VIA UPS 

Office of the Chief Counsel 

Attn: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, D.C. 20591 

Richard J. Durden 

Attorney at Law 

27987 Richmond Hill Road 

Conifer, Colorado 80433 

616/901-6516 

April9, 2016 

Re: Michael Pelzer and Pegasus Parachuting Service vs. The State of Michigan 

Docket No. 16-16-05 

Dear Sir or Madam: 

Enclosed for filing please find an original and three copies of the Complainant's Reply in 

Support of its 14 CFR Part 16 Complaint in the captioned matter. One copy is unbound, as 

requested by the FAA. 

enc. 

cc: Mike Trout, Executive Administrator, Office of Aeronautics, MDOT 

Michael Pelzer 
BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

MICHAEL PELZER and 

PEGASUS PARACHUTING SERVICE 

Complainant, 

vs. 

THE STATE OF MICHIGAN 

Respondent 

) 

) 

) 

) 

) 

) 

) Docket No.: 16-16-05 

) 

) 

) 

) 

COMPLAINANT'S REPLY IN SUPPORT OF ITS 14 CFR PART 16 COMPLAINT 

Please Serve: 

Richard J. Durden 

Richard J. Durden, Attorney at Law 

27987 Richmond Hill Rd. 

Conifer, Co. 80433 

T: 616/901-6516 

avlawyenZil.yahoo.com 

Counsel for Complainant 

Michael G. Trout, Executive Administrator 

Office of Aeronautics 

Michigan Department of Transportation 

2700 Port Lansing Road 

Lansing, Michigan 48906 

T: 517-335-9283 

Executive Administrator of Respondent 

In its unsigned (it does not appear to contain the signature certification required by 14 

CFR Part 16.13(e)) Response and Defenses, the Respondent State of Michigan denies all 

allegations that the irrational, ad hoc and opaque actions of its agent to refuse to reduce 

agreements to writing and to continually change the conditions under which it would lease space 

to Complainant for a commercial skydiving operation were a violation of the grant assurances. 

Respondent takes the position that the reason it did not allow Complainant to begin operations 

was because Complainant kept changing the amount of space that he wished to lease and that the 

eight different price schedules created by Respondent were actually consistent and in keeping 

1 
with its obligation to rent space at a consistent price to commercial tenants. Respondent asserts 

that it did nothing to prohibit skydiving access to the Airport. 

If that were true, why then is Complainant not now operating on the Airport under some 

form of temporary agreement while the terms of the hangar lease are being worked out? There 

was immediate agreement by the parties to the site for the PLA, so there were never operational 

issues with skydiving. Respondent has approved Complainant's insurance. Complainant 

specifically requested a temporary agreement to start operating when things bogged down on the 

Concession and Lease Agreement negotiations (Complaint Exhibit 15). Complainant has always 

been willing to sign the sponsor's Commercial Operating Agreement. 

If Respondent's assertion that it was pricing the space it proposed to lease to Complainant 

in a consistent manner-and was open about its calculations, why did Respondent not reveal 

what its standard per square foot rental price was when it provided the original Concession and 

Lease Agreement? 

As was shown in the Complaint, the issue has been the manner in which the sponsor's 

agent, Mr. Mazur, irrationally dealt with Complainant with regard to the Concession and Lease 

Agreement for the hangar. Respondent introduced eight different pricings thus far as 

Complainant has tried to negotiate a Concession and Lease Agreement. As will be shown below, 

in the course of trying to negotiate a suitable agreement, Complainant made one request to 

change the space being leased and that was only after Romeo Airport Management's owner 

decided to cover up his $8,000 pay to play demand by charging for parking and ramp spacesomething other operators didn't have to pay. At that point, Mr. Pelzer reduced the amount of 

parking space requested. 

2 
I. Factual Background 

As described in the Complaint, Complainant Mike Pelzer approached Romeo Airport 

Management in February 2015 regarding renting the recently vacated half of the community 

hangar for a commercial skydiving business (Complaint pages 3-4). In March, he met with Mr. 

