In the Matter of: 

u.s DEPARTMENT OF TRANSPORTATION REcEIvED 

FEDERAL AVIATION ADMINISTRATION 

JUN 0 3 2014 

HEARING DOCKET 

Joseph R. Maridon, Sr. FAA DOCKET 

Respondent FAA CASE NO. 2012WP190142 

(Civil Penalty Action) 

Administrative Law Judge Richard C. Goodwin 

MOTION TO DISMISS 

The Respondent files his Motion To Dismiss for failure of the allegations in the notice of 

proposed action and complaint to state a violation of the FAA Act or of this chapter 14 of the 

Code of Federal Regulations, pursuant to the Rules of Practice (14 C.F.R 13.49) This Motion is 

made and based upon the affidavit attached hereto, argument of counsel and all of the pleadings 

and papers on file herein. Respondent states as follows: 

I. Factual Background 

The complaint alleges that on or about September 29, 2012 Respondent parked his vehicle on an 

active taxiway and thereby prevented a Vision Airlines aircraft from taxiing for takeoff. It further 

alleges t.'le vehicle would interfere with the taxiing of the aircraft and thereby interfered with the 

flight crewrnembers' performance of their duties aboard the aircraft. It does not allege essential 

allegations of an entry, touching, or any contact whatsoever with the aircraft. Furthermore, it 

does not allege a safety violation. 

II. Argument 

The complaint is insufficient on its face because of an erroneous interpretation of the 

FAA's authority. The FAA lacks jurisdiction to proceed under the facts alleged. Jurisdiction lies 

with the airport operator as FAA regulations do not preempt the airport operator's jurisdiction 

over vehicles on t.'le ground on an airport. The FAA should be estopped from proceeding on the 

facts and circumstances of this case. 

The FAA bases its overly broad use ofl4 C.F .R. §91.11 in this case on an interpretation 

published in 76 FR 76611, 76612 (Dec. 8, 2011) dealing with Interference With a Crewrnember 

via Laser. That publication is limited to whether an individual on the ground can interfere with a 

Crewrnember with a laser. 
"Aboard" as used in 14 CFR §91.11 and as interpreted by the complainant in this case is 

not legally sustainable. 14 CFR §91.11 states, "No person may assault, threaten, intimidate, or 

interfere with a crewmember in the performance of the crewmember's duties aboard an aircraft 

being operated." The interpretation sought by the FAA in this case is ambiguous at best. Aboard 

is defined as "onboard a ship, train, aircraft, or other passenger vehicle". American Heritage 

Dictionary of the English Language (4th Ed.) The issue is who must be onboard for the 

interference to be committed. The CFR 's define when someone is a crewmember. 

''Crewmember means a person assigned to perform duty in an aircraft during flight time." 

"Flight crew member means a pilot, flight engineer, or flight navigator assigned to duty in an 

aircraft during flig..~t time." (14 CFR § 1.1 - General definition.s.) (Emphasis added) (i~"-licensed 

pilot in a passenger seat on an aircraft is not an aircrew unless assigned duties related to that 

flight.) Thus, it is illogical surplusage if "aboard" refers to the aircrew. 

As written, 14 C.F .R. §91.11 can refer to both the aircrew and the individual who is 

alleged to be interfering with them. However, to be a crewmember, the aircrew would normally 

already be on the aircraft. To be an aircrew they logically must be onboard the aircraft. They 

have no special status unless they are on the aircraft and have some duty related to the flight 

Consequently, and logically "aboard" must refer to the individual who is alleged to be 

interfering with the aircrew. If "aboard" is to be given its broadest possible interpretation, 

consistent with 76 FR 76611,76612 (Dec. 8, 2011), both the individual and the aircrew must 

have some physical connection to the aircraft. The individual can be outside of the aircraft and 

interfere with a flight crew t[the individual touches the aircraft, enters the aircraft with any part 

of the individual's body or is controlling an object which touches or enters t.~e aircraft. This is 

consistent with the common law, the FAA's interpretation in the Federal Register and Admr. v. 

Siegel cited therein. It is not consistent with the overbroad interpretation sought in this case. 

Thus, an individual who points a laser at an aircraft, whether it is in flight or not, is controlling 

an object that causes entrance into the aircraft thereby interfering with the flight crew by blinding 

them. Likewise, in Siegel, the individual although on the ground, clearly entered the aircraft to 

strike the pilot. 

