U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS RECE\VED 

WASHINGTON, D.C. 

In the Matter of Renaissance Jet, Inc. 

Docket No. F AA-20 13-1078, Case No. 2012EA390030 

Judge Sullivan 

OEC 1 8 2014 

HEARING DOCKET 

AGENCY'S RESPONSE TO MOTION TO DISMISS ON GROUNDS OF MOOTNESS 

COMES NOW the Agency, by and through his designated representative, the 

Regional Counsel for the Eastern Region and his duly designated agents, and responds to 

the motion of Renaissance Jet, Inc., to dismiss on grounds of motion, as follows: 

(I) The name of the Respondent in this case is Renaissance Jet, Inc. 

(2) The motion to dismiss is based on the claim that Renaissance Jet, Inc., dissolved 

as a corporation on March 23, 2009 when it was converted to another business 

entity, Renaissance Jet, Inc., which in tum was dissolved as a corporation on 

November 19, 2014. It is claimed that "Renaissance Jet, LLC, does not possess 

an Air Taxi Certificate and no longer operates aFAR 135 charter business" and 

that the "air carrier and the corporate entity have ceased to exist." 

(3) In fact, in its Answer to the Complaint dated March 4, 2014 (which has not been 

amended), it is admitted that "Renaissance Jet, Inc., is the holder of Air Carrier 

certificate No. 3RJA276M. 

(4) In fact, the operations specifications for Renaissance Jet, Inc., dated May 9, 203, 

reflect that Renaissance Jet, Inc., is the holder of air carrier certificate number 

3RJA276M and that its primary business address is 1560 North Main Street, 

Suite 103, High Point, NC 27262. See ExhibitA-1 

(5) In fact, on November 12,2014, the FAA approved the change in name for air 

carrier certificate number 3RJA276M from Renaissance jet, Inc., to X8 

Aviation, LLC. Se Exhibit A-2 
( 6) As a result of this name change, an air carrier certificate and operations 

specifications were issued to X8 Aviation, LLC, with authorization to operate in 

air carrier operations in the same manner as did the company when it was 

named Renaissance Jet, LLC. The primary business address ofX8 Aviation, 

LLC is listed as 1560 North main Street, Suite 103, High Point, NC (the same 

address as that of its predecessor in name, Renaissance Jet, Inc.) See Exhibits 

A-2, A-3, and A-4 

(7) X8 Aviation, LLC, is still an active corporation, with the same primary business 

address as its predecessor in name, Renaissance Jet, Inc. See Exhibit 5 

(8) Thus, the only change in the status of Renaissance Jet, Inc., is its name. Its 

successor in name, X8 Aviation, LLC, is still an active corporation and still has 

an air carrier certificate and operations specifications with authority to act as an . . 

mr earner. 

(9) A change in name only does not affect the legal ability of the company to 

conduct air carrier operations and the enforcement action should not be affected. 

M & R Helicopters, LLC, FAA Order No. 2013-4 (September 5, 2013). 

(1 0) Thus, the case is not moot and should not be dismissed. 

WHEREFORE the Agency requests that the motion to dismiss be denied in its entirety. 

Respectfully submitted, 

Alfred R. Jolmson, Jr. 

Regional Counsel 

By: 

Attorney 

Dated: December 9, 2014 
EXHIBIT A-1 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

AOO 1 . Issuance and Applicability HQ Control: 05/09/2003 

HQ Revision: 02c 

a. These operations specifications are issued to RENAISSANCE JET INC, whose principal base 

of operation is located at: 

Primary Business Address: 

Renaissance Jet, Inc. 

1560 North Main Street, Suite 103 

High Point, North Carolina 27262 

Mailing Address: 

Renaissance Jet, Inc. 

3611 Concord Mills Blvd, PMB 277 

Concord, North Carolina 28027 

The holder of these operations specifications is the holder of Certificate Number 3RJA276M and 

shall hereafter be referred to as the certificate holder. The certificate holder is authorized to 

conduct: 

On operations 

Demand in 

Common carriage pursuant to 119.21(a)(5)-

Title 14 Code of Federal ON 

Regulations (CFR) DEMAND 

Section 

and provided, at all times, the 

certificate holder has appropriate 

written economic authority issued by 

the Department of Transportation. 

