COFFIN, Senior Circuit Judge.
On the evening of November 19, 1993, an emergency medical evacuation helicopter operated by petitioner Echo, Inc. (Echo) ran out of fuel, lost engine power, and crashed into Casco Bay off the Maine coast, killing three passengers. The Federal Aviation Administration (the FAA) charged the pilot and Echo with violating several aviation safety regulations and issued emergency orders revoking Echo's certificate to operate as an air carrier...
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