Respondent recognizes that the agency's interpretation in 76 FR 76611, 76612 (Dec. 8, 

2011) is entitled to deference. "We further note that the Board is required to defer to the 

Administrator's interpretation of the Federal Aviation Regulations, provided that such 

interpretation is reasonable and not arbitrary and capricious. 49 U.S.C. § 44709(d)(3); see also 

Garvey v. NTSB, 190 F.3d 571,576-79 (D.C. Cir. 1999)" Babbitt v. Krivitsky, SE-18355RM. 

The limitation on the complaint's interpretation sought by Respondent gives due deference to, 

and is consistent with the FAA's current published interpretation ofthe 14 CFR §91.11. 

However, the interpretation necessary to sustain the complaint is clearly overbroad and arbitrary 

and capricious. Furthermore, the complaint relies on dicta for support. The Complaint requires 

taking out of context the statement, " ... support the finding that an individual does not need to 

be on board the aircraft to violate §91.11." 76 FR 76611,76612 (Dec. 8, 2011). That statement 

taken out of context of the entry into the aircraft in Siegel or controlling the instrumentality that 

2 
enters the aircraft (laser beam) makes the statement mere dicta. Simply, there must be some 

physical connection to the aircraft to support a finding of a violation of §91.11. 

"An agency may not, for example, depart from a prior policy sub silentio or simply 

disregard rules that are still on the books. See United States v. Nixon, 41& U.S. 683, 696, 94 

S.Ct. 3090,41 L.Ed.2d 1039 (1974)"cited with approval in Federal Communications 

Commission v. Fox Television Stations, Inc., 556 U.S. 502, 129 S.Ct. 1800, 173 L.Ed.2d 738,77 

USLW 4337 (2009) This is what the FAA is doing through its unpublished and unsupported 

interpretation of 14 CFR §91.11. Just being on the ground does not put one "aboard" the 

aircraft. Interference with a Crewmember can be committed from the ground if there is some 

physical connection with the aircraft from which to infer that the individual is aboard the aircraft. 

It is not sufficient simply to be on the ground doing whatever the FAA Inspector arbitrarily and 

capriciously determines to be interference. To argue that the "plain language of the regulation 

does not specify the person interfering with a crewmember must be onboard the aircraft" is 

clearly inconsistent with the history of the FAA's own previous interpretation of §91.11. "In a 

later amendment to the rule, the FAA stated that this section was "clearly intended to apply to 

passengers*** and any other'person' onboard the aircraft." 64 FR 1076, 1077 (Jan. 7, 1999) as 

cited in 76 FR 76611,76612 (Dec. 8, 2011). Indeed, to be criminally liable for interference with 

a flight crew one must be "on board" the aircraft. 49 C. F. R. §46504. 

Respondent agrees that (1) a person can be on the ground and interfere with a flight crew 

if there is contact with or entry into the aircraft individually or by instrumentality. This is 

analogous to burglary where an instrument is used. " ... but if the actor was also using the 

instrument to reach some property therein, then it constituted an entry." Walker v. State, 63 Ala 

49(1873) cited in Handbook on Criminal Law, LaFave and Scott p.711, n.32 West 1972. Here, 

neither the Complaint nor the witness statements provided allege, that Respondent was onboard 

the aircraft, or had any contact, or connection with the aircraft. The complaint is therefore 

insufficient on its face. 

Moreover, the facts alleged in the complaint are properly within the control and 

jurisdiction of the airport operator not the FAA. The FAA regulations do not control vehicles on 

an airport and 14 CFR §91.11 does not preempt state statutes or Clark County Ordinances 

dealing wit.II ground vehicles on a11 airport. 76 FR 76611, 76612 (Dec. 8, 2011) does not address 

vehicles on an airport, it is limited to lasers. FAA Advisory Circular AC No: 150/5210-20, 

GROUND VEHICLE OPERATIONS ON AIRPORTS, addresses the issue of vehicular control. 

"3. APPLICABILITY. The overall responsibility for the operation of vehicles on an airport 

rests with the airport operator. .. " The statement by the FAA Controllers to pilots that "Ramp is 

Uncontrolled" is clear evidence that the FAA has ceded jurisdiction to the airport operator. 

Exhibit A. Affidavit of Joseph R. Maridon, Sr. 

