U.S. Department 

of Transportation 

Federal Aviation 

Administration 

April!O, 2015 

Ms. Catherine L. Kloess 

President 

Office of the Chief Counsel 

TJP@JAX Inc. d/b/a The Jumping Place 

5731 18th St 

Zephyrhills, FL 33542 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Re: TJP@JAX Inc. v. St. Marv's Airport Authority; FAA Docket No. 16-15-06 

Dear Ms. Kloess: 

We have determined the above-captioned complaint, filed by you against the respondent, the 

StMary's Airport Authority, is incomplete under 14 C.P.R. part 16. 

Under 14 C.P.R. § 16.23(b ), complainants must (I) state "the specific provisions of each Act 

that the complainant believes were violated"; (2) provide "a concise but complete statement 

of the facts relied upon to substantiate each allegation"; (3) provide "all documents then 

available in the exercise of reasonable diligence ... in support of the complaint"; and (4) 

describe "how the complainant was directly and substantially affected by the things done or 

omitted to be done by the respondents." 

You submitted a complaint that includes a narrative of alleged denial of access for skydiving 

operations at St. Mary's Airport. You seem to allege a violation of Grant Assurance 22 by St. 

Mary's Airport, but this allegation (or allegation of other violations) is not clear from the 

complaint. Additionally, although some facts are stated in the complaint, those facts seem to 

be incomplete (e.g., specificity of occasions when TJP@JAX Inc. was denied access) as well 

as any documentation supporting the alleged denial of access. Furthermore, the certificate of 

service lists several individuals (specifically, Frank Frasca and James E. Stein) about whom 

no allegation of violation is made. The complamt must tdenufy tile specific proviSions of tile 

Act that the complainant believes were violated and a complete statement of facts relied upon 

to substantiate each allegation. 14 C.P.R.§ 16.23(b)(l), (3). 

Additionally, complainants must describe how they are "directly and substantially affected 

by the alleged noncompliance." 14 C.P.R.§ 16.21(a). Although a specific statement is not 

made in the complaint, the FAA construes a direct and substantial effect from the alleged 

facts. However, under 14 C.P.R.§ 16.21, prior to filing a part 16 complaint, a person directly 
and substantially affected by the alleged noncompliance must engage in good faith efforts to 

resolve the disputed matter informally with those individuals or entities believed responsible 

for the noncompliance. The FAA will not consider a complaint under part 16 unless it 

certifies that: 

(1) The complainant has made substantial and reasonable good faith efforts to 

resolve the disputed matter informally prior to filing the complaint; and 

(2) There is no reasonable prospect for practical and timely resolution of the 

dispute. 

14 C.P.R.§ 16.21(b)(l)-(2). Efforts to resolve informally should be relatively recent and be 

demonstrated by pertinent documentation. 14 C.P.R.§ 16.2l(c). 

Your complaint does not include the express certification required under§ 16.21. Your 

complaint also does not include any relatively recent documentation demonstrating your 

efforts to resolve the disputed matter. 

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Finally, 14 C.P.R.§ 16.15 sets forth the procedures for service of documents on the FAA and 

on parties. Your certificate of service was not signed as required under§ 16.15(a). Also, the 

certificate of service states the complaint was mailed on February 12, 2015, but the complaint 

was received by the FAA on April 2, 2015. 

Your complaint is dismissed without prejudice as incomplete under 14 C.P.R. § 16.27. You 

may file a new complaint that corrects the deficiencies noted above. Part 16 docket number 

16-15-06 is hereby closed. 

Should you have any questions on this matter, please contact me at (202) 267-3199 or the 

Office of Airports at (202) 267-3085. 

Attorney, Airport Law Branch 

Office of the Chief Counsel 

cc: St. Mary's Airport Authority 

John J. Holman, City Manager 

418 Osborne St 

St Marys, GA 31558 
Jay Jeffrey Stanford 

Manager, Stanford Airport Authority Board 

611 Carract Ct 

St. Marys, GA 31558 

Jay Jeffrey Stanford 

St. Marys Aviation 

400 N. Dandy St 

St Marys, GA 31558 

Frank Frasca 

909 Larkspur Ln 

St. Marys, GA 31558 

James E. Stein 

52 Camden Woods Pkwy E 

Kingsland, GA 31548 

Part 16 Proceedings Docket 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on / t7 2vfS:used to be placed in the 

United States Mail (first class mail, ostage paid) or ersonally delivered a true copy of the 

foregoing NOTICE OF DOCKETING ddressed to: 

Complainant 

Ms. Catherine L. Kloess 

President 

TJP@JAX INC. D/B/A THE JUMPING PLACE 

5731 18th St 

Zephyrhills, FL 33542 

Respondent 

John J. Holman 

City Manager 

ST. MARY'S AIRPORT AUTHORITY 

418 Osborne St 

St Marys, GA 31558 

Jay Jeffrey Stanford 

Manager 

Stanford Airport Authority Board 

611 Carract Ct 

St. Marys, GA 31558 

Jay Jeffrey Stanford 

St. Marys Aviation 

400 N. Dandy St 

St Marys, GA 31558 

Frank Frasca James E. Stein 

909 Larkspur Ln 

St. Marys, GA 31558 

52 Camden Woods Pkwy E 

Kingsland, GA 31548 

Hand-Delivered to: 

FAA Part 16 Airport Proceedings Docket (AGC-600) 

FAA Office of Airport Compliance and Management Analysis (AC0-1 00) 

I 

Christopher Huch 

Airports & Environmental Law Division 

FAA Office of the Chief Counsel 

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