CERTIFICATE OF SERVICE 

I hereby certify that on this 151

h day of June 2015, I caused the foregoing Motion For Leave To 

File Reply To Pro-Flight Aviation, Inc.'s Answer To Respondent's Motion For Summary 

Judgment And Proposed Reply and accompanying declarations to be served electronically upon 

the following: 

Federal Aviation Administration Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

Room 921 

800 Independence Ave, S.W. 

Washington, D.C. 20591 

(Telephone 202-267-3473) 

e-mail 9-A W A-AGC-Part-16@faa.gov 

Benjamin H. Klein 

Law Offices of Paul A. Lange, LLC 

80 Ferry Boulevard 

Stratford, CT 06615 

(Telephone 203-375-7724) 

e-mail: bhk@lopal.com 

/2' -:6 .~ ( Zanett L. Fontes, WSBA 9604 

Seni Assistant City Attorney 

c· ofRenton 

City Attorney's Office 

1055 South Grady Way 

Renton, W A 98057 

Phone: ( 425) 430-6486 

Fax: ( 425) 430-6498 

e-mail: zfontes@rentonwa.gov 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

v. Docket No. 16-15-03 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

RESPONDENT'S MOTION FOR LEAVE TO FILE REPLY TO 

PRO-FLIGHT AVIATION, INC.'S ANSWER TO RESPONDENT'S 

MOTION FOR SUMMARY JUDGMENT AND PROPOSED REPLY 

MOTION FOR LEAVE TO FILE REPLY 

Respondent City of Renton Municipal Airport ("Airport") hereby moves for leave to file 

a reply ("Reply") to the Answer ("Answer") filed by Complainant Pro-Flight Aviation, Inc. 

("PF A") to Respondent's Motion for Summary Judgment ("Summary Judgment Motion"). The 

Reply should be permitted to correct significant mischaracterizations of the record. As 

demonstrated below, critical factual assertions in PFA's Answer (some questioning the integrity 

of government officials) are unfounded and incorrect. 

• PF A alleges that the decision to lease the 760 and 770 Parcels to Boeing was a "foregone 

conclusion" even before the issue was presented to the Transportation/ Aviation 

Committee ("Transportation Committee") of the City Council. In short, PF A, for the first 

time and without any concrete evidence, contends that the City Council process was 

"political theater" and impugns the integrity of the Transportation Committee's members. 

As evidenced by the declarations attached to this Motion and Reply as Exhibits A 
through C, each of the Transportation Committee members independently considered the 

facts pertinent to the proposed lease, including the pros and cons of each application, 

before voting on the matter. PF A cites no evidence that supports its weighty charge that 

the approval process was rigged. 

• PF A alleges that the parcel previously occupied by a restaurant ("Old Restaurant Site") 

identified by the Airport as an alternative to the 760 and 770 Parcels that PF A could lease 

to meet its "tie-down" space needs is not viable because it is an unpaved property outside 

the Airport perimeter fence. Yet the reality is that the Airport is in the planning stage of 

converting the Old Restaurant Site to usable space for tie down parking spaces, as 

explained in the declaration of the current Airport Manager, Jonathan Wilson, which is 

attached to this Motion and Reply as Exhibit D. PF A offers a comment of a City 

employee that the property was not cost effective to develop, but even if that statement 

were made as described, it is not sufficient to create a dispute on the current viability of 

the site. 

PFA's Answer also misstates the law on a key issue, namely, whether Boeing is an 

aeronautical user engaged in aeronautical activity at the Airport. More specifically, in its attempt 

to exclude Boeing's activities from the aeronautical use definition, PF A has simply disregarded 

published FAA policy guidance that clearly brings those activities well within the scope of 

aeronautical use. Getting the law correct on this particular legal issue is essential because 

Boeing's alleged non-aeronautical status provides the basis for PFA's claims that the Airport has 

unjustly discriminated against PF A in violation of Grant Assurance 22 by favoring a purportedly 

non-aeronautical user over its own aeronautical use of the Airport. It also plays an important 

2 
role in PFA's Grant Assurance 24 argument that Boeing must be charged the fair market rate 

applicable to non-aeronautical airport users for its leases. 

