UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINSTRATION 

WASHINGTON, D.C. 

WALKER AG SUPPLY, LLC, WALKER ) 

LUEDTKE, MIDWEST SPRAY SERVICE, LLC, ) 

BRAD GATE, BETTER AIRPORTS, LLC and ) 

WILLIAM FOSTER, ) 

Complainants, 

vs. 

WAHOO MUNICIPAL AIRPORT and WAHOO 

AIRPORT AUTHORITY, 

Respondents. 

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FAA Docket No. 16-14-08 

RESPONDENTS WAHOO MUNICIPAL AIRPORT AND WAHOO AIRPORT 

AUTHORITY'S SUPPLEMENTAL ANSWER TO THE COMPLAINT 

COMES NOW Respondents WAHOO MUNICIPAL AIRPORT ("WMA") and WAHOO 

AIRPORT AUTHORITY ("WAA'') (collectively ''Respondents"), by and through their 

attorneys, KAPLAN, MASSAMILLO & ANDREWS, LLC, and for their Supplement to their 

Answer to the Complaint of Complainants WALKER AG SUPPLY, LLC, WALKER 

LUEDTKE, MIDWEST SPRAY SERVICE, LLC, BRAD GATE, BETTER AIRPORTS, LLC 

and WILLIAM FOSTER (collectively "Complainants"), state as follows: 

INTRODUCTION 

On December 18, 2014, Respondents served their Answer to Complainants' Complaint to 

the FAA via FedEx, and to the Complainants via U.S. Mail on December 19, 2014. Pursuant to 

the FAA's December 1, 2014 Order granting Respondents' Motion for an Extension of Time, 

Respondents' Answer was due to be served December 19, 2014. On December 22, 2014,r 

Respondents also realized that two of the Complainants' "Formal Complaint Issues" (52A and a 

duplicate no. 68) had not been specifically referenced in their Answer that was served. (Notably, 

however, a denial and substantive response to the subject matter categories of these specific 

"Formal Complaint Issues" are included in Respondents' Answer.) This oversight was dne in 

part to the fact that these "Forn1al Complaint Issues" had either been unconventionally numbered 

or misnumbered. Respondents now supplement their Answers to Complainants' Complaint with 

their Answers to Complaint Issue 52A and the First Complaint Issue No. 68 on page 463 of 

Complainants' Complaint. (Respondents had already specifically answered the Second 

Complaint Issue No. 68 on page 469 of Complainants' Complaint.) 
SECTION FOUR: RESPONDENTS' ANSWERS TO COMPLAINANTS' COMPLAINT 

ISSUES 

Complainants' have identified I 09 Complaint Issues in their 900-plus page Complaint. 

Respondents address each, and where appropriate reference the Subject Matter Category 

("SMC") that is responsive to allegations in a particular Complaint Issue. 

The following are all of the SMCs listed in Section Three of Respondents' Answer, and 

which are referenced in Respondents' supplemental Answer below: 

SMC 1. 

SMC2. 

SMC3. 

SMC4. 

SMC5. 

SMC6. 

SMC7. 

SMC8. 

SMC9. 

SMC 10. 

SMC!l. 

SMC 12. 

Justification of the WMA's Minimum Standards 

Storm's Alleged Containment Pad Violations at the WMA 

Storm's Alleged Improper Method of Storing Chemicals at the WMA 

Storm Flying Service's Alleged Open Fires at the WMA 

WAA's Reasons for Denying Walker Ag's Application to Operate 

Storm Flying Service's "Ice Dusting" of the Platte River in 2010 

The Number of Airport Operations at the WMA 

The Longer Fuel Hose at the WMA 

Snow Removal at the WMA 

Lease Language and Alleged Lease Violations 

EAA Hangar Issues 

Allegations Regarding theW AA's Compliance with Its Spill Prevention, 

Control and Countermeasure ("SPCC") Plan 

In addition to their General Denial set forth in SECTION TWO of their Answer, Respondents 

answer as follows: 

Complaint Issue No. 52A 

See SMC No. 1. 

First Complaint Issue No. 68 (page 463 of Complainants' Complaint) 

See SMC No. 2. 

WHEREFORE, Respondents WAHOO MUNICIPAL AIRPORT and WAHOO 

AIRPORT AUTHORITY (collectively "Respondents") respectfully request that each and every 

allegation of the Complainants WALKER AG SUPPLY, LLC, WALKER LUEDTKE, 

MIDWEST SPRAY SERVICE, LLC, BRAD GATE, BETTER AIRPORTS, LLC and 

WILLIAM FOSTER be dismissed, and for all other relief the U.S. Federal Aviation Authority 

deems just. 
Walker Luedtke- Sent USPS Mail First Class Delivery 

Walker Ag Supply, LLC 

1682 County Road G 

Wahoo, NE 68066 

Brad Gage- Sent USPS Mail First Class Delivery 

Midwest Spray Service, LLC 

31019 E. 260'11 Avenue 

Bethany, MO 64424 

Larry S. lkaplan, Esq. 

Keith S. Yamaguchi, Esq. 

Susan J. Russell, Esq. 

KAPLAN, MASSAMILLO & ANDREWS, LLC 

200 W. Madison Street, 16th Floor 

Chicago, Illinois 60606 

(312) 335-3000 

Firm !.D. No. 42047 

Attorneys for Respondents Wahoo Municipal 

Airport and Wahoo Airport Authority 

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