In the Matter of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

MONROE AIR CENTER, LLC, 

Respondent 

FAA CASE NO. 2011 SW030084 

FAA CP CASE NO. ___ _ 

JUDGE NOT ASSIGNED 

ANSWER OF MONROE AIR CENTER, LLC 

COMES NOW Monroe Air Center, LLC, Respondent in the above-captioned matter, AND 

pursuant to 14 CFR § 13.209, and for its Answer shows the Court as follows: 

FIRST DEFENSE 

The Complaint fails to state a violation of 14 CFR §135.21(a). See~~ 3(a), 3(b) on page 1 ofthe 

Complaint and~ a on page 2 of the Complaint alleging violations of 14 CFR § 135.21(a) despite the fact 

that in a letter of interpretation from FAA AS0-7 to FAA AS0-200 dated June 10, 1981 [attached as 

Respondent's Exhibit No. 1], FAA counsel specifically found that a failure to comply with the 

requirements of a General Operations Manual ("GOM") could not fonn the basis for a violation of the 

Federal Aviation Regulations because the GOM merely must be "used" [14 CFR §135.21(a)]. See 

Respondent's Exhibit No. 1 attached. Since the verb "use" means to "accustom, habituate, to put in 

action or service," it is not binding, FAA counsel having declared: 

"In considering this definition it is difficult to conclude that a requirement to 

use a manual is the same as a requirement to be bound by the manual. .. " !d. 

In light of the foregoing, even if the facts alleged in the Complaint were true, they would not constitute a 

violation ofthe Federal Aviation Regulations. There is and was no violation of 14 CFR §135.21(a) as 

alleged in the Complaint. 

1 
SECOND DEFENSE 

The Complaint fails to state a violation of I4 CFR § II9.5(g) for the following reasons: 

(1) At all times material hereto, Monroe Air Center, LLC ("MAC") was the holder ofF AA Air 

Carrier Certificate No. HLWA II6E. See Respondent's Exhibit No. 2 attached, Air Carrier 

Certificate issued to Respondent by the FAA; 

(2) MAC was authorized to operate N800CF on its air carrier certificate. See Respondent's 

Exhibit No. 3 attached, FAA Operation Specification D085 listing N800CF as an approved 

aircraft on Respondent's Air Carrier Certificate; 

(3) MAC was in the process oftransitioning its air carrier operations to JPS Aviation, LLC 

("JPS") by October I8, 20 II. See Respondent's Exhibit No.4, FAA Operation Specification 

A502 issued October 3, 2011; 

( 4) MAC's transition to JPS had not been successful by October 18, 2011 with the result that 

MAC's air carrier operations reverted to MAC effective October 20, 2011. See Respondent's 

Exhibit No. 5, letter from the FAA to MAC, October 20, 20 II; 

(5) MAC, believing the transition to JPS would be accomplished in a timely fashion, ordered 

forms (including invoices) bearing the name of JPS. The forms were only to be used after the 

transition was accomplished; 

(6) MAC underwent a focus inspection by the FAA from August 8 to August I2, 20Il. See 

Complaint, ~2; 

(7) There was a great deal of confusion among the staff at MAC about the transition; and July 

Fuller, MAC's Chart Coordinator, was so confused, she simply used the wrong invoice. See 

Respondent's Exhibit No. 6, Invoice No. I1-1 0035 from JPS to Oschner Hospital, October 

25, 2011; and 

(8) N800CF was on MAC's air carrier certificate on October 25, 2011 (Respondent's Exhibit No. 

3); hence, the claim that N800CF was operated in air carrier service "without, or in violation 

2 
of, an appropriate certificate and operation specifications" (14 CFR §119.5(g)) is false. See 

Complaint, ~~4, 5, 6, 7, 8, 9, 10, (b). 

THIRD DEFENSE 

The Complaint fails to state a violation of the Federal Aviation Regulations for all the reasons 

outlined above in the First and Second Defenses. 

FOURTH DEFENSE 

By virtue of the complicity of the FAA in generating confusion about whether the operations 

were to be conducted by JPS or MAC, the FAA bears responsibility in the matter at hand and is estopped 

from asserting any violation of the Federal Aviation Regulations by Respondent. 