Mazur to go through the plan for the business including the space to be rented, drop zone 

location, plan for structures for classrooms and storage in the hangar and for fuel use. Over the 

subsequent months Complainant made no changes to the size of the space he wished to leasethe half of the community hangar vacated by the Dan's Excavating. Only after Respondent's 

agent, Mr. Mazur, said he was going to require Mr. Pelzer to rent parking and ramp space in 

addition to the hangar space was there ever a change to the space involved-he sought to rent 

less parking area. The following table summarizes the eight prices demanded for Mr. Pelzer's 

proposed operation in a hangar as outlined in the Complaint, the space involved and the various 

prices set by Respondent: 

Price Number Space Requested Price 

1 Original $950/month 

Relevant Pages of 

the Complaint 

3-7 

Relevant 

Exhibits 

1-7 

Subsequent Developments: Mr. Pelzer contacted Mr. Mazur to advise that the overall lease was 

acceptable but there were some terms that needed to be corrected and he had questions on others. 

There was a meeting between Mr. Pelzer, Mr. Mazur and representatives of Respondent at which 

the proposed Parachute Landing Area was approved. A few days later Mr. Ma= said the price 

was going up by $200 because the PLA was on area that was being farmed. 

Price Number Space Requested Price 

2 Original $1, 150/month 

Relevant Pages of 

the Complaint 

7-9 

Relevant 

Exhibits 

I, 8, 9 

Subsequent Developments: Complainant noted that Mr. Ma= had not incorporated the changes 

the two had agreed upon subsequent to Agreement #1; they met again and reached agreement on 

most areas on concern and Mr. Mazur said Complaint could start operating. The next day Mr. 

Mazur said that Complainant's insurance was not adequate and that he must buy a policy to be 

provided by Mr. Mazur's broker. The policy turned out not to exist. Mr. Mazur then left a 

3 
voicemail for Complainant stating that his insurance was adequate but that "the cost of doing 

business" just went up by $8,000. 

Price Number Space Requested Price Relevant Pages of 

the Complaint 

3 Original $8,000 per year 9 

mcrease 

Relevant 

Exhibits 

1,10 

Subsequent Developments: Mr. Pelzer asked for a written description of what the extra $8,000 

per year provided him. He never received an answer. 

Price Number Space Requested Price 

4 Original $1,750/month 

Relevant Pages of 

the Complaint 

9-11 

Relevant 

Exhibits 

I, 11-15 

Subsequent Developments: Mr. Pelzer asked Mr. Mazur why the terms they had agreed upon 

regarding commercial operations, fuel, maintenance, aircraft storage and signage had still not 

been incorporated into the Concession and Lease Agreement. Because of his concern about 

adequate space for parking, Mr. Pelzer asked for additional parking-! 00 feet by 150 feet-on 

July 3, 2015. When informed by Mr. Mazur that $2,000 of the $8,000 "cost of doing business" 

would be for parking, Mr. Pelzer withdrew his request for additional parking. On July 27 Mr. 

Pelzer sent Mr. Mazur an email (Exhibit 24) answering Mr. Mazur's questions about signage and 

parking and ramp area needed-Mr. Pelzer only needed 1/3 ofthe ramp in front ofthe hangar. 

Mr. Pelzer continued to question the additional $8,000 sum and was then told by Mr. Mazur that 

it was to cover the increased cost of insurance. Yet, as was discovered only in the Response and 

Defenses, Mr. Mazur was never told by his broker that his insurance cost was going to go up by 

$8,000 (Respondent's Exhibit K), only that it would go up. Mr. Pelzer asked for a temporary 

agreement so he could begin operations and was denied. Mr. Mazur then changed the pricing 

structure to charge for ramp space and parking. 

Price Number Space Requested Price Relevant Pages of 

the Complaint 

5 Original I $2,920.07/month 11 

Relevant 

Exhibits 

2, 17 

Subsequent Developments: With the radical price increase and sudden charge for parking and 

ramp space (Mr. Mazur sought to charge for use of the entire ramp in front of the hangar while 

Mr. Pelzer's operation only needed 1/3 of it), Mr. Pelzer sought to reduce the parking space that 

he was obligated to pay for. 

Price Number Space Requested 

6 Original, with 

less parking 

space 

Price 

$2,614.43/month 

4 

Relevant Pages of 

the Complaint 

11-12 

Relevant 

Exhibits 

18 
Subsequent Developments: A meeting was scheduled at Romeo Airport with the Executive 

Administrator of the Michigan Office of Aeronautics to negotiate terms and pricing. 