For the foregoing reasons, Respondent Airport hereby moves for leave to file the Reply 

set forth below. 

REPLY TO MOTION FOR SUMMARY JUDGMENT 

I. The Votes Of Members Of The City Council Transportation Committee To 

Award The 760/770 Lease to Boeing Were Independent Merit-Based Decisions 

In the Complaint, PF A described its communications with the prior Airport Manager 

between 2011 (shortly after PFA leased its current Airport space on the 750 Parcel) and 2013 

(when the adjacent 760 Parcel became available for lease) regarding PFA's desire for additional 

space to conduct its FBO operations at the Airport. Complaint, ,-r,-r 18-25. PF A alleged it was 

misled by this individual regarding the availability of the 760 Parcel, but admits that it 

nevertheless submitted a lease application for both the 760 and 770 Parcels. !d. at ,-r,-r 25-26. 

PF A further explains that its application was rejected by the City Administration, the City 

Council's Transportation Committee, and ultimately by the whole City Council, allegedly in 

violation of the Airport's federal grant assurance obligations. !d. at ,-r,-r 27-29. 

Although PF A was required by the Part 16 rules to provide a complete statement of its 

facts in its Complaint (see 14 C.P.R. §16.23), PFA now adds the additional factual claim in its 

Answer (at pp. 2,8,9) that the outcome with respect to the competing leases was a "foregone 

conclusion" even before the matter was sent to the City Council for a vote, suggesting that the 

City Council hearing and voting process was a meaningless rubber-stamping of a decision that 

had been made and imposed on the Transportation Committee by the City Administration. This 

late-asserted allegation is based principally upon a July 24, 2013 letter that the City 

Administration sent to PF A the day before the Transportation Committee hearing, which advised 

3 
that the "City Administration"-not the City Council-had decided to lease the property to 

Boeing. Answer, p. 7 (referencing Complaint, Ex. 1 0). PF A ignores the distinction between two 

different governmental entities in a tripartite government by equating the "City Administration" 

with the elected City Council; in fact, they are not one and the same. The Administration 

includes individuals hired by the City to manage various city functions. In this case, the 

pertinent administrators include the Airport Manager and the Public Works personnel who 

oversee the operation of the City's transportation facilities, including the Airport. Those 

individuals did indeed decide to recommend lease of the disputed parcels to Boeing, and so 

advised the City Council's Transportation Committee members. The ultimate decision, however, 

rested with the City Council. 

Those acting for the City Administration are separate and apart from the City Council, 

which alone, pursuant to RCW 35A.11.020, has the legal authority to grant or deny Airport lease 

applications. As set forth in the attached declarations from each of the members of the City 

Council's Transportation Committee, these three elected officials attended the Committee 

meeting on July 25, 2013, where the competing applications for the lease of Airport Parcels 760 

and 770 were contemporaneously considered. Each Councilperson attests to having gone into 

the meeting with an open mind and making an independent decision on which application to 

approve based upon the presentations of both lease applicants as well as the responses to 

questions asked by Council members. Declaration of Marcie Palmer, Renton City Council 

Woman (hereinafter "Palmer")~~ 3 and 7; Declaration of Don Persson, Renton City Councilman 

(hereinafter "Persson") ~~ 6 and 7; Declaration of Greg Taylor, Renton City Councilman 

(hereinafter "Taylor") ~~ 6, 9, and 10. In complaining about this process, PFA makes little 

mention that its representatives appeared at the meeting and argued the merits of its proposed 

4 
lease of the property to the Council members. The Council members also heard from the then 

