U.S. Department ofTransportation Federal Aviation Administration April!O, 2015 Ms. Catherine L. Kloess President Office ofthe 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; FAADocketNo. 16-15-06

Dear Ms. Kloess: We have determined the above-captioned complaint, filed by you against the respondent, the StMary'sAirport 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 ofeach Act thatthe complainant believes were violated"; (2) provide "aconcise but complete statement ofthe facts relied upon to substantiate each allegation"; (3) provide "all documents then available inthe exercise ofreasonable diligence

... in support ofthe complaint"; and (4) describe "howthe 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 ofalleged denial ofaccess for skydiving operations at St. Mary's Airport. You seem to allege a violation ofGrant Assurance 22 by St. Mary's Airport, butthis allegation (or allegation ofother violations) is not clear from the complaint. Additionally, although some facts are stated inthe complaint, those facts seem to beincomplete (e.g., specificity ofoccasions when TJP@JAX Inc. was denied access) as well as any documentation supporting the alleged denial ofaccess. Furthermore, the certificate of service lists several individuals (specifically, FrankFrasca andJames E. Stein) about whom no allegation ofviolation is made. The complamtmust tdenufy tile specific proviSions oftile Actthat the complainant believes were violated and a complete statement offacts relied upon to substantiate each allegation. 14 C.P.R.§ 16.23(b)(l), (3). Additionally, complainants must describe howthey are "directly and substantially affected bythe alleged noncompliance." 14 C.P.R.§ 16.21(a). Although a specific statement is not made inthe 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 directlyand substantially affected bythe alleged noncompliance must engage in good faith efforts to resolve the disputed matter informally with those individuals or entities believedresponsible for the noncompliance. The FAA will not consider a complaintunder part 16 unless it certifies that: (1) The complainanthas 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 ofthe 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 certificationrequired under§ 16.21. Your complaint also does not include any relatively recent documentation demonstrating your efforts to resolve the disputed matter. 2

Finally, 14 C.P.R.§ 16.15 sets forth the procedures for service ofdocuments onthe FAA and onparties. Your certificate ofservice was not signed as required under§ 16.15(a). Also, the certificate ofservice states the complaint was mailed onFebruary 12, 2015, butthe complaint was received bythe FAA onApril 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 docketnumber 16-15-06 is hereby closed. Should you have any questions onthis matter, please contactme at (202) 267-3199 or the Office ofAirports at (202) 267-3085.

Attorney, Airport LawBranch Office ofthe ChiefCounsel

cc: St. Mary's Airport Authority John J. Holman, City Manager 418 Osborne St St Marys, GA 31558Jay Jeffrey Stanford Manager, StanfordAirport Authority Board 611 Carract Ct St. Marys, GA 31558 Jay Jeffrey Stanford St. Marys Aviation 400 N. Dandy St StMarys, GA 31558 Frank Frasca 909 LarkspurLn St. Marys, GA 31558 James E. Stein 52 CamdenWoods Pkwy E Kingsland, GA 31548 Part 16 Proceedings Docket 3CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on /

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# 2vfS:usedto be placed inthe United States Mail (first class mail, ostage paid) or ersonally delivered a true copy ofthe 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 JohnJ. Holman CityManager ST. MARY'S AIRPORT AUTHORITY 418 Osborne St St Marys, GA 31558 JayJeffrey 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 James E. Stein Frank Frasca 909 Larkspur Ln St. Marys, GA 31558 52 Camden Woods Pkwy E Kingsland, GA 31548 Hand-Deliveredto: FAA Part 16 Airport Proceedings Docket (AGC-600) FAA Office ofAirport Compliance and Management Analysis (AC0-100)
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Christopher Huch Airports & Environmental Law Division FAA Office ofthe ChiefCounsel 4