The certificate holder shall conduct these kinds of operations in accordance with the specific 

authorizations, limitations, and procedures in these operations specifications and all appropriate Parts 

of the CFR. 

b. These operations specifications are effective as of the "Date Approval is effective" listed in 

each paragraph and shall remain in effect as long as the certificate holder continues to meet the 

requirements of Part 119 as specified for certification. 

c. The certificate holder is authorized to use only the business name which appears on the 

cer1ificate to conduct the operations described in subparagraph a. 

d. The cer1ificate holder is authorized to conduct flights under 14 CFR Part 91 for crewmember 

training, maintenance tests, ferrying, re-positioning, and the carriage of company officials using the 

applicable authorizations in these operations specifications, without obtaining a Letter of 

Authorization, provided the flights are not conducted for compensation or hire and no charge of any 

kind is made for the conduct of the flights. 

RENAISSANCE JET INC AOOl-1 

Arndt. No: 5 

Certificate No.: 3RJA276M 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

I. Issued by the Federal Aviation Administration. 

2. These Operations Specifications are approved by direction of the Administrator. 

Digitally signed by Royden W Henry, Principal Operations Inspector (EA39) 

[1] EFFECTIVE DATE: 3/6/2013, [2] AMENDMENT#: 5 

DATE: 2013.03.08 06:57:58-06:00 

3. I hereby accept and receive the Operations Specifications in this paragraph. 

Digitally signed by Robert R Viall 

DATE: 2013.03.06 08:49:43 -06:00 

RENAISSANCE JET INC AOOI-2 

Arndt. No: 5 

Certificate No.: 3RJA276M 
EXHIBIT A-2 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

November 12,2014 

Mr. Mark Palmer, Director of Operations 

X8 Aviation, LLC (3RJA276M) 

15105-D John J. Delaney Dr. PMB 302 

Charlotte, NC 28277 

Dear Mr. Palmer: 

RE: (X8 Aviation) 

Greensboro Flight Standards District Office, EA39 

1301 South Terminal Service Road 

Greensboro, NC 27409 

P: 336-369-3900 

F: 336-369-3980 

This letter documents the change in name for Air Carrier Certificate number; 3RJA276M, 

from Renaissance Jet, Inc. to X8 Aviation, LLC. Included with this letter is the amended Air 

Carrier Certificate for X8 Aviation, LLC with a new effectivity date of 11/12/2014. 

All of the Operations Specifications have been reissued in WebOPPS to account for the 

name change. The Ops Specs should be printed and inserted into the affected manuals as 

applicable. 

The change of names affected the General Operations Manual (GOM), Training Manuals, 

Approved Aircraft Inspection Programs (AAIP). Minimum Equipment Lists (MEL) and 

their associated procedures manuals. Copies of the List of Effective Pages from each of 

these manuals have been stamped and signed with FAA approval or acceptance and are 

included with this letter to be inserted into the affected manuals maintained by X8 Aviation, 

LLC. 

Should you have any questions or concerns do not hesitate to contact me at (336)369-3968. 

Sincerely, 

John Combrinck-Graham 

Principal Maintenance Inspector 

Enclosures 
EXHIBIT A-3 
US Department 

ofT ransportation 

Federal Aviation 

Administration 

Air Carrier Certificate 

This certifies that 

X8 Aviation, LLC 

1560 North Main Street, Suite 103 

High Point, North Carolina, 27262 

has met the requirements of the Federal Aviation Act of 1958, as amended, and the rules, 

regulations, and standards prescribed thereunder for the issuance of this certificate and is 

hereby authorized to operate as an air carrier and conduct common carriage operations in 

accordance with said Act and the rules, regulations, and standards prescribed thereunder 

and the terms, conditions, and limitations contained in the approved operations specifications. 

This certificate is not transferable and, unless sooner surrendered, suspended, or revoked, 

shall continue in effect indefinitely. 