Airport Manager regarding the two competing lease applicants. Palmer, at ~ 10. Indeed, as they 

do in all matters, the Council members based their decision upon the information presented to 

them by Airport management and the involved parties. Palmer, at~~ 13 and 14; Persson at~~ 7 

and 9; Taylor, at~ 10, 11, and 12. The fact that the Transportation Committee ultimately chose 

the lease applicant recommended by the Airport Manager does not suffice to create a genuine 

issue on PF A's serious charge that the outcome was predetermined, and PF A has offered no 

other evidence to support that contention. Indeed, the only evidence in the record pertaining to 

the Council members' deliberative process shows that the Transportation Committee members 

found the selection of Boeing to be the logical and best choice considering all the facts and 

circumstances presented to them. 

II. Even Though PFA's Space Shortage Is A Predicament Of Its Own Making, The 

Airport Continues To Make Reasonable Efforts To Accommodate PF A's Desires 

PFA has argued in its Answer (at pp.12, 23-24) that there are no viable locations for 

placement of its aircraft other than the 760 and 770 Parcels. That is not true, and the Airport's 

current efforts to develop the Old Restaurant Site described below highlight the lengths to which 

the Airport has gone to accommodate PF A. 

To begin with, PF A should not be heard to complain about its space problems when they are 

the direct result of PFA's own actions. As explained in the Summary Judgment Motion (at 

pp.10-11), PFA and Renton Gateway Center ("RGC"), a "sister" company that is PFA's landlord 

and in which PFA's owners have a substantial interest, divided the ramp space on the 750 Parcel 

in a way that left PF A almost immediately with inadequate space for its aircraft. Specifically, 

RGC/PFA decided to lease limited ramp space to the King County Sheriffs Department, to the 

media aircraft operators, and to other aircraft owners, a decision that left PF A with insufficient 

5 
space from the outset of its sublease in 2011. Thus, PFA could solve its problems through a 

reallocation of ramp space on the 750 Parcel. 

As also explained in the Summary Judgment Motion (at pp.3, 11, 15), the Airport offered 

PF A the 820 Parcel back in 2011 as soon as the space problems were mentioned, but that Parcel 

was rejected by PF A. In fact, PFA continues to reject the space in 2015 even as it complains 

about the potential lease of that space to Boeing. !d. at p.15. 

As also mentioned in the Summary Judgment Motion, the Airport has previously 

suggested the Old Restaurant Site as another parcel that might be able to accommodate PF A's 

aircraft, but PF A contends that this property would not truly solve its space problems. !d. at 

pp.3, 14-15. Although PFA correctly notes in its Answer that the Old Restaurant Site is not 

currently configured for PFA's needs, the Airport has begun the process of developing the site to 

accommodate tie-down aircraft parking spots for both Renton-based and transient aircraft. 

Specifically, as explained in the Wilson declaration (at ~~ 5-7), the Airport has requested a 

design and cost analysis for that property, which will provide the basis for a complete design, 

solicitation of bids, obtaining of permits, and construction. Finally, the Airport has also 

identified 9 tie-down spaces dedicated to month-to-month leases on the east side of the Airport 

which may become available for PFA's use. See Wilson,~ 8. 

In sum, cognizant of its obligations as an airport operator, the Airport has taken 

reasonable steps to help PF A find additional aircraft parking spaces even though PF A's space 

crunch was and continues to be a product of its own making. Having originally entered a lease 

for inadequate space and rejected the Airport's prior offers of other space to accommodate its 

aircraft, PF A should not now be heard to complain at this late date of the Airport's recent 

decision to lease space to Boeing, another long-standing Airport tenant. 