FIFTH DEFENSE 

Responding to the numbered paragraphs of the Complaint, Respondent shows as follows: 

1. 

Responding to the allegations made in Paragraph I of the Complaint, page 1 of the Complaint, 

Respondent admits that MAC was advised in a Notice of Proposed Civil Penalty that the FAA proposed 

to assess a civil penalty of $2,800.00; however, Respondent denies that it is obligated to pay a civil 

penalty of $2,800.00 because Respondent is not guilty of any violation of the Federal Aviation 

Regulations. In further response to Paragraph I of the Complaint on page 1 of the Complaint, Respondent 

admits that on June 28, 2012, Respondent submitted a written Request for a Hearing in this matter. 

2. 

The allegations made in paragraph 1 under Roman Numeral II of the Complaint alleging that 

MAC holds FAA Certificate No. HLWA116E are admitted. 

3 
3. 

The allegations made in paragraph 2 under Roman Numeral II of the Complaint that Respondent 

was the subject of an FAA focused inspection from August 8, 20II to August I2, 201I are admitted. 

4. 

Responding the allegations made in Paragraph 3, subparagraph (a) under Roman numeral II ofthe 

Complaint on page I of the Complaint, Respondent admits that John 0. Shamblin was mistakenly listed 

as General Manager in the GOM; however, Respondent denies that this is the basis for finding a violation 

under I4 CFR § 135.21(a) for the reason that a certificate holder is not "bound" by its GOM so as to create 

a violation of the Federal Aviation Regulations if it fails to "use" the GOM as confirmed by the letter of 

interpretation from AS0-7 to AS0-200 dated June IO, 198I, attached hereto and marked as Respondent's 

Exhibit No. I. 

5. 

Responding to the allegations made in Paragraph 3, subparagraph (b) under Roman numeral II of 

the Complaint on page 1 of the Complaint, Respondent denies that the superseded aircraft status log could 

not be located, but even if it could not be located, the failure to locate the superseded aircraft status log 

does not give rise to a violation of the Federal Aviation Regulations under I4 CFR § 135.21(a) for the 

reasons set out in the letter of interpretation from AS0-7 to AS0-200 dated June 10, 1981 attached hereto 

and marked Respondent's Exhibit No.1. 

6. 

Responding to paragraph 4 under Roman numeral II on page of the Complaint, the allegations 

made that Operation Specification A502 was issued effective March 28, 2001 are admitted and that 

Operation Specification A502 allowed MAC to continue operations as "Monroe Air Center" while MAC 

completed training and developed the qualifications necessary to transition to JPS. 

4 
7. 

Responding to the allegations made in paragraph 5 under Roman numeral II of the Complaint 

appearing on page 2 of the Complaint, Respondent admits that Operation Specification A502 indicated 

that the approved transition must have been completed by September 1, 2012. 

8. 

Responding to the allegations made in paragraph 6 of the Complaint under Roman numeral II of 

the Complaint on page 2 of the Complaint, Respondent admits that MAC, due to the unreasonable 

demands of the Baton Rouge FSDO, did not complete the requirements for transition to September 1, 

2011 and the FAA granted an extension for completion to no later than October 3, 2011; provided, 

however, Respondent states that the FAA created a number of hurdles to transitioning as JPS to the extent 

that the Baton Rouge FSDO was not agreeing to the terms and provisions of the GOM drafted by 

Respondent and became unreasonably obtrusive, burdensome and demanding during this period of 

transition which was expected by Respondent to be accomplished without so much obstruction by the 

Baton Rouge FSDO representatives. 

9. 

Responding to the allegations made in paragraph 7 of the Complaint under Roman numeral II on 

page 3 of the Complaint, Respondent admits that it was not able to meet the transition requirements by 

October 3, 2011, because of the obstructionist conduct of the Baton Rouge FSDO and that the FAA 

granted Respondent an additional extension period for completion of the transition to October 18, 2011. 

10. 

Responding to the allegations made in paragraph 8 under Roman II on page 3 of the Complaint, 

Respondent admits that because of the obstructionist behavior of the Baton Rouge FSDO, it was unable to 

complete the transition to JPS prior to October 18, 2011. 

5 
11. 

