EASTMAN & ASSOCIATES, LLC 

Haslachstrasse 39 

79868 Feldberg-Falkau 

GERMANY 

ATTORNEYS AT LAW 

POST OFFICE Box 180 

CHARLESTON, SOUTH CAROLINA 29402 

USA 

ROBERT G. EASTMAN 

ADMITTED IN DE, FL, GA, :MD, NJ, PA, & SC 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

July 1, 2014 

Re: Part 16 Formal Complaint 

PHONE: {843) 329-9657 

FAX: {843) 723-0005 

robertgeastman@msn.com 

It -1'1-a..S 

~!E~(EO~rE~ 

I JUL 7 20~ PART i 6 DOCKETS 

Skydive Myrtle Beach, Inc. v. Horry County Department of Airports 

and Robinson Aviation, Inc. d/b/a CRE Aircraft Control Tower 

Dear Sir or Madame: 

Skydive Myrtle Beach, Inc. (SDMB) 1 (f/k/a Skydive Myrtle Beach, LLC), 

respectfully requests the Federal Aviation Administration (FAA) to initiate a Formal 

Complaint pursuant to Part 16 of Title 14, Code of Federal Regulations (CFR) for the 

hereinafter stated reasons. 

SUMMARY 

Since Harry County Department of Airports (HCDA) resumed control of Grand 

Strand Airport (GSA), SDMB has: been unable to renegotiate a written long-term lease 

with Harry County; been unable to receive mail and parcels at its business address 

during normal business hours; been continually harassed in its FAA-recognized 

aeronautical activity of non-emergency parachuting or skydiving; had its secure hangar 

broken into by HCDA personnel; received an unreasonable offer to continue occupation 

of its business in exchange for 10-24% of its gross proceeds; been cited by the Deputy 

County Attorney for making repairs to meet fire code compliance; and otherwise treated 

differently from other commercial tenants within HCDA jurisdiction. 

Additionally, under the direction of HCDA, GSA Air Traffic Control (CRE) has 

initiated a reporting process whereby conduct in compliance with Part 105 of Title 14, 

Skydive Myrtle Beach, LLC, (SMB) was reformed into Skydive Myrtle Beach, Inc. a North 

Carolina corporation in January 2014. Member Aaron Holly owned 100% interest of SMB and retains 

100% or all shares of SDMB. 

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CFR is styled as "unsafe" and in violation of Part 139 resulting in the unnecessary 

expenditure of resources of all concerned parties. This conduct by HCDA and its 

private Air Traffic Control has resulted in the expenditure of tens of thousands of dollars 

in legal fees, significant interference with its normal business operations, and loss of 

business revenue by SDMB. 

ISSUE 

It appears that CRE and HCDA are confused about the proper application of 

Parts 105 (Parachute Operations) and 139 (Airports) ofTitle 14, CFR and the difference 

between "pedestrians" and "parachutists" in Parts 139 and 105 respectively. 

Sport parachuting safety and its interaction with related FAA recognized 

aeronautical activities is more fully explained in FAA Advisory Circular (AC) 105-4E 

"Sport Parachuting" (December 4, 2013). FAA states that: 

[w]hile skydivers attempt to land in [designated landing 

zones (LZ or LZs)], at times there may be inadvertant 

landings in other grass or hard-surfaced areas. This could 

include landings on runways, taxiways, and other hardsurfaced areas. Areas such as runways, taxiways, 

clearways, and Obstacle Free Zones (OFZ) are not 

prohibited areas but should not be designated as a primary 

landing area and should be vacated as soon as 

practicable. 

AC 105-4E, ,-r 6{c)(2) (emphasis supplied). 

FAA also requires towered operators to implement policies for vehicles and pedestrians 

from entering into designated areas by such measures as two-way radio communication 

with the Air Traffic Control Tower (ATC). See 14 CFR § 139.329(c). 

HCDA and CRE have a Letter of Agreement (LOA) that requires all pedestrians 

and vehicles to have two-way radios and receive CRE authorization prior to entering 

active areas defined as taxiways and runways at GSA. See Exhibit 2, at 1-3. It appears 

that CRE and HCDA "feel" that Part 139 supersedes Part 105 and FAAs interpretation 

of the regulatory interrelation of sport parachuting operations and airport safety found in 

FAA AC 1 05-4E. This apparent regulatory misinterpretation is the genesis of the 

current issues identified below. 

PART 16 CERTIFICATION 

Pursuant to 14 CFR § 16.21(c), SDMB certifies that it has made substantial and 

reasonable good faith efforts to resolve the issues relating to FAA recognized 

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aeronautical activity, non-emergency parachuting/skydiving, since HCDA resumed 

operations at GSA in August 2013. 

