MEMORANDOM FROM: President and CEO, RoomShare TO: VP of Operations, RoomShare DATE: July 21, 2020 RE: New Business Model Needed (as a result of COVID-19) As you know, due to the COVID-19 pandemic, revenue and number of individuals booking through our room sharing platform has decreased over 80% since February. We need to find new opportunities in the property sharing industry. I’ve been reading about how individually owned small aircraft, known as “general aviation,” are now operating almost back to normal levels compared to the airlines. Many of these types of aircraft can hold 4-6 people and can fly all over the country to the over 5,000 public use airports. That’s a lot of airports! This got me thinking, to make just like Uber and Lyft, why can’t we develop a smart phone app platform for these “general aviation” aircraft owners to advertise available seats in their aircraft to others?Here’s specifically my idea: this app would act like an exclusive “bulletin board,” but with push notifications to those who desire to travel on the same route as the aircraft owner/pilot. This app would only allow up to 200 individuals to join (i.e., pay a fee) at a time per airport base. Keeping it as a small group allows all the users to know each other better. When an aircraft owner/pilot has an extra seat to share on a proposed flight, that individual will enter that in the app, which will then notify through push notifications and/or email to those individuals in the same airport base who might be interested based on their profile. We could set up these bases at regional airports all over the country, and project to get well over $1,000,000 in revenues in the first year alone. I’ve done a little bit of research already. Apparently, several companies, such as Open Airplane, Flytenow and Blackbird have formed to offer similar air transportation programs using privately owned, non-commercially operated aircraft on an expense-sharing basis under 14 CFR 61.113(b) (formerly 61.118(b)). For some reason, the FAA has some sort of authority on this, and apparently, they don’t like these ideas. So, I need you to write up a formal memo responding to the following questions, because our general counsel is not knowledgeable about aviation.1. Does the FAA have authority over issues like this? If so, who or what says they have authority, what does the authority say, and what does it mean for us? A. Hint: You’ll need to do some legal research and apply those rules to the facts here to answer the question. 2. Assuming the FAA has authority, determine the FAA’s current position on the legality of what we propose and the reasoning behind that position (i.e., what is the FAA’s current legal and/or policy position on the matter, and why, i.e., what is the rationale) A. Hint: Same thing here, you’ll need to do some legal research, which will include court cases, FAA legal interpretations, and FAA policy (e.g., Advisory Circulars). 3. Based on our business model and what you found in your research, do you think we will be exposed to enforcement or civil penalties from the FAA? A. Hint: This is the analysis/application section. You will need to take all of the rules you found above and apply them to this scenario. 4. Finally, what is your recommendation? (e.g., should we move forward with this business plan, change it, or abandon it? Why?) Please respond with a memo answering these questions with an analysis based on your research that supports your conclusions. Additional Instructions: The memo must be between 3-5 pages long of substantive material (e.g. a reference page is not counted), double spaced, reasonable margins, reasonable font type and size. This memo should answer the questions above in a logical and coherent way, supported by appropriate and relevant sources of information. You may use MLA for citing Include some background about how COVID-19 has impacted the Aviation industry