TANG, Circuit Judge:
Essery petitions for review the revocation of his commercial pilot certificate by the National Transportation Safety Board (NTSB). The Federal Aviation Administration (FAA) revoked the certificate after finding that Essery violated FAA regulations in two incidents: (1) towing a banner over San Diego by plane and (2) delivering a Santa Claus to a downtown San Diego intersection by helicopter. Administrative Law Judge Davis held an evidentiary hearing...
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