The Federal Aviation Act has no express preemption clause. The Martin ex rel. Heckman 

v. Midwest Exp. Holdings, Inc., 555 F.3d 806 (9th Cir. 2009). The FAA has not by pervasive 

3 
regulation of vehicles on airports sought to preempt the states or counties or airport operators 

from enacting or enforcing such regulations. FAA Advisory Circular AC No: 150/5210-20 

clearly cedes jurisdiction over vehicles on the airport. In reliance on this Clark County, Nevada 

has enacted a pervasive statutory scheme to deal with vehicles on its airports, including penalties. 

This is consistent with the long held view of the courts, predating the FAA: 

" ... patrons of the field, whether they be owners of property abutting upon it or not, have no 

right in making use of the field to enter it with their ships except at places and in the manner 

provided by the rules and regulations of the city or its managers and agents in control of the 

field, which regulations may be changed from time to time as necessity and safety may 

require. City of Spokane v. Williams, 288 P. 258, 157 Wash. 120 (Wash. 1930) 

FAA Advisory Circular AC No: 150/5210-20, GROUND VEHICLE OPERATIONS ON 

AIRPORTS 

reiterates this view stating in pertinent part: 

a. 3. APPLICABILITY. The overall responsibility for the operation of vehicles on an 

airport rests with the airport operator ... a. Airport operators should establish procedures and 

policies concerning vehicle access and vehicle operation on the airside of the airport. These 

procedures and policies should address such matters as access, vehicle operator requirements, 

vehicle requirements, operations, and enforcement and should be incorporated into tenant leases 

and agreements. 

North Las Vegas Airport, is owned and operated by Clark County, Nevada. Clark County Code 

§ 20.08.010 states in pertinent part: 

20.08.010 Traffic regulations-Vehicular movement generally. 

(a) The "Rules of the Road" set forth in Chapter 484 of the Nevada Revised Statutes at 

NRS 484.251, et seq., as amended, and Title 14 of this code shall be applicable to and 

shall govern motor vehicle operation upon the real property known as McCarran 

International Airport or upon other county airports as if the roadways were dedicated and 

considered highways under said statutes and Title 14 except as otherwise provided by 

those regulations set forth in or promulgated pursuant to this chapter. (emphasis added) 

Clark County has further established Rules and Regulations for its General Aviation Airports, 

and has promulgated the appropriate rules which state: 

No person shall operate an aircraft at a General Aviation Airport in an unsafe or 

careless manner or in disregard of the rights and safety of others. AIRCRAFT 

OPERATIONS, Rules and Regulations for General Aviation Airports p.3 

The section regarding Restricted Operations: states: 

4 
The Director, or designee, may restrict the allowable types of aircraft operations 

on certain runways during noise sensitive hours, or for other operational 

considerations. Rules and Regulations for General Aviation Airports , P .4 

Those rules provide penalties from $100.00 to $1,000.00 per violation per day for violations of 

the rules. Those failures include: 

... fail( ure ) to comply with applicable federal, state, local and/ or DOA safety and 

health standards, regulations, or operating directives. Director, or designee, has the 

authority to enforce compliance with all applicable standards, regulations, or operating 

directives .... 

It has long been Respondent's understanding that vehicle matters on the ground at an airport 

are within thejurisdiction of the airport operators. In fact, he specifically contacted the Airport 

Manager about the issue about the Vision Airlines pilots taking the "back way" "shortcut" to 

runway 7. He placed his reliance on prior practice and the representations in FAA Advisory 

Circular AC No: 150/5210-20, GROUND VEHICLE OPERATIONS ON AIRPORTS (Affidavit 

of Joseph R. Maridon, Sr. attached hereto and incorporated herein by this reference) 

In this case, there is no published legal authority for the interpretation necessary to expand 

the jurisdiction of the FAA to the facts alleged in the complaint. The Complaint is also 

inconsistent with the arguments and representations in the Federal Register. Without that legal 

published authority, the FAA lacks jurisdiction to pursue this case and their complaint is 

insufficient on its face. The FAA's decision to proceed under these facts and circumstances is 

unreasonable, arbitrary, capricious, and contrary to law. 

