December 1, 2014 

Attention: FAA Part 16 Airport Proceedings Docket 

AGC-610 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Subject: Title 14 Code of Federal Regulations Part 16 Complaint 

Complainant: 

F. Britt Harrington, President 

Hairoun Aviation Services, Inc., DBA Execujet Flight Services 

8200 Lindbergh Bay Drive 

St. Thomas, VI 00802 

214-226-2498 

execujet@att.net 

Name and address of persons subject to this complaint: 

Virgin Islands Port Authority- Carlton Dowe, Executive Director 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

340-77 4-1629 

cdowe@viport.com 

Virgin Islands Port Authority- Don C. Mills, Esq., General Counsel 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

340-774-1629 

dcmills@viport.com 

Virgin Islands Port Authority- Denise M. Mills, CPM, Director of Property Management 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

340-774-1629 

dmills@viport.com 

December 1, 2014 Title 14 Code of Federal Regulations Part 16 Complaint Page 1 of 4 

Hairoun Aviation Services, Inc. Versus Virgin Island Port Authority 
Hairoun Aviation Services, Inc., DBA Execujet Flight Services, (Execujet) is a Fixed Base Operator (FBO) 

located at Cyril E. King Airport (STI} located on St. Thomas, United States Virgin Islands. Execujet is one of 

three FBOs doing business at STI. The two other FBOs are Alliance Aviation and St. Thomas Jet Center. 

Execujet has been a tenant of the Virgin Island Port Authority (VIP A} since October 1, 2002 and has three 

years remaining on its current lease, with an option for five more years. 

Execujet conducts its operation from a modular building on land leased from VIPA. The structure is over 

thirty years old and is in need of substantial repairs. These repairs are currently economically infeasible 

because of the uncertain nature of its VIPA leasehold. Not having an updated facility puts Execujet at a 

competitive disadvantage against the other two FBOs. To further exacerbate the problem, Execujet was 

recently informed that it will no longer have direct access to the Air Operations Area, unlike like the other 

two FBOs. This change will also require Execujet to remove its Americans With Disabilities Act compliant 

ramp that is used to accommodate patients on air ambulance and medical flights. These flights comprise 

a significant portion of Execujet's revenue. 

Execujet has formally applied for a new lease and permission to construct a hangar or other permanent 

long term facility costing in excess of $1 Million on three separate occasions in the last eighteen months: 

(1} On April16, 2013, Execujet submitted an application to construct a hangar and general offices on 

its current leasehold, as enlarged. See attached site plan as indicated by (1). 

(2) On July 18, 2013, Execujet submitted an application to construct a hangar and general offices on 

the site of the STI vehicle maintenance building. See attached site plan as indicated by (2). 

(3) On August 14, 2014, Execujet submitted an application to construct a General Aviation Terminal 

building on the site of the STI vehicle maintenance building, including spaces for the existing 

tenants that might be displaced because of airport expansion. See attached site plan as (3). 

None of these applications have been accepted and there has been virtually no dialog from VIPA 

concerning them. 

On October 14, 2014, VIPA published on its web site a Request For Proposals (RFP) to develop hangars on 

the two sites that Execujet has previously made application to construct a permanent facility. Execujet 

received a copy of RFP from VIP A on October 15, 2014. 

This RFP will negatively impact Execujet in that its leasehold is currently situated on one of the sites being 

redeveloped. The Execujet facility will have to be completely demolished if a hangar is built. The RFP 

designates the hangars as "for general aviation uses" which includes the sale of aviation fuel, aircraft 

maintenance etc. This puts Execujet at a further competitive disadvantage. 

Execujet has a relocation clause in its current lease giving VIP A the authority to relocate Execujet under 

certain circumstances. Whether the redevelopment of these two sites qualifies as one of those 

circumstances is in question. 

December 1, 2014 Title 14 Code of Federal Regulations Part 16 Complaint Page 2 of 4 

Hairoun Aviation Services, Inc. Versus Virgin Island Port Authority 
Regardless, in the event of a relocation, VIPA is required to offer Execujet reasonably comparable 

alternate premises. The only two remaining sites that would offer comparable premises are the two sites 

proposed to be redeveloped in the RFP. 

Execujet has done everything in its power to enhance its facility and the image of STI to no avail. Execujet 

is clearly being discriminated against by VIP A, which appears to prefer that it just go away. This is unfair 

and contrary to Title 14 Code of Federal Regulations Part 16, specifically as it relates to Grant Assurance 

22(h). 

Execujet hereby requests the FAA to investigate this matter and complaint. 

I hereby certify that I have this day served the foregoing Part 16 Complaint on the following persons at 

the following physical addresses and/or email addresses: 

Virgin Islands Port Authority- Carlton Dowe, Executive Director 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

cdowe@viport.com 

Virgin Islands Port Authority- Don C. Mills, Esq., General Counsel 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

dcmills@viport.com 

Virgin Islands Port Authority- Denise M . Mills, CPM, Director of Property Management 

Administrative Building 

8074 Lindberg Bay 

St. Thomas, VI 00802-5922 

dmills@viport.com 

December 1, 2014 Title 14 Code of Federal Regulations Part 16 Complaint Page 3 of 4 

Hairoun Aviation Services, Inc. Versus Virgin Island Port Authority 
(1) On April16, 2013, Execujet submitted an application to construct a hangar and general offices on 

its current leasehold, as enlarged. 

(2) On July 18, 2013, Execujet submitted an application to construct a hangar and general offices on 

t he site of the sn vehicle maintenance building. 

(3) On August 14, 2014, Execujet submitted an application to construct a General Aviation Terminal 

building on the site of the STI vehicle maintenance building, including spaces for the existing 

tenants that might be displaced because of airport expansion. 

December 1, 2014 Tit le 14 Code of Federal Regulations Part 16 Complaint Page 4 of 4 

Hairoun Aviation Services, Inc. Versus Virgin Island Port Authority