Responding to the allegations made under Roman numeral II, paragraph 9, on page 2 of the 

Complaint, Respondent admits receiving a letter from the Baton Rouge FSDO dated October 20, 2011 

reminding MAC that the operation specifications for the merger/acquisition had expired. See 

Respondent's Exhibit No. 5 attached. 

12. 

Responding to the allegations made under Roman numeral II, paragraph 1 0, on page 2 of the 

Complaint, Respondent admits that "MAC operated civil aircraft number N800CF in charter service;" 

however, MAC denies that N800CF was operated "as JPS Aviation, LLC". Rather, the flight was 

conducted by MAC in accordance with its air carrier certificate and the operation specifications 

authorizing the operation ofNSOOCF on the air carrier certificate of Respondent. See Respondent's 

Exhibit Nos. 2 and 3 attached. 

13. 

Responding the allegations made in subparagraph (a) to the unnumbered paragraph appearing on 

page 2 ofthe Complaint, Respondent denies any violation of 14 CFR §135.2l(a). 

14. 

Responding to the allegations made under subparagraph (b) under the unnumbered paragraph on 

page 2 of the Complaint, Respondent denies any violation of 14 CFR § 119.5(g). 

15. 

Responding to the allegations made in paragraph 1 under subparagraph III ofthe Complaint on 

page 2 of the Complaint, Respondent denies that it is subject to a civil penalty under 49 U.S.C. §4630 1 in 

6 
the maximum amount of$11,000.00 per violation for the reason that Respondent has committed no 

violation of the Federal Aviation Regulations. 

16. 

Responding to the allegations made in paragraph 2 below Roman numeral III of the Complaint, 

on page 2 of the Complaint, Respondent denies that it is liable to pay the FAA a civil penalty to 

$2,800.00; and, furthermore, Respondent denies that it is obligated to pay the FAA any civil penalty in 

any amount whatsoever. 

17. 

Responding to the allegations made in the unnumbered Complaint appearing below Roman 

numeral III, paragraphs 1 and 2 of the Complaint, Respondent denies again any violation of the Federal 

Aviation Regulations and denies that this Court is authorized to enter judgment for a civil penalty in the 

amount of$2,800.00 against Respondent, because Respondent is guilty of no violation ofthe Federal 

Aviation Regulations. 

WHEREFORE, having fully answered the Complaint, Respondent pray as follows: 

a. That the administrator's Complaint be dismissed; 

b. That the Court find that the FAA may not assert a violation of 14 CFR § 135.21(a) in view of 

the letter of interpretation issued by AS0-7 to AS0-200 dated June 10, 1981 in the form 

attached hereto and marked as Respondent's Exhibit No. 1; 

c. Respondent prays that the Court find that in light of the fact that MAC did have an air carrier 

certificate and in light of the fact that N800CF was listed on the air carrier certificate as an 

approved aircraft on October 25, 2011, there was no violation of 14 CFR § 119.5(g) because 

the aircraft was operated "with" an approved air carrier certificate, the billing invoice marked 

Respondent's Exhibit No.6 having been a mistake that resulted from the confusion that came 

7 
from the activity and interaction between Respondent and the Baton Rouge FSDO beginning 

in August 20 11 and thereafter; 

d. That the Court find that there has been no violation of 14 CFR § 119.5(g) because of the 

complicity of the FAA and the confusion associated with the attempted transition from MAC 

to IPS resulting in Judy Fuller, MAC's charter coordinator, mistakenly invoicing for the trip 

of an approved aircraft on MAC's charter certificate using an incorrect invoice; and 

e. That the Respondent have such additional and further relief as the Court deems just and 

proper in the premises. I B f ~ 

Respectfully submitted this the _ 1 _day of July, 2012. 

2900 Chamblee Tucker Road 

Building 5, Suite 350 

Atlanta, GA 30341 

770-451-0313- 0 

770-451-0317- F 

alan@alanan11stronglaw.com 

8 

Alan Armstrong ~ 

Georgia Bar No. 022075 " 

Counsel for Respondent, Monroe Air Center, LLC 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the Matter of: 

MONROE AIR CENTER, LLC, 

Respondent 

CASE NO. 2011 SW030084 

RESPONDENT'S LIST OF EXIITBITS 

1. Letter oflnterpretation from AS0-7 to AS0-200, June 10, 1981 regarding enforeceability of 

FAR Section l35.21(a) 

2. Air Carrier Certificate issued to Monroe Air Center, LLC by the FAA effective January 24, 

1986 (reissued March 5, 2002), Certificate No. HLWA116E 

3. Operation Specification D085 issued to Monroe Air Center, LLC effective September 15, 

2011 

4. FAA Operation Specification A502 issued to Monroe Air Center October 3, 2011, expiring 

October 18, 2011. 