6 
III. Boeing Is An Aeronautical User Engaged In Aeronautical Activity At The Airport 

PF A has strenuously argued throughout its Answer that Boeing is a "non-aeronautical 

user" of the Airport. To reach this conclusion, PF A argues that Boeing is not engaged in 

aeronautical activity because aircraft manufacturing overall is not aeronautical in nature 

(Answer, pp.16-17). What is at issue here is not the FAA's categorization of the overall aircraft 

manufacturing process, but rather a subset of aircraft assembly-related activities that will take 

place on the newly-leased 760 and 770 Parcels. These activities include, (i) the temporary 

storage of aircraft pending certification and sale, (ii) aircraft maintenance, (iii) reengineering and 

modification of the aircraft to the extent required based upon flight and other test results, (iv) the 

initiation of the aircraft flight tests from the Airport, and (v) the operation of aircraft under Part 

91 at the time of delivery to the airline customer or other purchasers. All of these activities have 

been described by the FAA as aeronautical. Order 5190.6B, Appendix Z, Definitions and 

Acronyms; FAA Advisory Circular 150/590-6, Exclusive Rights at Federally Obligated Airports, 

App. 1, § 1.1(a). 

Further, as the Airport explained in its Summary Judgment Motion (at pp.18-19), the 

FAA last year clarified its position on aeronautical use, stating unequivocally that even "the final 

assembly of an aircraft, leading to the completion of the aircraft to a point where it can be 

taxied", is aeronautical use. See "Policy on the Non-aeronautical Use of Airport Hangars", 79 

Fed. Reg. 42483, 42485 (July 22, 2014) ("2014 Policy Statement"). PFA attempts to limit the 

FAA's 2014 Policy Statement to only homebuilt aircraft (Answer, pp. 19-20), but the FAA 

policy does not contain any such limitation. To the contrary, the FAA expressly states in its 

2014 Policy Statement that "the same principles apply generally to large aircraft manufacturing" 

and expressly identifies as aeronautical activities two distinct classes of activities related to the 

7 
final assembly of aircraft-"the manufacturing" and the "homebuilt construction process"-with 

the following language: 

5. Final, active assembly of an aircraft in the manufacturing or homebuilt 

construction process, resulting in a completed, operational aircraft requiring 

access to the airfield, is considered an aeronautical activity for the purposes of this 

policy. 

79 Fed. Reg. at 42485 (emphasis added). In short, the FAA recognized that the final steps in 

preparing aircraft for flight, whether they are commercial aircraft or homebuilt aircraft, are 

aeronautical activities for the purposes of interpreting and carrying out the Grant Assurances. 

This FAA clarification clearly establishes that Boeing is engaged in "aeronautical activity" when 

it performs the final assembly and modification of the 73 7 MAX aircraft temporarily located on 

the 760 and 770 Parcels. In demanding (Answer, p.l6) that the FAA "affirm a definition of 

aeronautical use that excludes activities that are related, directly or indirectly, to the commercial 

manufacture of aircraft," PF A is asking the FAA in this proceeding to issue a decision in direct 

conflict with the clarification issued by the Agency in its July 2014 Policy Statement. This is not 

an appropriate venue to effect any such policy change. The policy of the FAA as to the 

completion of commercial aircraft manufacture is clear and should control the decision as a 

matter of law in this Part 16 proceeding. 

Contrary to PFA's argument, recognizing Boeing's use of Parcels 760 and 770 as 

aeronautical will not lead to "effectively convert[ing] a public airport into a private one." 

(Answer, p.16.) As an initial matter, PF A dramatically overstates the impact of the Boeing lease 

on its operations. With some minor parking space reassignment of aircraft, PF A will continue to 

be able to operate as a full-service FBO at the Airport as it has been doing since 1994, serving 

the general aviation community. Moreover, the Renton Airport is uniquely situated insofar as it 

has a final assembly facility of one of the world's leading aircraft manufacturers immediately 

8 
adjacent to the Airport. Consequently, unlike other operators of reliever airports, Renton Airport 

management must endeavor to balance the unique needs of this long-standing manufacturer with 

the needs of other tenants, which it has done for decades when carrying out its leasing program 

that is now being challenged. Renton has been even-handed, above board, and fair in allocating 

limited airport space among its Airport tenants. PF A has not met its burden of proving that the 

Airport has not done so in compliance with the applicable Grant Assurances. Accordingly, 

summary judgment in favor ofthe Airport should be granted and PFA's Complaint dismissed. 