The FAA should be Estopped from Proceeding on the Complaint and the Complaint should 

be dismissed 

The NTSB has recognized that equitable estoppel applies in administrative cases: 

We have previously recognized that equitable estoppel is a legal doctrine that prevents a 

person from adopting a new position that contradicts a previous position when allowing 

the new position would unfairly harm another person who has relied on the previous 

position to his or her detriment. Administrator v. Coughlan, NTSB Order No. EA-5197 at 

10 n.lO (20051 (citing Merriam-Webster's Dictionary of Law (1996)). Blakey v. 

Coughlan, SE-17000 

Estoppel will not be applied under the following circumstances: (estoppel does not apply where 

the public interest and safety in air commerce are at stake, and where the Administrator's powers 

are so clearly granted by statute). Administrator v. Fisher, 6 NTSB 1292 (1989), affd. Fisher v. 

DOT, 917 F.2d 27 (9th Cir. 1990) 

5 
Respondent clearly relied on previous position ofF AA that the airport operator is responsible for 

vehicle operations on the airport. (Exhibit A, Affidavit of Joseph R. Maridon, Sr.) His detriment 

is that the FAA has chosen to move forward with an alleged violation of 14 CFR §91.11 when 

that allegation is contrary to the FAA's previously stated position in FAA Advisory Circular AC 

No: 150/5210-20 that vehicles on an airport are subject to the jurisdiction of the operator of the 

airport, not the FAA. Moreover, there were no safety issues at stake created by the actions 

alleged against respondent the vehicle was clearly visible to the pilots and they were able to stop. 

Safety issues if present, were caused by the pilots of Vision Airlines taking a "short cut" with 

limited visibility for themselves and the tower. Moreover, it is in the public interest that vehicles 

on the airport be controlled by the airport operator and that interest is clearly addressed by the 

Clark County Code. Finally, it is clear that the FAA's statutory powers do not apply in this 

factual circumstance, because they have been ceded to the airport operator. 

Conclusion 

The complaint should be dismissed because: it is insufficient on its face, the FAA lacks 

jurisdiction and it should be estopped from proceeding on the complaint based on prior 

inconsistent representations. 

Respectfully submitted, 

/S/ 7osepfi OR. 'Maridon, 7~ 

Joseph R. Maridon, Jr. 

Attorney at Law 

Counsel for Respondent 

6130 Elton Ave. 

Las Vegas. NV 89107 

Attorney at Law 

Counsel for Re;;po1J'de:nt 

13435 North Whitehouse Court 

Spokane, W A 99208 

DATED:~Zd~ 

6 
U.S DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION REcEIvED 

In the Matter of: 

JUN 0 3 2014 

HEAHING DOCKET 

Joseph R. Maridon, Sr. 

Respondent 

FAA DOCKET 

FAA CASE NO. 2012WP190142 

(Civil Penalty Action) 

Administrative Law Judge Richard C. Goodwin 

AFFIDAVIT OF JOSEPH R. MARIDON, SR. IN SUPPORT OF MOTION TO DISMISS 

STATE OF WASHINGTON ) 

: ss 

COUNTY OF SPOKANE ) 

I, JOSEPH R. MARIDON, SR., being first duly sworn on oath, under penalty of petjury, deposes and 

says: 

I. I am 71 years of age. I have personal knowledge of the facts set forth herein, except for those 

matters stated to be based upon information and belief, which matters T believe to be true. 

2. I am a licensed Professional Engineer. I have owned and operated an airport and have 

knowledge of the rules and regulations regarding their safe operations. T am further aware that vehicular 

land operations on an airport are within the jurisdiction and responsibility of the operator of the airport as 

represented in FAA Advisory Circular No: 150/5210-20, GROUND VEIDCLE OPERATIONS ON 

AIRPORTS on which I have relied and continue to rely. 

3. On a number of occasions before September 12, 20121 contacted the North Las Vegas Airport 

Manager and requested that Vision Airlines not taxi by my hanger due to the excessive noise generated by 

the Do228 Dornier operated by Vision Airlines due to its adverse effect on myself and my visiting grand 

child. 

4. I also had serious safety concerns about large commercial aircraft taxiing in that area because 

there are numerous "blind alleys" from the rows of enclosed hangers on the right and left of that taxiway. 
I have seen small aircraft on the taxiway in question come nose to nose with other aircraft taxiing from 

those enclosed hanger rows to the right and left of the taxiways. (Depicted in exhibit A attached hereto 

and incorporated herein by this reference) 

5. I have owned the hanget· depicted in Exhibit A before September 12, 2012. When the FAA 

Control Tower (old tower) was between my hanger and the Vision Airlines ramp, Vision aircraft did not 

use the route that passed next to my hanger. It was my understanding based on information and belief 

that this was due to noise abatement and safety issues, although the controller from the old tower could 

clearly see the aircraft on the taxiway in question and in the hanger rows near the taxiway. 