Price Number Space Requested Price 

7 Same as 6 $1,800/month 

Relevant Pages of 

the Complaint 

12, 13 

Relevant 

Exhibits 

20 

Subsequent Developments: The $1,800 per month-including parking-pricing was confirmed 

via email by the Executive Administrator of the Office of Aeronautics-who apparently also 

prepared the Respondent's Response and Defense. Within days of the meeting that generated 

pricing structure number 7, Mr. Mazur reneged on it and came up with number 8. 

Price Number Space Requested Price 

8 Same as 6 $2,480.43 

Relevant Pages of 

the Complaint 

13, 14 

Relevant 

Exhibits 

22 

Subsequent Developments: Mr. Mazur continued to come up with new conditions-including 

architectural drawings and a permitting process for the hangar. 

In its Response, Respondent makes frequent comments that it refers to as explanations 

regarding what it did in dealing with Mr. Mazur and Complainant, yet it does not refer to 

contemporaneous records to support those explanations. Respondent did not address the long 

periods that Mr. Mazur failed to return telephone calls or emails or his irrational behavior of not 

incorporating terms agreed to on such things as fueling and signage in the next Concession and 

Lease Agreement he would send to Mr. Pelzer. 

While pricing is only a part of the malce-it-up-as-you-go-along behavior of Respondent's 

agent, Respondent claims that it had a standard lease rate for commercial space. The behavior of 

Mr. Mazur, as reflected in the table above as well as his pay to play "cost of doing business" 

voicemail demonstrate that Mr. Mazur only seized on it as a justification for his price increase 

after his claim that his insurance would go up by that amount proved untrue. 

A. PLA Fee/Agricultural Land 

5 
The first price increase imposed by Mr. Mazur was following the establishment of the 

PLA. It is approximately 700 feet by 700 feet, totaling some 490,000 square feet or 11.24 acres. 

In its Response, Respondent stated that the fee charged was to offset lost revenue from the 

agricultural activity (Response p. 5). 

Respondent's exhibit J is a copy of two years (2014 and 2015) of Agricultural License 

Agreements for land on the Airport. It shows that Respondent's agent was engaged in the same 

questionable practices against the Agricultural Licensee as against Complainant. The number of 

acres ofland involved is precisely the same for both years. The rate per acre that the Licensee 

must pay Mr. Mazur's company is precisely the same for both years. The first year Mr. Mazur 

did the math correctly, leading to a total sum due to RAM of $9,911 for the use of the farmland 

(Exhibit J, page 1 ). The second year Mr. Mazur's company used what appears to be creative 

math to cause the total sum due RAM to become $12,000 (Exhibit J, page 4). 

Respondent's Exhibit J also shows that Mr. Mazur just picked a number out of the air 

when corning up with the $200 per month price increase for use of the PLA. There are three 

distinct rates per acre applicable to three tracts of land referenced in the License Agreement. The 

Agreement does not make clear on which tract the PLA lies. Nevertheless, applying the highest 

rate per acre in the Agreernent-$65 per acre-the maximum loss to be recouped by RAM for 

the PLA is $730.60 for a year, or $60.89 per month, less than half the fee charged. 

B. Fueling/Signage/Condition of Hangar/Maintenance 

From before the first Concession and Lease Agreement, Mr. Pelzer had ongoing 

discussions with Mr. Mazur about the terms of the Agreement (when Mr. Mazur could be 

reached). As pointed out in the Complaint, Mr. Mazur and Mr. Pelzer reached agreement on 

6 
many of the items that needed to be either added to or changed within the boilerplate of the 

Agreement, notably fueling, signage, condition of the hangar and aircraft maintenance. 

However, when the next Agreement was produced by Mr. Mazur, those agreed upon changes 

were, inexplicably, never made. The only change that ever was incorporated was to allow 

parking of two rather than one airplane in the hangar. 

Respondent did not address its agent's repeated refusal to incorporate agreed-upon terms 

into the Concession and Lease Agreement. 

C. Skydiving Operations 

At page 5 of its Response, Respondent attempts to explain away or justify some of Mr. 