5. Letter from FAA Aviation Safety Inspection Mary E. Donahue to Monroe Air Center, LLC, 

October 20, 2011 

6. Invoice No. 11-10035 from IPS Aviation, LLC to Ochsner Hospital, October 25,2011 

referencing N800CF 

1 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the Matter of: 

MONROE AIR CENTER, LLC, 

Respondent 

CASE NO. 2011 SW030084 

RESPONDENT'S LIST OF EXHffiiTS 

1. Letter oflnterpretation from AS0-7 to AS0-200, June I 0, 1981 regarding enforeceability of 

FAR Section 135.21(a) 

2. Air Carrier Certificate issued to Monroe Air Center, LLC by the FAA effective January 24, 

1986 (reissued March 5, 2002), Certificate No. HLWA116E 

3. Operation Specification D085 issued to Monroe Air Center, LLC effective September 15, 

2011 

4. FAA Operation Specification A502 issued to Monroe Air Center October 3, 2011, expiring 

October 18, 2011. 

5. Letter from FAA Aviation Safety Inspection Mary E. Donahue to Monroe Air Center, LLC, 

October 20, 2011 

6. Invoice No. 11-10035 from JPS Aviation, LLC to Ochsner Hospital, October 25,2011 

referencing N800CF 

1 
. ' 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

/) ~~ "'5' ,R; 2:0 =< 

~<<::-):"~·;. _<,J\ if .,:; ~ r G 1·(.<.:, ~\ 1 f. . {\ ) -~~ \J:._ ··-.., ' _.;.._;:.I [.7 .. 

DATE: JUN 1 0 138\ 

SOUTHERN REGION ~ P. 0, BOX 20636 

ATLANTA, GEORGIA 30320 

suBJECT: Enforceability of FAR § 135. 21(a) 

FROM: Attorney, Office of the Regional Counsel 

TO: AS0-200 

The second sentence of FAR 135.2l(a) provides that "This manual must 

be used by the certificate holder's flight, ground and maintenance 

personnel in conducting its operations. Your memo dated March 6, 

1981, asks, in effect, whether, in light of the foregoing language, 

noncompliance with the certificate holder's manual by its employees in 

the conduct of air taxi operations would be a violation of §135.2l(a). 

We believe that §135.21 was never intended to be enforced in~this 

manner. In arriving at this conclusion I have reviewed not only the 

appropriate regulatory sections but also the regulatory history\of 

§135.21. Copies of this material are attached for reference. 

Prior to the time Part 135 was amended in 1978 there only existed the 

requirement that a certificate holder "prepare and keep current a 

manual for the use and guidance of flight, ground operations, and 

maintenance personnel in conducting its operations." As noted above, 

amended language now provides that these individuals must "use" the 

manual. The question now arises as to the significance of this 

change. 

Notice of Proposed Rule Making 77-17 (42 FR 43490, Aug. 29, 1977) 

included the following language pertaining to this change: 

§135.23 [changed to §135.21 in the final rule] 

MANUAL REQUIREMENTS. 

. . In addition, this section would be revised by amending 

paragraph (a) to require each certificate holder who is required 

to have a manual to prepare a manual acceptable to the 

Administrator. Further, each flight, ground, and maintenance 

employee of the certificate holder would be required to use the 

manual in the conduct of the ceertificate holder's flight 

operations. 

RESPONDENT 

EXHIBIT 

l 
This language, on its face, would seem to imply that the FAA w~s about 

to make a radical departure from past practice by making noncertificated individuals (i.e., ground employees) s~bject to 

disciplinary actions. Moreover, the change would be even more radical 

since we would be enforcing not only sta~dards specified in the FARs 

but also internal company standards. 