6. The new FAA Control Tower is now across the airfield and has a restricted view of those 

hanger rows and does not control the taxiway that passed by my hanger. The Controllers in the tower 

frequently state over the radio to pilots words to the effect, "Ramp is uncontrolled" when the pilots 

request taxi instructions. The controllers at North Las Vegas Airport have also noted that their visibility 

from the new tower is limited in that area. (Exhibit B, VGT Bulletin page 2, July 2013, attached hereto 

and incorporated herein by this reference) 

7. There is a safer, alternative route that was previously used by Vision aircraft. It passes the 

open shade hangers and the fuel pumps and on to Taxiway "A" that gives the controllers in the new tower 

a far better view of taxiing commercial aircraft, is less noisy to the tenants, and gives the Vision pilots a 

better view of small aircraft and vehicles moving in and about the open shade hangers, because there are 

no blind alleys. (Exhibit A) 

8. The "back way" taken by the Do228 Domier pilots, as characteri7£d in the pilot's and copilot's 

statements, is a shorter route to the run-up area than the safer, alternative route described in paragraph 7. 

On information and he lief, it is apparent that the Vision pilots were taking an unsafe short cut to save time 

and fuel since in my experience there is rarely any "congestion" at the fuel pumps that would hinder an 

aircraft taxiing in the area of the fuel pumps at the North Las Vegas Airport. 

2 
Further, Affiant sayeth naught. 

' ~ c::ut«Ac."'-~ J,., . Date 

SUBSCRIBED and SWORN to before me, 

:1 /)'-fi, 

this ,d) day ofMay, 2014. ~ 

Notary Public 

State of Washington 

Jeri L. Mainer 

MY EXPIRES 

3 
Exhibit A to Affidavit of Joseph R. Maridon, Sr. 

Aerial views of North Las Vegas Airport and FAA Diagram 

LEGEND 

1. New Tower 

2. Area of alleged incident 

3. Vision Airlines Ramp 

4. Enclosed "Blind Alley" Hangers (Right and Left of Taxiway) 

5. Open Shade Hangers 

6. Fuel Pumps 

7. Maridon Hanger 

8. Old Tower Site 

9. Run-up area Runway 7 

"G" Taxiway G 

"F" Taxiway F 

AAA ... Shortcut "Back way" taken by Vision Airlines pilots 

BBB ... Safer route by Shade Hangers via Taxiway A 

Scale W' to 50' (enlarged aerial view) 

Do 228 Wingspan 55'8" 


13346 

AIRPORT DIAGRAM 

A TIS 

118.05 

NORTH LAS VEGAS TOWER* 

125.7 360.75 

GNDCON 

121.7 

CLNC DEL 

124.0 

JANUARY 20 I 0 

ANNUAL RATE OF CHANGE 

O.I"W 

Al-6970 !FAA) 

--- ----

CORPORATE 

-7=-. 

HANGARS 

I 

' 

HANGARS -

RWY07-25 

S-30 

RWY 12l-30R 

S-30 

RWY 12R-30l 

S-30 

---I 

NORTH LAS VEGAS (VGT) 

LAS VEGAS, NEVADA 

TWR 

* 

~ HANGAR 

.. / 

2230± 

A l--~--'-----~--'------t---'------'----~--'----I--~-'---'---36'12.0'N 

CAUTION: BE ALERT TO RUNWAY CROSSING CLEARANCES. 

READBACK OF All RUNWAY HOLDING INSTRUOIONS IS REQUIRED. 

I I 

115'12.0'W 115'11.5'W 

AIRPORT 11IAGR_AM LAS VEGAS, NEVADA 

NORTH LAS VEGAS (VGT) 13346 

UJ 

~ 
Exhibit B to Affidavit of Joseph R. Maridon, Sr. 