Mazur's practice of being out of touch for extended periods of time as the need for him to 

consult with Respondent about establishing requirements and procedures for skydiving onto the 

Airport. It refers only to its Exhibit H which consists of emails from Mr. Pelzer to Respondent 

asking for help because he can't reach Mr. Mazur and, very quickly, the setting up of a meeting 

at which the PLA was approved. This was completed on May 14,2015, very early in the 

process. Mr. Mazur's long absences and delays did not stop as of that date, as pointed out in the 

Complaint. 

There is no further discussion of operational rules or requirements for skydiving found in 

the written communications between any of the parties. That is either because the FAA regulates 

skydiving as an aeronautical activity in 14 CFR Part 105 and there is a presumption, as with all 

other regulated aeronautical activities, that it will be carried out in a safe fashion in accordance 

with the regulations or, because Mr. Mazur is waiting to use operating procedures as yet another 

new condition to delay the process of establishing a commercial skydiving operation. 

7 
It should also be noted that there has been skydiving operations on to Romeo Airport in 

the past. Mr. Pelzer has jumped onto the Airport as part of Airport open house/airshow events 

and a commercial skydiving operator based on an airport nearby has loaded its customer/jumpers 

at the Airport and occasionally parked its airplanes overnight without a commercial operating 

agreement. 

The approval of the PLA and no expressed concerns about operational matters mean that 

there was no rational reason for Mr. Mazur to not approve a plan for temporary operations tmtil 

the hangar lease was signed. 

D. Insurance/Pay to Play/Parking and Ramp Fees 

Even though the process of establishing a commercial skydiving operation had begun in 

February and the PLA was agreed upon in May, Mr. Mazur kept coming up with new conditions 

to delay or deny skydiving. In June, he suddenly decided that insurance was a concern, that the 

policy Mr. Pelzer had provided-the standard coverage available for commercial skydiving 

operators-wasn't satisfactory and sent Mr. Pelzer on a wild goose chase for coverage that was 

estimated to cost as much as $200,000 a year and ultimately turned out not to exist. [Complaint 

at pages 8 and 9] 

Following the June 24th meeting with Respondent [Complaint at page 9], Mr. Maznr was 

satisfied that Mr. Pelzer's coverage was satisfactory and he left the pay to play "cost of doing 

business" voicemail for Mr. Pelzer and increased the price Mr. Pelzer would have to pay to play 

on the Airport by $8,000. As pointed out in the Complaint, Mr. Mazur has made several afterthe-fact attempts to justify the extra $8,000. Mr. Pelzer's request for a written description as to 

what the extra $8,000 provided him (Exhibit 1 0) was never answered by Mr. Mazur or 

8 
Respondent. The first justification, on July 7, was that $2,000 was for automobile parking-the 

first time paying for parking was ever demanded (Exhibit I, page 4)-and the remaining $6,000 

was for an insurance price increase that "may" happen next year. 

Respondent's Response is silent on Mr. Mazur's $8,000 pay to play demand. On page 6 

of its response it makes reference to Exhibit K in which an insurance broker predicts a rate 

increase if skydiving is allowed on the Airport and states that it must maintain a fee and rental 

structure that doesn't subsidize an additional insurance expense. While Respondent must 

comply with Grant Assurance 24, there was no number specified for an insurance rate increase 

by the insurance broker and it can't rationally raise rental prices without knowing if the 

insurance rate is truly going to increase and by how much. 

Mr. Mazur's second attempt to justify the $8,000 "cost of doing business" came on July 

15 (Exhibit 15, page 5) when he said that an insurance price increase was imminent-yet the 

documents produced by Respondent do not support an imminent price increase of $8,000, or any 

specific amount at all--only a prediction that some increase will occur. 

The third, and current, method used by Mr. Mazur and Respondent to justizy the $8,000 

"cost of doing business" and subsequent price increase came in late July-five months after Mr. 

Mazur knew the space Mr. Pelzer wished to lease-when Mr. Mazur came up with the idea of 

charging for parking and ramp space. It neatly swallowed the $8,000 price increase, and then 

some-and lead to Mr. Pelzer requesting less parking space. 

In its Response, Respondent ignores the fact that the idea of charging for parking and 

ramp space only came into being after Mr. Mazur had left his "cost of doing business" voicemail 

and increased the price $8,000 and spends most of its Response in a discussion of per square foot 

9 
pricing and comparing those prices with other commercial and noncommercial operators on the 

Airport. 

