 

5. All expert witnesses are involved in flight trainii ^ in one aspect or another, e'rther as instructors, 

check pilots, assistant or chief instructors or FAA DP examiners, [see attachment) 

6. All expert witnesses are involved irt flight trair>fng in one aspect or another, erther as instructors, 

check pilots, assistant or chief instnjoors or FAA DP examiners. The subject matter is my FAA 

Part 141 TOO. One wilDess is a computer software specialist designing our new program7. Please clarify this request as I do not know who Mr. Midiaelby is. 

8- Since this has been ongoing for several rrwnths it is impossible to recall exact dates of 

conversations and wFth whom I have discussed the matters alleged in the Complaint, it is most 

likely limited v> persons affiliated with the flight school as they have received instruction so the 

occurrences wfll not happen again. 

9. CSA's Part 141TCO and training documents 

REQUESTS FOR PRODUCTION 

1-4 The FAA already has copies of the documents - do you need me to make additional copies 

of the rndtenals you sent to me? The software designer of n^w flight school training 

program has computer prototype ready. This will have to be shown in person to FAA. 

REQUEST FOR ADMISSIONS 

1. Admit 

2. Admit - did at the time; with FAA consent have now changed method of record keeping 

3. Admit 

4^ Admit — She was a transfer student from Utah Valley Unh/ersity where she completed her 

private pilot ground school course. 

Page 1 of 4 

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FAA Correspondence Complainant's Initial Discovery Request Cornerstone Aviation 

5. Admit - she only qualifies to recefve partial credit under her part 61 training which amounts to 

25% of the course requirements. So she could only count 7.5 hours towards her instrument 

ground Instruction. During the course of instrumeni: training her rrtstructor logged 18.8 hours of 

briefing time with her on a one-on-one basis. That equates to ZS.3 hours out of the required 30 

hours. 

6. Admit 

7. Admit - they used to be 141 but at the time of Wilson's training they were Part 61. 

8. Admit 

9. Admit 

10. Admit 

11. Admit 

12. Admit 

13. Admit 

14. Admit 

15. Admit 

.15. Admit 

17. No — When CSA administration discovered that Cameron Howell, hia instructor, and Michael 

Stann began the flight training prior xo his passing his private pilot certification check ride, CSA 

repaid Mr. Stann far his training up until that point (several thousand dollars) and told him that 

we could not count any of that training and would re-start his instrument program- CSA selfdisclosed that information to the FSDO in SIC CSA told his CFI to begin a new training record 

and destroy tha old record as it could not be used. Adrfrtionany, students have access to online 

scheduling program to schedule flights. Michael 3sn n scheduled ahead to start instrument 

training 

Page 2 of 4 

ELO/L LO SrtQ ^ VVJ ZVl^ZG^iZOZ XVJ 8SSL LLOS/GL/Ol 
10/13/2911 0^:35 ^•:5227lej07 ^NM7 P^GE 12/13 

FAA Correspondence Complainant's Initial Discovery Request ~ Cornerstone Aviation 

ATTACHMENT 

Cameron Howell - CFIl for Michael Stann 

1251 North Murdock Drtve 

Pleasant Grove, UT 840G2 

(BOl) 623-2858 

Kris Krie -CR I for Haley Wilson 

8791 S^juth Terra Poirtt Way 

West Jordan, UT 84088 

(801) 864-4421 

Michael stann - student of Cameron Howell 

2115 S. Richard Sti 

Salt Lake City. UT 84115 

[801) 244-1404 

Fiona Silcox - Assistant chief instructor for CSA at SLCC campus 

250 W. 3900 So. 

Salt Uk e Qty, UT 84107 

(801) 949-3194 

Brian Vanderwei -Chief instructor-for CSA 

1015 H. 1010 W. 

Pleasant Grove, UT 84062 

(SOI) 836-7112 

Richard Marshall - former chief instructor for CSA - Private Pilot Certification program 

7883 South Grant Street 

Midvale, UT 84047 

(801) 671-3302 

Tom Kuhlman - retired FAA, current Designated Pilot Examiner (DPE) 

9508 South Kilmuir Qrda 

So. Jordan, I;TS409 5 

(801) 633-G386 

Jack Garzella - Computer Software specialist 

1871 Longbranch Drive 

Draper, UT S4020 

(SOI) S23-8243 

Page 3 of 4 

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FAA Correspondence C^mplair«nt's Initial Discovery Request Cornerstone Aviation 

Bernard Connelly - FAA FSDO 

1D20 N. Flyer Way 

salt Lake City, LrTS4U6 

(801)257-5054 

William Hughes - FAA 

1020 N. Flyer Way 

Salt Lake aty,U T 84116 

(801) 257-5045 

George David Cawthra - FAA — FSDO Manager 

1020 N. Flyer Way 

Salt Lake aty,UT 84116 

(801) 257-5046 

Page 4 of 4 

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