Respectfully submitted 

CITY OF RENTON 

By: etta L. Fontes, WSBA 9604 

Its: enior Assistant City Attorney 

9 
DECLARATION 

OF 

COUNCIL WOMAN, 

MARCIE PALMER 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

Docket No. 16-15-03 

v. 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

DECLARATION OF MARCIE PALMER, 

RENTON CITY COUNCIL WOMAN 

I, Marcie Palmer, hereby declare based upon my personal knowledge, under penalty of 

petjury under the laws of the state of Washington, that the following is true and correct: 

1. Prior to my election to the Renton City Council, I was a member of the Renton 

Airport Advisory Committee (RAAC), having served between May 2001 (the first 

ever RAAC meeting) until I resigned to take my seat on the City Council. I served 

as a chair of the RAAC. 

2. I was elected to the Renton City Council in the fall of2003. I started my term of 

office in January 2004. 

3. I have always been proud of my work on the City Council and its Committees, and 

am committed to fully, fairly and independently considering the matters that come 

to me as a Council member. 

Declaration of Marcie Palmer- l 
4. In my tenure on the Council, I have served on the Transportation Aviation 

Committee ("Committee") for 12 years, chairing the Committee for 10 of those 12 

years. My break in service came as a result of serving as president of the Council. 

5. This Committee does not have the authority to act on behalf of the Council as a 

whole. Rather, it makes a recommendation to the entire City Council about the 

aviation and other transportation-related matters that come before the Committee 

and that require action by the City Council. 

6. I was the Chairperson of the Committee in 2013 when the Committee considered 

the lease of the 760/770 parcels. The competing applicants were Pro Flight 

Aviation ("ProFlight") and The Boeing Company ("Boeing"). 

7. As a council member on the Committee I considered the recommendation made by 

Renton City staff, as well as the substance of the presentations made and answers 

given at the Committee meeting by the applicants and staff. 

8. The Paholkes, who I knew from my participation on the RAAC, presented PFA's 

case at the July 2013 meeting where the Committee considered the leasing of the 

760 and 770 parcels at the Airport. 

9. A Boeing representative made Boeing's case. 

10. The Committee heard from Ryan Zulauf, the Airport Manager at the time, and then 

from both applicants. I will always allow people who take the time to come to a 

Committee meeting the opportunity to make a presentation. That was no different 

in July, 2013, when the Committee considered the competing applications between 

ProFlight and Boeing. 

Declaration of Marcie Palmer - 2 
11. The Paholkes were given an opportunity to address the Committee and did so. The 

Paholkes explained they wanted to use the 760 and 770 parcels primarily for tie 

down space. They were discussing their need for a long-term lease. 

12. The Boeing representative then spoke and advised that Boeing was looking for a 

short-term lease in conjunction with the production of the new 737MAX aircraft. 

13. I appreciated the input the Committee received from the applicants and the 

information they provided. It assisted me in making the difficult decision of serving 

two different applicants who both use the airport. 

14. After the presentations by staff as well as comments from the Paholkes and Boeing, 

I decided that the best interests of the Airport would be served ifthe shorter-termed 

lease was executed at this time, allowing the Airport the greatest amount of 

flexibility in the future. 

15. As there appeared to be other space available for ProFlight to use for the short 

term, leasing the 760 and 770 parcels to Boeing appeared to me to be the best and 

highest use of the parcels. 

16. I voted to recommend to the City Council, as a whole, to approve the lease with 

Boeing. 

17. A Committee report was prepared and signed by all three members of the 

Committee and the recommendation was made to the 7-member city council for 

consideration at the next council meeting. 