Respondent ignores that the other operators are not seeking to use a hangar that is in such 

bad shape that it is scheduled for demolition, its ramp has not been maintained, has numerous 

potholes and a drain that sticks above the surface so that a section floods and Mr. Pelzer will 

have to install temporary structures and portable toilets to make the hangar useable. At page 4 of 

its Response, Respondent said the Community Hangar is "stable but in need of cosmetic repairs." 

It went on to say that "All man-doors are being replaced with aluminum doors. Installation is 

scheduled to be completed by AprilS, 2016." At 6:30pm EDT on April 8, 2016 Mr. Pelzer 

visited the Community Hangar-no work had started on replacing the man-doors. 

Respondent's Response refers to one commercial operator in the new terminal building 

and far better hangars (Response page 7)-it would be ludicrous to apply even remotely 

comparable square footage rates for the spaces involved. 

Respondent provided the Agreements for the two commercial operators it referenced in 

its Response (Exhibits M and N). What Respondent didn't point out is that the Agreements 

show that those two commercial operators do not pay for parking or ramp space. Each only has 

to pay for office and hangar space. 

At page 8 of its Response, Respondent states that the Airport's Minimum Standards 

(Exhibit B) require that a commercial operator pay for parking, staging and ramp space. That is 

not correct, there is no such requirement. The language of the section referenced by Respondent 

reads: "The Operator shall construct a building or lease a portion of a building to provide 

suitable facilities for office space, flight planning, aircraft parking, and auto parking for 

customers and employees." 

10 
It only speaks to leasing a portion of a building, not any of the land around it. 

Accordingly Respondent does not charge the operators identified in Exhibits M and N for the 

land around the portions of the buildings they lease. Exhibit M also provides evidence contrary 

to the Respondent's statement on pages 4 and 5 of the Response that commercial operating 

agreements are required to be signed before operations commence. Respondent did not apply 

that requirement to Victory Aviation. It was operating without a signed commercial operating 

agreement (Exhibit Mat page 24). 

On page l 0 of the Response, Respondent attempts to justify Mr. Mazur reneging on the 

pricing structure established by the author of the Response brief. Respondent states that Mr. 

Mazur made the change to comply with grant assurances, however, Mr. Mazur gave no such 

explanation at the time. To believe the justification requires that one believe that the Executive 

Administrator of the Michigan Office of Aeronautics did not know the requirements of the grant 

assurances applicable to an airport his department owns. 

E. Permits 

As pointed out in the Complaint, Respondent or Mr. Mazur constructed a new terminal 

building on the Airport without going through a permitting process. Respondent apparently 

denied doing so but has not provided a copy of any permit, and to Complainant's knowledge, 

none was ever displayed on the building. As shown in Exhibit 2, the new executive hangar 

constructed on the Airport did not have to go through a permitting process. The addition of a 

permitting requirement months into Lease negotiations-when it knew that none existed, and 

then attempting to force a local govermnent to create one-is just additional evidence of the 

irrational operation run by Mr. Mazur on behalf of Respondent. 

11 
Respondent announced in its response that it has taken until now to come up with a 

permitting process that can be followed and is apparently trying to have it apply retroactively to a 

building that has been completed, the new executive hangar, all as part of trying to justifY 

imposing the requirement on Complainant months after lease negotiations began. Complainant 

notes that he has no objections to going through a permitting process, but points out that the 

manner in which the requirement was added at the last minute and the way the permitting 

process has evolved and who will do it is a further example of the irrational behavior of 

Respondent and its agent throughout. 

Complainant also notes that Respondent and its agent are consistent in doing nothing but 

delaying in dealing with their responsibilities as an airport sponsor as noted in the three years it 

took to negotiate a simple land lease described in Exhibit 2 and complete failure to remedy the 

problem that has caused night instrument approaches to the Airport to be prohibited as of 

September 2014. 

II. Law and Argument 

As pointed out in the Complaint and generally denied by Respondent, an airport sponsor 

is not relieved of its grant assurance obligations when it contracts with a management company 

to run its airport. Here, the head of the management company irrationally continued to impose 

additional conditions on Complainant that had the effect of denying him skydiving access. 

Further, Mr. Mazur imposed a pay to play arrangement, which he tried to cover up through 

various justifications-that Respondent joined and became party to in its Response. 