North Las Vegas Airport Bulletin, July 2013, page 2, Noting Limited Visibility of North Las 

Vegas Controllers visibility in Hanger Area depicted in Exhibit A 
BEN'S BRIEFING 

AIRFIELD IMPROVEMENT 

PROJECT- To improve airport 

safety and efficiency the airfield geometries has been changed pursuant 

to the direction of the FAA Please 

remember to "stay off the green". 

The new configuration will provide a 

visual queue to assist transient pilots in navigating around the airport. 

The intent of the green islands is to 

provide funneling and ensure that 

the aircraft is situ<~ted perpendicular 

to the mandatory hold bar. 

GUY ELEMENTARY SCHOOL 

TOUR - One hundred and ten 

students visited VGT from Guy Elementary. A "Big Thanks" to Airwork LLC, Dave Edwards, EGA 

Aviation, Elite Aviation, Jeff Farmer, 

FAA ATCT, Chet Kruleski, SWAT, 

and Vision Air for displaying aircraft 

and meeting with the children to get 

them even more excited about aviation! Community outreach and fostering enthusiasm in today's youth 

is extremely important to the future 

of aviation. 

STAKEHOLDERS MEETING 

The next Stakeholder meeting is 

scheduled on September 19, 2013 

at 6:00p.m. 

FACILITY UPDATE - For your 

convenience there are several 

waste oil collection barrels located 

throughout the airport Please dispose waste oil only in these collection sites. The DOA routinely has 

the waste oil removed and reprocessed. 

MEMORIAL - Larry James Siggelkow left us too soon, on April 

28, 2013 after living a very full life 

and touching so many lives along 

the way. He was born on December 24th, 1947 and grew up in 

Garden City and was very active 

in the Community Christian Center. He earned his pilot's license on 

his 16th birthday and continued to 

fly his entire life. In Las Vegas he 

joined the police department where 

he proudly served for over 30 years 

in various capacities. He was instrumental in helping the police 

force integrate with aviation assets 

and spearheaded many of its penal 

transportation programs. 

Always known as a hard worker 

who possessed many creative and 

innovative ideas, Larry would take 

his natural entrepreneurial spirit 

and focus efforts on building one of 

the most successful charter airlines 

in the Las Vegas area. He retired 

in 2011 and returned to Boise to be 

near his family and spend what he 

called his H-A-P-P-Y years, fishing in his backyard, doing regular 

goose patrols, running on his favorite trails, and spending time with 

his beloved wife. Larry was a true 

gentleman and served as a genuine 

example of humanity to all who 

had the pleasure of knowing him. He 

will be deeply missed. 

PROJECT CONCEPT 

APPROVAL- If you are planning 

any improvements to your hangar or 

commercial facility you must receive 

approval from the DOA before 

proceeding. The Business Office will 

complete a Project Concept Approval 

form based on your complete project 

description and concept drawing (email to the Airport Manager Bencz@ 

mccarran.com or submit to the 

office). 

North Las Vegas Airport 

Airport Manager 

2730 Airport Drive, Suite 101 

North Las Vegas, Nevada 89032 

DOA will respond to your request as 

soon as possible (may take a few 

weeks based on the complexity of 

the project). A Project Coordinator 

will be assigned to assist you and a 

pre-construction kick-off meeting will 

be scheduled. 

During construction, the contractor 

will work with the DOA Project 

Coordinator and Inspector to 

complete the Project Acceptance 

Checklist. When all checklist items 

have been completed (including 

the submission of As-Builts), DOA 

Construction/Engineering will confirm 

that all business/ acquisition issues 

have been completed before closing 

the project. 

All projects shall be in accordance 

with the Tenant Improvement 

Manual located on-line at http:// 

www.mccarran.com/Doing Busness 

/te nant_i mprovement. html. 
Keep off the Grass! More precisely, keep off the green painted 

areas in the vicinity of Rwy 7 and Taxiway G & F. In an effort 

to reduce the number of pilot deviations, many airport layout 

changes have been made or are in progress. Over the last 

decade, VGT has constantly been near the top nationwide 

for the most runway incursions annually; but we're changing 

that. Currently, we are well below are historical year to date 

average and well on our way to a spectacular year. However, 

with the change in geographical layout come some issues 

that all pilots should be aware. 

One issue to note is that there is limited visibility from the control tower of 

the ramp at the entrance of taxiway G. Aircraft taxiing westbound passing 

taxiway F and aircraft taxiing eastbound from runup area or from behind the 

hangars must use good judgment and exercise caution as the ramp is a nonmovement area (non-controlled) and out of the line of site from the tower. 