18. Any member ofthe public can attend a City Council meeting. Ifthe Paholkes had 

come to the City Council meeting where the Committee's recommendation was 

considered, they would have been allowed to address the council as a whole and 

Declaration of Marcie Palmer - 3 
would have been able to explain why the Committee's recommendation to the 

Council should not be adopted. I do not recall if the Paholkes were in the audience 

at the Council meeting. However, they did not address the Council before its 

consideration of the Committee's recommendation. 

DATED THIS day of June, 2015. 

'lf)OAW__ 

Marcie Palmer, 

~ 

Renton City Councilwoman 

Declaration of Marcie Palmer- 4 
DECLARATION 

OF 

COUNCILMAN, 

DON PERSSON 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

Docket No. 16-15-03 

v. 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

DECLARATION OF DON PERSSON, 

RENTON CITY COUNCILMAN 

I, Don Persson, hereby declare based upon my personal knowledge, under penalty of 

perjury under the laws of the state of Washington, that the following is true and correct: 

1. I have served on the Renton City Council since January 2000. 

2. In my capacity as an elected member of the City Council it is my responsibility to 

exercise my independent judgment. I take this duty very seriously. 

3. I have served on the Transportation Aviation Committee ("Committee"), off and 

on, for thirteen (13) years. Four (4) ofthose years, I served as chair of the 

Committee. 

4. Our deliberative process involves this Committee making a recommendation to the 

entire City Council about the matters that come before the Committee and that 

require action by the City Council. Approval of a lease at the Airport is just such 

an ISSUe. 

Declaration of Don Persson - 1 
Ill 

Ill 

5. I was on the Committee in 2013, when the Committee considered the lease of the 

760/770 parcels. The competing applicants were Pro Flight Aviation ("PFA") 

represented by Mr. and Mrs. Paholke, and The Boeing Company ("Boeing"). 

6. As a member on the Committee I considered the presentations made by a City staff 

member as well as the comments made and answers given by staff and the 

representatives ofPFA and Boeing at the Committee meeting held on July 25, 

2013. 

7. The Committee heard from both applicants, who were provided as much time as 

needed to make their presentations to the Committee explaining their need for and 

intended use of the property. 

8. During the course of the Committee meeting I considered both applications without 

any specific outcome in mind. My interest was in doing what was best for the 

Airport and the City over the long term. I exercised my independent judgment 

throughout the course of this process. Any suggestion that the PF A application was 

not given due consideration is incorrect. 

9. Based on what I heard from all interested parties who spoke, I concluded that the 

City should enter into the proposed lease with Boeing rather than PF A. 

10. In my opinion, it was in the City and Airport's best interest to enter into the 

proposed lease with Boeing. I voiced that opinion at the time. 

Declaration of Don Persson - 2 
11. I signed the Committee report with the recommendation to the full City Council 

that parcels 760 and 770 be leased to Boeing. 

DATED THIS ( {fir day of June, 2~ 

DonPersso~ 71 ~ Renton City Councilman 

Declaration of Don Persson - 3 
DECLARATION 

OF 

COUNCILMAN, 

GREG TAYLOR 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

Docket No. 16-15-03 

v. 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

DECLARATION OF GREG TAYLOR, 

RENTON CITY COUNCILMAN 

I, Greg Taylor, hereby declare based upon my personal knowledge, under penalty of 

perjury under the laws of the state of Washington, that the following is true and correct: 

1. I have served as a Council member for the City of Renton since January of 2008. 

2. When acting as a member of the City Council or its Committees, I fully evaluate 

and consider the various options and information presented on all matters coming 

before the Council. I take my obligation to exercise my independent judgment very 

seriously. 

3. In my time on the City Council, I have served on the Transportation Aviation 

Committee ("Committee") for three (3) years. 

4. Issues considered by this Committee that require a Council action (e.g., leasing at 

the airport) are sent to the Council as a whole by way of a recommendation from 

this Committee. 