The extent of this change becomes apparent when considering specific 

cases. Consider, for example, a company manual requirement which 

provides that an aircraft refueler must turn in fuel slips to the 

chief of operations at the end of each day. Could the FAA logically 

take the position that if the refueler turns in the fuel slips at the 

end of each week and turns them in directly to the accounting 

department he would be in violation of ~he manual, and, therefore, in 

violation of §135.2l(a) and subject to ? civil penalty. The answer is 

self evident. 

The language which was adopted in the final rule provides that the 

manual must be 11 used. 11 The word 11used' 1 is, not defined in Part 1, so 

under the rules of construction we must apply its commonly :accepted 

meaning. Webster's new collegate dictionary provides the following 

definition. 

USE (verb) 1. Accustom, habituate 2. to put into action or 

service: avail oneself of: employ 3. to consume or take (as 

liquor or drugs) regularly 4. to carry out a purpose of action 

by means of: utilize 5. to expend or consume by putting to use 

6. to behave toward: act with regard to: treat' . l 1 I 

. ·_, i 

In considering this definition it is ~iffic~lt to conclude that a 

requirement to use a manual is the same as a requirement to be bound 

by the manual. This conclusion is furth·er strengthened when other 

language in the preamble and rule is considered. For example, the 

third sentence in §l35.2l(a), although addressing deviations, clearly 

implies that the manual is for the "guidance" of flight, ground and 

maintenance personnel. Guidance, by definition, is not mandatory but 

merely informatory. 
After considering all of the material available and also after 

discussions with AGC-220 it seems clear that the requirement to "use" 

the manual was intended as a mandate to the operator to insure that 

its personnel have sufficient guidance available and that company 

emphasis be placed on the use of this guidance. It was not intneded 

to be enforceable against individual employees. 

Now that the foregoing conclusion has been drawn a qualification must 

be inserted. In almost every case where enforcement action would be 

appropriate (i.e., in cases other than the type used in the example 

above) there will be an appropriate FAR section other than 135.2l(a) 

on which the violation action can be based. For example, if a pilot 

violates the manual's weight. and balance provisions [see §135.23(b)], 

he will, 1n all probability, also be in violation of §135.185. 

There will, of course, be times when an operator imposes on his 

employees a higher standard than required in the FARs. In a case 

where an employee violates this higher standard, under the guidance 

stated above, enforcement action would not be appropriate. 

In summary, the rule of thumb should be that if an individual fails to 

comply with a part of the manual that is made mandatory by some 

section of the FARs other than §135.2l(a) then the violated FAR should 

be cited. If, on the other hand, an individual violates a company 

standard not covered by the FARs then any enforcement action as to the 

violation of that standard should be at the discretion of the company. 

This opinion has been coordinated with the Office of the Chief 

Counsel, Operations Law Branch, AGC-220. 

AO""s:J< D ·~ ' 

XRSCHEL H·uN, JR. 
US Department 

of Tr2nsportation 

Federal Aviation 

Administration 

: RESPONDENT 

EXHIBIT 

h 

Air Carrier Certificate 

This certifies that 

Monroe Air Center, LLC 

5410 Operations Road 

l\,1om·oe, Louisiana 71203 

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

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

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

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

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

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

sha!! continue in effect indefinitely. 

Certificate number: ___ ..HU\'AUJi.E___ 

Effective Date: ___ January __ ~-1-. l ~_§ __ 

Reissued: 03/05/2002 

Issued ai: __ iLHilllJsDJ!~-.J&tti8;uFl __ _ 

FAL; Fcrrn s.:;3Q-l S (6-Bl) 

By Direction of the Administrator 

/~L--0~~ ___ "-.___./=-~]= To~ph D Smith 

(Signature) 

~0~ ~FFIC::IAL USE ONLY 

Puoltcavalfability to be 

determined under 5 U.S.C. 552" 

--~A=c~l~ae~r ____ _ (Title) 

w., 

(Region/Office) 
! RESPONDENT ~ EXHIBIT 

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of Transportation 

Federal Aviation 

Admini stration Operations Specifications 

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D085. Aircraft Listing: HQ Control: 02/06/1998 

HQ Revision: 02a 

a. The certificate holder is authorized to conduct operations under 14 CFR Part 135 using the 

aircraft identified on this operations specification. 