Respondent asserts that it has done nothing to prohibit skydiving access at the Airport, 

the only problem has been that Complainant kept changing the amount of space he wanted to 

12 
lease. That a sponsor claims it wants to allow an aeronautical activity on an airport is not the 

measure as to whether it is actually willing to do so, as set out in the cases cited in the 

Complaint, and for which Respondent provided no countervailing authority. What matters, is the 

actions of the sponsor and whether those actions have the effect of delay and thus denial. 

Here, the sponsor continually and without warning, changed the conditions for a hangar 

lease, refused to authorize temporary operations, repeatedly changed the pricing for the space in 

an old, nearly worn-out hangar, imposed an $8,000 pay to play fee and then tried to cover it up 

by charging for parking and ramp space even though the documents provided showed it didn't do 

so for other commercial operators. The actions of the Respondent and its agent have had the 

effect of denying skydiving access in violation of Grant Assurances 5, 22 and 23. 

III. Conclusion 

For the reasons set out above and in the Complaint, Complainant respectfully requests the 

FAA enter an order providing the relief desired in the Complaint. 

Dated: April9, 2016 By: 

13 

Respectfully submitted, 

Richard J. Durden, Attorney at Law 

Attorney for Complainant 

,--·""/""? 

Conifer, Colorado 80433 

(616) 901-65156 

avlawyer@yahoo.com 
Subject: Re: Romeo Airport 

From: 

To: 

Cc: 

Bee: 

Date: 

Hi Steve, 

Mike Pelzer (mikeyp@prodigy.net) 

mbdevelopment@comcast. net; 

zapataj@michigan.gov; 

mikeyp@prodigy.net; jlamonaca@avlaw.us; 

Tuesday, July 14, 2015 7:42PM 

Page 1 of3 

Here is my plan for signs.... (see attachment) All of them with the exception of the ones on the building will be temporary 

and taken down when we are not in operation. The ones on !he building will just have logo, phone number and internet 

address and will be smaller than 14' x 6' feet unless you have some sort of restriction. The signs on the North side, East 

end of the hangar will be on poles or sawhorse type barricades and say NO PARKING BEYOND THIS POINT. Estimated 

size is 3' x2' foot. Other signs will designate the landing area and say NO SPECTATORS BEYOND THIS POINT 

approximately 2' x 1' foot. I will probably set at least 5 or 6 across the East end. They will either be on poles that we 

remove when we're not in operation or sawhorse type barricades. I will also use the same signs and barricades on the 

ramp to keep people that aren1 jumping away from the aircraft. I will also have one sign sending people towards the 

parking area. (blue square) 

I am still waiting for responses to my email from 719 and I am also interested in a "self-fueling agreement" unless we can 

come up with something that works for both of us. 

Thank you! 

Mike Pelzer 

From: "mbdevelopment@comcast.net" <mbdevelopment@comcaat.net> 

To: Mike Pelzer <mikeyp@prodigy.net> 

Cc: "Zapata, Juan" <zapataj@michigan.gov> 

Sent: Tuesday, July 7, 2015 9:10PM 

Subject: Re: Romeo Airport 

Mr. Mike Pelzer, 

In regards to your comments and requests in the Commercial Operation Agreement: 

The commencement date for both License and Commercial Agreement shall be described in 

Exhibit "D" (Commencement Date Confirmation) of Concession and License Agreement 

since they both shall be signed simultaneously. In addition, this simplifies the 

commencement date, makes it consistent with all other past agreements and we do not 

know when this actually will get signed. You stated 11-9-2020, why this date? 

M2 - This shall not be deleted since this refers to adequate aircraft parking and that you 

have secured enough land and both aircraft and automobile parking. Exhibit "F" will be 

~, "Airport land for Parachute Landing and Parking Areas" 

https://us-mg5.mail.yahoo.cornlneollaunch?.partner==sbc&.rand=l5uh7cdrrk48d 11/15/2015 


CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing 14 CFR Part 16 Complaint on 

the following person at the following address by UPS second-day delivery: 

Mike Trout 

Executive Administrator, Office of Aeronautics 

Michigan Department of Transportation 

2700 Port Lansing Road 

Lansing, Michigan 48906-2160 

Dated this 9th day of April, 2016