Declaration of Greg Taylor- I 
5. I was on the Committee on July 25, 2013, when the lease ofthe 760/770 parcels 

was on the agenda. The two applicants for this property were Pro Flight Aviation 

("Pro-Flight") and the Boeing Company ("Boeing"). 

6. As a member of the Committee I considered the recommendation made by City 

staff members, as well as the presentations made and answers given by staff and the 

applicants' representatives. 

7. Mr. and Mrs. Paholke, Pro-Flight's owners, were present at the July 25,2013 

meeting where the Committee considered the leasing ofthe 760 and 770 parcels. 

8. A Boeing representative also attended the meeting. 

9. The Committee heard from staff, and then from both applicants. 

10. I did not start the Committee meeting favoring any particular outcome, other than 

identifying a lessee for the parcels. In fact, I am always concerned about the needs 

of small business owners, never wanting to stifle their growth opportunities. 

Consequently, I specifically inquired about whether there were alternate locations 

for ProFlight at the Airport, in the event these two parcels were leased to Boeing on 

a short term, and whether any other parcels might be coming available later. 

11. I learned there was at least one other location where Pro-Flight could relocate their 

planes. 

12. It appeared to me that both applicants could be served and that, under the 

circumstances, it was in the Airport's best interest to lease the 760 and 770 parcels 

to Boeing for the proposed term. 

13. Accordingly, I voted to recommend to the City Council, as a whole, to approve the 

lease with Boeing. 

Declaration of Greg Taylor- 2 
14. I signed the Committee report with that recommendation to the City Council. 

hf~ DATED THIS /~ day of June, 2015. 

Renton City Councilman 

Declaration of Greg Taylor- 3 
DECLARATION 

OF 

AIRPORT MANAGER, 

JONATHAN WILSON 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

Docket No. 16-15-03 

v. 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

DECLARATION OF JONATHAN WILSON, 

AIRPORT MANAGER, RENTON MUNICIPAL AIRPORT 

I, Jonathan Wilson, hereby declare based upon my personal knowledge, under penalty 

of perjury under the laws of the state of Washington, that the following is true and correct: 

1. I am the current Airport Manager at the Renton Municipal Airport. Prior to my 

appointment as the Airport Manager in October, 2014, I served as the Airport's 

Assistant Manager for 7 years. 

2. On the North West comer ofthe Airport, there is open space formerly used by a 

restaurant. We refer to this location as the Old Restaurant Site. 

3. Based on our preliminary analysis of the capacity of the Old Restaurant Site, it will 

accommodate approximately 11 single engine or small multiengine type aircraft. 

4. The Airport has started the architectural and engineering process for preparing the 

Old Restaurant Site to bring it within the perimeter fence and to prepare the site to 

accommodate aircraft tie-down parking locations. 

Declaration of Jonathan Wilson- 1 
5. We have already identified a consultant to prepare a 30% design & cost estimate. 

This is a precursor step to putting the project out for bids from contractors. 

6. Once the permitting and design process is complete, the project will be put out for 

bids. The actual construction time is expected to be 6-8 weeks. 

7. The current best estimate is that the Old Restaurant Site development project would 

be completed by July 2016. 

8. In his declaration that is attached to Pro Flight Aviation's Answer to the Airport's 

pending motion for summary judgment , Mr. Paholke claims to have spoken to 

some unnamed individual who manages some tie-down spaces on the East side of 

the Airport. Mr. Paholke did not talk to or inquire of me, the Airport Manager, 

about the Airport's tie-down space on the East side of the Airport. The Airport has 

dedicated 9 tie-down spaces on the East side of the Airport for month to month tie 

down usage. The availability of these spaces can fluctuate from month to month 

and, depending on then current demand, spaces would be available for lease by 

PFA. 

\ t_.... 

DATED THIS ___ day of June, 2015. 

Declaration of Jonathan Wilson- 2 

,.. 

~ 

Jo ~~ athan Wilson, 

Renton Airport Manager