Another issue to be cautious with is aircraft should be utilizing appropriate 

lights while taxiing after sunset as blue reflectors are being temporarily utilized 

to delineate taxiway edges where the green islands have been added. Third, 

the run up area is no longer a movement area; ATC may or may not be aware 

of the presence of aircraft taxiing in the vicinity. And last, the taxi clearance, 

'Runway 7, taxi via G' authorizes aircraft to cross taxiway A and up to the 

hold short marking for Runway 7. Many aircraft are stopping short of taxiway 

A and contacting Tower prior to entering the movement area. While not an 

issue in itself, during peak traffic periods, holding short of taxiway A may 

cause blockages in the taxi lane. 

As summer approaches, it is vital for pilots to stay aware of weather 

conditions and its impact to the performance of aircraft. Increased takeoff 

distance, reduced rate of climb, increased true air speed on landing and 

approach, and increased landing roll distance are all affected by density 

altitude. Additionally, thunderstorms can develop rapidly and should be cause 

for concern. Until next time, heads up, hold short, fly right. 

Grand Canyon Room 

2nd Monday- CAP- Nellis Sr. Squadron 

4th Monday - CAP - Nellis Sr. Squadron 

1 stTuesday - EAA Chapter 163 

2nd Tuesday - 1/4 Scale Assoc- 6:45pm 

1st Wednesday - Commemorative Air Force 

2nd Wednesday- Rebel Squadron (In 

Modular Building) 

4th Wednesday- Prop- Nuts 

Every Thurs. - Clark County 

Composite Squadron Civil Air Patrol 

4th Thursday -FAA FAST TEAM 

Conference Room 

4th Monday - Dust Devils 

1st Tuesday - CAP 

2nd Tuesday- LV Eagles 

3rd Tuesday- 99s- 5:30pm- 7:00pm 

4th Tuesday- LV Balloon Club 

3rd Wednesday -Commemorative Air 

Force 

Every Thurs. - Clark County Composite 

Squadron Civil Air Patrol 

{All meetings are at 7PM unless otherwise noted.) 

COMMISSIONERS 

Steve Sisolak, 

Chair 

Larry Brown, 

Vice-Chair 

Susan Brager 

Tom Collins 

Chris Giunchigliani 

Mary Beth Scow 

Lawrence Weekly 

Donald G. Burnette, 

County Manager 

Assistant County Managers 

Edward Finger 

Randall J. Tarr 

Jeffrey M. Wells 

Rosemary A. Vassiliadis, 

Director of Aviation 

Harry Waters, 

Deputy Director 

Cecil Jolmson, 

Assistant Director, 

General Aviation 

Ben Czyzewski, 

Manager, GA Airports 

Cheryl Jackson, 

Customer Service 
U.S DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION REcEIvE 0 

JUN 0 3 2014 

In the Matter of: HEAHING DOCKET 

Joseph R. Maridon, Sr. 

Respondent 

Richard C. Goodwin Administrative Law Judge 

Docket No. FAA-2014-0116 

CERTIFICATE OF SERVICE 

FAA DOCKET 

FAA CASE NO. 2012WP190142 

(Civil Penalty Action) 

1 hereby certify that I am over the age of eighteen years and not a party to the within 

action. I further certify that on the 2:1!._ day of 911 a. tj , 2014, I deposited in the U.S. 

Mail, with postage fully prepaid, a true and correct copy of : 

(1) Motion To Dismiss 

(2) Affidavit Of Joseph R.Maridon, Sr 

addressed to the following: 

ORIGINAL & ONE COPY 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur-Wright Building-Suite 2W1 000 

ONE COPY 

Joseph Maridon, Sr., Respondent 

9212 E. Frederick Ave 

Spokane, WA 99206-4303 

Jospeph R. Maridon,Jr., Respondent's Counsel 

Attorney at Law 

6130 Elton Ave 

Las Vegas, NV 89107 
Naomi Tsuda, Complainant's Counsel 

Office ofthe Regional Counsel, A WP-7 

Federal Aviation Administration 

Western-Pacific Region, 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

TEL: 310-725-7100 

FPLX:310-725-6816 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

TEL: 202-366-5121 Staff Assistant 

F PLX: 202-366-7536 

/s/~L~