02/19/2010 12:4G FAX 2024935142 FAA * DMS 0001/003 

fi "K :>v., •••.'.,.^? ;? ^ I Y iiu . TU> ' 

Fee -12010 

HEARING DOCKET 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATIOIN ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION 

Complainant, 

FAA Case No. 2007NE800010 

CITY OF BRIDGEPORT CONNECTICUT 

Respondent. 

Honorable Isaac D, Benkin 

Administrative law Judge 

FAA Docket No. CP -

(Civil Penalty Action) 

February 1, 2010 

RESPONDENT'S ANSWER 

I 

1. Paragraph 1 is admitted. 

2. Paragraph 2 is admitted. .'l 

3. Paragraph 3 is admitted. 

4. Paragraph 4 is admitted, 

5. As to the allegations of Paragraph 5, It is admitted that the FAA conducted an 

inspection on IVIarch 29 2007and March 30, 2007^ and that findings were made. 

It is denied that that there were numerous unsatisfactory discrepancies 

concerning Bridgeport's duties and responsibilities. 

6. As to the allegations of Paragraph 6, it is admitted that the FAA made 

determinations regarding Bridgeport's FAA- approved ACM and 14 CFR Part 

139. It is denied that Bridgeport failed to comply in any manner. 

7. As to the allegations of Paragraph 7, it is admitted that the FAA made certain 

determinations. The reminder of the allegations of Paragraph 7 is denied. 

— I 

" 1 1 

' - H 

^ I 

CD 
02/19/201 0 12:47 FAX 2024935142 FAA * DMS 1002/00 3 

8. As to the allegations of Paragraph 8, it is admitted that the FAA made numerous 

findings. The remainder of the allegations of Paragraph 8 are denied. 

9. Paragraph 9 is admitted. 

10. Paragraph 10 is denied. 

11. Paragraph 11 is denied. 

12. Paragraph 12 is admitted. 

13. Paragraph 13 Is denied. 

14. Paragraph 14 is admitted. 

15. Paragraph 15 is admitted, 

16. Paragraph 16 is denied. 

17. Paragraph 17 is admitted. 

18. As to the allegations of Paragraph 18, it is admitted that the FAA made certain 

findings. It is denied that Bridgeport failed to comply, and/or failed to require 

other fueling agents to comply, with the standards of 14 C.F.R. Section 139.321 

As to the allegations of sub-Paragraphs 18 (a-d), the Respondent lacks sufficient 

information upon which to form a belief and therefore leaves the Complainant to 

its proof, 

19. Paragraph 19 is admitted. 

20. Paragraph 20 is denied. 

21. Paragraph 21 is admitted, 

22. Paragraph 22 is denied. 

23. Paragraph 23 is denied. 
02/19/201 0 12:4 7 FAX 202493514 2 FAA •*• DMS 1003/003 

24. As to the allegations of Paragraph 24, it is admitted that the FAA made certain 

findings regarding bird activity. The remainder of the allegations of Paragraph 24 

[are] is denied. 

25. Paragraph 25 is denied. 

26. The allegations of Paragraphs 26 (a-k) and (m-p) are denied. As to the 

allegations of Paragraph 26 (I), it is admitted that water occasionally accumulated 

in some isolated safety areas. It is denied that the Respondent failed to maintain 

the safety areas. At the time of the alleged violations, a proposed reconstruction 

project had been submitted to and was pending before the FAA. 

27. Paragraph 27 is denied. 

28. Paragraph 28 is denied. 

THE RESPONDENT^ 

CITY OF BRIDGEPORT 

BY 

Richard G/Kascak, Jr. 

Associate City Attorney 

Office of the City Attorney 

999 Broad Street, 2"** Floor 

Bridgeport, Connecticut 06604-4328 

Telephone (203) 576- 7647 

Facsimile (203) 576-8252 

richard.kascak@bridgeportct.gov