### UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINSTRATION WASHINGTON, D.C.

WALKERAG SUPPLY, LLC, WALKER ) LUEDTKE, MIDWEST SPRAY SERVICE, LLC, ) BRAD GATE, BETTERAIRPORTS, LLC and ) WILLIAM FOSTER, )
Complainants,

vs.

WAHOO MUNICIPAL AIRPORT and WAHOO AIRPORT AUTHORITY,
Respondents. ) ) ) ) ) ) ) ) 

### ) FAA DocketNo. 16-14-08

RESPONDENTS WAHOO MUNICIPALAIRPORT AND WAHOO AIRPORT AUTHORITY'S SUPPLEMENTALANSWERTO 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

OnDecember 18, 2014, Respondents served their Answerto Complainants' Complaintto 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 ofthe 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 thatthese "Forn1al Complaint Issues" had either beenunconventionally 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 onpage 469 ofComplainants' Complaint.)SECTIONFOUR: RESPONDENTS' ANSWERS TO COMPLAINANTS' COMPLAINT ISSUES
Complainants' have identified I09 Complaint Issues intheir 900-plus page Complaint. Respondents address each, and where appropriate reference the SubjectMatter Category ("SMC") thatis responsive to allegations in aparticular Complaint Issue.

Thefollowing are all ofthe SMCs listed in Section Three ofRespondents' Answer, and which are referenced inRespondents' supplemental Answer below:

SMC 1. SMC2. SMC3. SMC4. SMC5. SMC6. SMC7. SMC8. SMC9. SMC 10. SMC!l. SMC 12. Justification ofthe WMA's Minimum Standards Storm's Alleged Containment PadViolations atthe WMA Storm's Alleged Improper Method ofStoring Chemicals atthe WMA Storm Flying Service's Alleged OpenFires at the WMA WAA's Reasons for Denying WalkerAg'sApplicationto Operate Storm Flying Service's "IceDusting" ofthe Platte River in2010 TheNumber ofAirport Operations atthe WMA The LongerFuel Hose at the WMA SnowRemoval at the WMA Lease Language and Alleged Lease Violations EAAHangar Issues Allegations Regarding theW AA's Compliance with Its Spill Prevention, Control and Countermeasure ("SPCC") Plan

In additionto their General Denial setforth in SECTION TWO oftheir Answer, Respondents

answer as follows:
Complaint

### Issue No. 52A

See SMCNo. 1.

FirstComplaint

### IssueNo. 

### 68 (page 463 ofComplainants' 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 reliefthe U.S. Federal Aviation Authority deemsjust.Walker Luedtke- Sent USPS Mail First Class Delivery Walker Ag Supply, LLC 1682 County Road G Wahoo, NE 68066

Brad Gage- SentUSPS 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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