Registration No. Serial No. Aircraft lVlfl\IIS 

N559DW BB-1036 BE-200-8200 

N711EL TH-732 BE-58-58 

N800CF TH-1599 BE-58-58 

N396CA U-1035 BE-90-C90 

1. The Certificate Holder applies for the Operations in this paragraph. 

2. Support information reference: 

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

211ll .t1'1.15 1.~:' :<: 2'<· ,: nlr:li [),, -. ld\1 Tin~o.: 

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4. Date Approval is effective: 09115/2011 Amendment Number: 12 

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

Woodward, Donald E., Dir. of Maintenance, Part 135 

Print Date : 9/1512011 

Date : 09/15/2011 

FOR OFFICIAL USE ONLY 

"Publ ic availability to be 

determined under 5 U S.C. 552" 

D085-l 

Monroe Air Center. L.L.C. 
& 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

£+ 

Operations Specifications 

AS02 . Air Carrier Merger and/or Acquisition HQ Control: 05/23/2006 

HQ Revision: 000 

a. The certificate holder, Monroe Air Center, L.L.C., is authorized to conduct operations in 

accordance with these operations specifications during the merger transition period with JPS 

Aviation, LLC.. The merger transition period will commence October 3, 2011 and shall continue until 

all required training and qualifications are accomplished or within: a period no later than October 18, 

2011.. 

b. The following conditions must be met for the certificate holder to continue to conduct operations 

during the transition period: 

(1) General: 

Letter of Compliance addressing appropriate parts of 14 CFR Parts 43, 61, 91, 119 and 135 must 

be submitted for JPS Aviation, LLC 

No changes in required personnel (Director of Operations, Chief Pilot, or Director of Maintenance) 

unless approved by the Baton Rouge FSDO. 

Schedule of Events for Air Carrier certification per FAA Order 8900.1 will be provided to show 

target dates. 

(2) Operations: 

Operations under 14 CFR 135 will be conducted using Monroe Air Center, LLC's Operation 

Specifications, General Operations Manual, Training Program, HAZMAT Program, MEL's and 

aircraft checklistlbriefmg cards 

(3) Airworthiness: 

Any required inspections, sign-offs, or maintenance training will be conducted using Monroe Air 

Center, LLC's Operation Specifications, Genera1 Operations Manual, maintenance training, Aircraft 

Maintenance Manuals and authorized maintenance program. 

c. This operations specification is valid as of the effective date and shall remain in effect as long as 

the certificate holder continues to meet the requirements of this operations specification. 

d. This operations specification msut be re-issued to extend the transition period indicated in 

subparagraph a above. When the transition is complete, this operations specification is no longer 

necessary and must be archived. 

Utilization of the above Operation Specifications, Manual and procedures shall be void after 

certification is completed for JPS Aviation, LLC. 

RESPONDENT ]~ EXHIBIT 'h. 

Print Date: 1017/2011 A502-l Certificate No.: HLWA116E 

fk5<Fffif.Mf::rAEtff s\:bNLY 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

1. Issued by the Federal Aviation Administration. 

2. Support infom1ation reference: 

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

:o 11.111.(1~ I >;:Oi:o:.: ( ·.:nlr<tl [)," li:..Jll rin1.: 

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l'ri~ll'ip:il ( J!l.:ratir;lh Jn-;.pc'Cltll' t S\\'11:~ 1 

4. Date Approval is effective: 10/03/2011 Amendment Number: 5 

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

Jarrell, C. Palmer, Dir. of Operations, Part 135 

Date: 10/03/2011 

Prmt Date: 1017/2011 A502-2 Certificate No.: HL W A 116E 

Monroe Air Center, L.L.C. 
U.S. Deportment 

of Transportation 

Federal Aviation 

Administration 

October 20, 2011 

Baton Rouge, Louisiana 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Mr. Paul Bullock, Agent for Service 

MonroeAir Center, LLC 

5410 Operations Rd. 

Monroe, LA 71203 

Dear Mr. Jarrell: 