By Direction of the Administrator 

Certificate number: 3RJA276M James S . Verre 

(Signature) 

Effective Date: 11/12/2014 Manager 

(Title) 

Issued at: ----"G'=r"'e""e~ns'>'b,_o_.rc"o:.o_, _,N"'C..__ GSO FSDO EA-39 

(Region/Office) 

FAA Form 8430-18 (6-87) Electronic Forms (PDF) 
EXHIBIT A-4 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

AOO 1 . Issuance and Applicability HQ Control: 05/09/2003 

HQ Revision: 02c 

a. These operations specifications arc issued to XS Aviation, LLC, whose principal base of 

operation is located at: 

Primary Business Address: 

XS Aviation, LLC. 

1560 North Main Street, Suite 103 

High Point, North Carolina 27262 

Mailing Address: 

XS Aviation, LLC. 

15105-D John J. Delaney Drive, PMB 302 

Charlotte, North Carolina 28277 

The holder of these operations specifications is the holder of Air Carrier Certificate Number 

3RJA276M and shall hereafter be referred to as the certificate holder. The certificate holder is 

authorized to conduct: 

On operations 

Demand in 

Common carriage pursuant to 

Title 14 Code of Federal 

Regulations (CFR) 

Section 

119.2l(a)(5) and provided, at ali times, the certificate 

- On- holder has appropriate written economic 

Demand authority issued by the Department of 

Transportation. 

The certificate holder shall conduct these kinds of operations in accordance with the specific 

authorizations, limitations, and procedures in these operations specifications and all appropriate Parts 

of the CFR. 

b. These operations specifications are effective as of the "Date Approval is effective" listed in 

each paragraph and shall remain in effect as long as the certificate holder continues to meet the 

requirements of Part 119 as specified for certification. 

c. The certificate holder is authorized to use only the business name which appears on the 

certificate to conduct the operations described in subparagraph a. 

d. The certificate holder is authorized to conduct flights under 14 CFR Part 91 for crewmember 

training, maintenance tests, ferrying, re-positioning, and the carriage of company officials using the 

applicable authorizations in these operations specifications, without obtaining a Letter of 

Authorization, provided the flights are not conducted for compensation or hire and no charge of any 

kind is made for the conduct of the flights. 

X8 Aviation, LLC AOOl-1 

Amdt. No: 7 

Certificate No.: 3RJA276M 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

I. Issued by the Federal Aviation Administration. 

2. These Operations Specifications are approved by direction of the Administrator. 

Digitally signed by Clinton Festa, Principal Operations Inspector (EA39) 

[1] EFFECTIVE DATE: 11/12/2014, [2] AMENDMENT#: 7 

DATE: 2014.11.12 13:12:11-06:00 

3. I hereby accept and receive the Operations Specifications in this paragraph. 

Digitally signed by Mark L Palmer 

DATE: 2014.11.08 15:59:05-06:00 

XS Aviation, LLC A001-2 

Arndt. No: 7 

Cettificate No.: 3RJA276M 
EXHIBIT A-5 
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Business Registration I N01ih Carolina (Home State) 

North Carolina Secretary of State 

Business Details 

Business Name: X8 Aviation, LLC 

Corporation Type: Limited Liability Company 

Citizenship: Domestic 

State of Incorporation: NC 

Secretary of State JD: 1216125 

Status: Current-Active 

Fom1ed: 08/08/2011 

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High Point, NC, 27262 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing AGENCY'S RESPONSE TO MOTION TO DISMISS ON 

GROUNDS OF MOOTNESS has been sent on this date via FAX and first class mail to: 

John Adams Hodge, Esq. 

136 Stonemark Lane 

Columbia, SC 29210 

FAX: 803-783-9210 

Judge J.E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (EI 1-3 I 0) 

Washington, DC 20590 

FAX: 202-366-7536 

I hereby certify that the foregoing AGENCY'S RESPONSE TO MOTION TO DISMISS ON 

GROUNDS OF MOOTNESS has been sent on this date via first class mail to: 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

Date: DEC 1 0 2014 ~J ~J~~ I/ a Hooks 

Paralegal Specialist 

Federal Aviation Administration 

Office of Regional Counsel 

I Aviation Plaza 

Jamaica, NY 11434