Open Letter to the FAA Flight Standard District Office, Fresno, CA

James Murray- Operations Supervisor
David Lehman – Airworthiness Supervisor

In Re: American School of Aviation

Dear Messrs Murray and Lehman:

In the FAA Aircraft Registry records, there appears to exist conflicting records that are likely to constitute a violation in compliance with the statutory requirement relating to civil aircraft registry in the US.

Synopsis:
American School of Aviation, Inc. is a California corporation with its president and other corporate officer(s) are not U.S. citizen.

Title 14 CFR Part 47 of the Federal Aviation Regulations (FAR) governs the requirement related to the civil aircraft registration in the US

Part 47.3 stipulates Registration required.
Part 47.5 defines Applicants.
Part 47.7 defines U.S. citizens and resident aliens with respect to civil aircraft registration.
Part 47.9 defines “Corporations not U.S. citizen”.
Part 47.9 (f) stipulates thrice annual report requirement by the registrant to the FAA.

Analysis:
All ASA aircraft except one (30 before 8/04/08 down to 11 as of 8/14/2008 ) are currently registered under FAR Part 47.7 and issued aircraft registration certificate bearing “Corporation” instead of its true and factual status of its corporate entity as “Foreign Corporation”. In the FAA AC Form 8050-1 Aircraft Registration Application, there is a specific box to be checked off for Non-citizen Corporation and provided along with “Certification” section for the applicant’s certification for a non-citizen corporation. If these sections were properly completed in the ASA aircraft registration application, all of its registration then should have been issued under Part 47.9 with the respective registration certificate bearing ”Foreign corporation”

Conclusion:
If ASA has made erroneous entry in its aircraft registration application and submitted to the FAA Aircraft Registry knowingly or not knowingly and obtained its registration certificate, then the ASA aircraft are not registered under Part 47.9 and not in compliance with Part 47.9(f) requirement. This ipso facto invalidates all of its registrations under FAR 47.41(a) ( 8 ) (ii) and requires ASA to surrender all of its invalidated registration certificate immediately in accordance with FAR 47.43 (b).

One of the school owners had publicly stated their school received 109 surveillance visits from your office in 2007, yet why this blatant aircraft registration violation eluded the filed inspectors scrutiny is beyond me.

There exists an ample evidence based on flight activities taking place recently at Hayward, Modesto and elsewhere to indicate the school is still operating under the guise of new satellite base after its 141 school certification has been long presumed to be suspended if not revoked already.

In view of the matter affecting the welfare and interests of all those victimized students as well as that of local aviation community, it would be most appropriate that your office offers a public announcement in connection with the ASA matter as soon as aircraft registration investigation is completed.

All eyes are on your prudent and swift enforcement action.

Respectfully submitted.

Echo Yankee

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10 thoughts on “Open Letter to the FAA Flight Standard District Office, Fresno, CA

  1. Ex,
    Your assumption on FAA is way contorted and dead wrong.
    If you have some solid story to tell that you can back it up, then let’s hear about it or else such statement shouldn’t be made in a public forum so carelessly.

    Exception of low level clerical workers in the office, most FAA people is a career bureaucrat with high integrity. Most operations people have extensive prior aviaiton background in military of civilian sector. In fact, I know many of the field inspectors worked as chief pilot, check airman, designated examiner, director of maintenance and etc. before joining the FAA. They are respectable and honorable people.

    If you want to know where all the money went, read my 7/17/08 post.
    Here’s the excerpt:

    In my ball park estimation of the ASA monthly expense of $225k ~$250k is based on the following operational assumptions, give or take:

    Payroll (40 CFIs, plus mx crew, plus owner’s draw) $115k
    FICA /Emp. Taxes $ 25k
    Insurance (monthly premium) A/C, Operation, Liability $ 10k
    Rent (Dormitory, Hangar, Office) $ 18k
    Fuel/Oil (10k gal. 220qt.) $ 54k
    Repair and parts $ 3k
    Total $225k

    It is based on a 40 hrs. per day operation for 20~25 students flying 1.3~1.5 hr.per lesson. For a good month (good wx, A/C availability, etc.) figure 10% more for additional direct operating costs. Again it’s my ball park figure but I feel I am not too far off on this numbers, in fact Bhavana N’s post stating that Prince told them he needs 5 new students every months to keep the operation going pretty much validates my above estimate.

    Echo Yankee, out!

  2. Secondcity,
    What happened to all the headline posts that disappeared?

    A technical glitch, or intentional connivance? Hummm??

  3. Which posts are missing? We can see all the 48 posts published from our end. May be some sort of server changing hands or so. Please go to the main url of the site which is https://2ndcity.wordpress.com scroll down to the bottom of the page and click on previous entries on every page. You’ll find the posts you are looking for. Happy Independence day to all fellow Indians and congratulations to Abhinav Bindra for winning us first ever Olympic Gold after 28 years in individual event!

    Regards

    Ashutosh
    SecondCity News Desk

  4. Hello Ashutosh,
    Following path showed all the recent posts headlines on one opening page with 2ndcity icon and color graphic inscription box icon as late as 2 hours ago but it now only shows the most recent headline with 2ndcity icon dated 7/30/2008.

    http://wordpress.com/tag/american-school-of-aviation/

    Your instruction worked as stated and it will do just fine. I just became so familiar with the one page format showing all the latest post headlines.

    Congrats on your National Independence Day and the Gold Medal by Abhinav Bindra. Forgive my ignorance but perhaps you could allude me to the coverage of this athlete if you’re so kind.

    BTW, I’m wondering which Indian city 2ndcity is located, inquiring mind wants to know.

    Thank you and regards.

    echo yankee, out!

  5. Happy Independence Day Folks!!!

    Getting loads of hits today!!!! Thanks for your continued support and your comments and brilliant research done by Echo yankee! We would like to thank all our readers, contributors and commentators such as Bhavna (we are missing her these days). Hope you’ll keep everyone updated with the latest news and development on ASA. We are situated in Bangkok (Thailand), Seattle (WA) & Chandigarh (India). Our team consists of travel writers, Indian & South Asian Journalists & former RJ with Radio Bangkok. Quite a mix of talent at one place!
    About Abhinav Bindra, no words to describe the feeling! Ashutosh will surely write a piece about him tomorrow.

    With lots of love & good luck

    Meenaxi Rai

  6. Meenaxi Rai,

    Thank you for the kind words and a glimpse of 2ndcity operation.

    As an international business consultant at present specializing in aviation marketing to hi-tech M&R deals, I visit many metropolitan cities in Asia, and Bangkok remains one of my favorite cities.

    All the best to you all.

    echo yankee, out!

  7. holy crap. whoever the author of this blog is.
    my sincere thanks to him/her/them.. for supporting us in this fight for justice..

    i have no doubts that these crooks will be behind bars soon..
    hopefully u will be by our side til then..
    thank you …

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