Flight Standards District Office 

6100 Corporate Boulevard 

Suite 200 

Baton Rouge, Louisiana 70808 

225-932-5900, Fax: 225-932-5975 

; · RESPONDENT ~ . ·ExHfBlT 

s 

The Operations Specifications paragraph for Air Carrier Merger/ Acquisition has expired 

effective October 18, 2011 and the authorization for a transition to JPS Aviation, LLC has 

been suspended at this time. Enclosed you will find your amended copy of Operatioq 

Specifications paragraph A004, removing paragraph A502. 

must utilize the following: 

Monroe Air Center, LLC Operations Specifications 

Monroe Air Center, LLC General Operations Manual 

Monroe Air Center, LLC Training Program 

Monroe Air Center, LLC HAZMA T Program 

Monroe Air Center, LLC Minimum Equipment Lists 

Monroe Air Center, LLC Maintenance Program 

Also, per 14 CFR 119.9, the business name on your Air Carrier Certificate, i.e. Monroe Air 

Center, LLC, must be used for all operations conducted under 14 CFR Part 135. 

Please review the enclosed Operations Specifications, sign both copies and return one set to 

this office within 14 days of receipt. 

Should you have any questions concerning the above, please call this office. 

Sincerely, 

Mary E. Donahue 

Aviation Safety Inspector 

FOR OFFICI!\L USE ONLY 

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Mr. Paul Bullock, Agent for Service 

Monroe Air Center, LLC 

541 0 Operations · Road 

Monroe, LA 71203 

SENDER: COMPLETE THIS SECTION . · · -. - . . . . . . 

·l • Complete items 1, 2, and 3. Also complete 

item 4 if Restricted Delivery is desired. 

• Print your name and address on the reverse 

so that we can return the card to you. 

• Attach this card to the back of the mailpiece, 

or on the front if space permits. 

1. Article Addressed to: 

. FOR OFFICiP.L u~;t: ONLY 

"Public availability to be 

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'···I II 11111•11111·111111 'II" I II 1'1 II 11111•11 " l!;====:f=:===========::::======ic== 

Mr. Paul Bullock, Agent for Service 

Monroe Air Center, LLC 

541 0 Operations Road 

Monroe, LA 71203 4. Restricted Delivery{ (Extra Fee) 

2. Article Number 

. . , (fr<ylsfe,r f(OITJ 7~ryir;e laJ;leO 7010 1870 0001 8188 2871 

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0 Yes 

1 02595-02-M-· 
JPS Aviation, LLC 

5410 Operations Road 

Monroe, LA 71203 

800-223-3895/318-387-0222/318-325-7 558 (Fax) 318-387-1506 

Invoice: 11-1 0035 

Account#: OCHHO 

Sold To: OCHSNER HOSPITAL (RAMEE & WHITE) 

Attn: LORI DRUFNER 

A TIN: Dr. Christopher White 

1514 Jefferson Hwy 3rd Floor 

New Orleans, LA 70121 

10/25/11 

8.12AM 

Sales Person: Lisa 

Une# Type Item/Description !cr?! Aircraft I Quantity! Units I List Price I Disci 

1 Chrt Charter I I N800CF I 11 Trip I 1,757.501 I 

Aircraft Charges 1,332.50 

Capitan Daily Rate Charges 350.00 

Ldg/Departure Fees 75.00 

CHARTER TO NEW ORLEANS 

CONFIRMED BY: LAURIE ADAMS 

PASSENGERS: DR. RAMEE AND LORI 

PILOT: ALLEN FORD 

DATE OF CHARTER: 10/25/11 

I Subtotal 

I Total Due 

No returns on electrical parts. No parts exchanges. 

Customers returning parts must pay a 20% restocking charge. 

Terms: Net 10 days 

Printed: 10/27/11 FOR OFFICIAL USE ONLY 

"Public availability to be ,, 

rJ .,I.-:.rminRrl under 5 U.S.C. 552 

RESPONDENT 

EXHIBIT 

·e; 

Unit Price Extended 

1,757.50 1,757.50 

1,757.50 

1,757.50 

I 

I 

Page: 

I 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the above and foregoing Answer of Monroe Air Center was served 

upon counsel for the Administrator by First Class United States Mail, postage prepaid, addressed as 

follows: 

Tim Duff, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

2601 Meacham Blvd. 

Room 663 

Fort Worth, TX 76137 

Respectfully submitted this the /8 ~of July, 2012. 

9