From May 2012 to August 2013 or more than fifteen (15) months and over 2,500 

parachute jumps, SDMB received no complaints from FAA, CRE or HCDA. 2 From 

August 2013, to date (the period since HCDA has resumed control of GSA), SDMB has 

received repeated complaints and been subjected to other intimidation attempts.3 

SDMB has requested multiple meetings concerning GSA active areas with both 

HCDA and CRE officials since HCDA took over GSA management. When SDMB 

requested mediation with HCDA, however, it was unaware of the HCDA/CRE 

partnership that initiated policing "unusual" airport activity and refereeing the boundaries 

of SDMBs primary LZ. Additionally, HCDA continues its refusal to mediate within the 

bounds of South Carolina Rules of Professional Conduct (SCRPC) by demanding an 

expanded scope to include matters of state law before it will discuss issues relating to 

this Part 16 Complaint 4 See Exhibit 3, at 1-14. 

Since HCDA and CRE are working together to report and enforce subjective 

"unusual incidents"5 and CRE will no longer discuss applicable regulations with SDMB, 

there is no other option than for SDMB to refile its complaint for resolution by FAA. 

Without FAA intervention for the reasons enumerated below, there is no reasonable 

prospect for practical, equitable, and timely resolution of the dispute. 

STATEMENT OF FACTS 

In April 2012, SDMB negotiated a lease with Ramp 66, LLC for Hangar 7 at the 

GSA in North Myrtle Beach, SC and was granted exclusive rights to conduct parachute 

operations at CRE for a period of eight (8) years. 

On May 11, 2012, a Letter of Agreement (LOA) was signed by SDMB, HCDA, 

Myrtle Beach Air Traffic Control Tower (MYR) and CRE for conducting non-emergency 

parachute operations. See Exhibit 2 at 19-21. 

2 A SDMB tandem instructor did receive a warning letter for jumping too close to clouds 

while conducting non-emergency parachute operations in the summer of 2012. This included a two-year 

probationary period for the instructor from FAA Flight Standards District Office (FSDO) Colombia, SC. 

3 SDMB has alleged that the conduct of CRE and HCDA has materially interfered with its 

business. See gen. Exhibit 5. 

4 On June 5, 2014, HCDA utilized an alternative legal forum to attempt to have SDMB 

evicted and removed from Hangar 7 in Myrtle Beach Magistrate's Court. See Exhibit 4. 

5 See Exhibit 2, at 10-13 for an explanation and examples of filed reports. 

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On or about July 15, 2013, Ramp 66, LLC represented to SDMB that HCDA 

would require SDMB to enter into a Lease with HCDA with the same or similar term and 

rental cost provisions. 

On August 1, 2013, Ramp 66, LLC sold its leasehold interest to HCDA and 

HCDA resumed control of GSA. 

In August 2013, HCDA informed SDMB that it would have to double its liability of 

"slip and fall" policy coverage to $2,000,000 and pay $1 ,200 per month for Hangar 7 or 

HCDA would not permit SDMB to operate its business on GSA property. See Exhibit 1 

at 14-16. HCDA represented to SDMB that these terms would be presented to Horry 

County Council during the six (6) month temporary period for a long-term lease. 

On October 15, 2013, CRE notified SDMB of a situation whereby a skydiver 

crossed a taxiway rather than staying on the grass as required by FAA regulations. See 

Exhibit 1 at 86. 

On October 27, 2013, a skydiver inadvertently landed on the taxiway adjacent to 

the landing area and was medivacked to the hospital. Information requested from 

HCDA relating to this incident was not released to avoid a potential Health Information 

Privacy Protection Act (HIPPA) and Privacy Act violation. See Exhibit 1, at 99. 

In October 2013, Sgt. Ortiz, a North Myrtle Beach, SC fire inspector, informed 

SDMB that it needed to replace a blank panel in the electrical box, remove extension 

cords, and install electrical receptacles for its office equipment to avoid a fine or 

violation. SDMB requested HCDA, through its manager Tim Jackson, to correct the 

electrical deficiencies. In November, having heard nothing from HDCA relating to the 

electrical issues, SDMB repaired the defective receptacles and conduit with a licensed 

electrical engineer. Due to HCDAs failure to correct the electrical deficiencies, SDMB 

was issued a fine for the violations by the North Myrtle Beach Fire Department and paid 

a $205 dollar fine to the city. See Exhibit 2, at 22-24. 

On November 27, 2013, via certified mail, return receipt requested, HCDA 

alleged that SDMB had an unrestrained dog roaming the "active areas" of the airport 

and had overnight guests in the Hangar in violation of unpublished HCDA policies that 

would result in the revocation of SDMBs operating permit and space use permit, if 

repeated. See Exhibit 2, at 27-28. 

On or about January 6, 2014, SDMB addressed HCDAs concerns and notified 

HCDA that the failure to respond to its letter was due to the fact that it's Manager, Tim 

Jackson had issued instructions to the FBO employees to refuse to accept any and all 

mail and parcels requiring signatures. See Exhibit 1, at 109-110. 

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On January 21, 2014, CRE notified SDMB that it manager "feels" parachuting on 

GSA was unsafe and steps should be taken to improve safety due to the HCDA 

mandated change of parachute Landing Zone (LZ), banner tow, and helicopter guide 

operations for the upcoming season. See Exhibit 1, at 111. 

On January 23, 2014, SDMB requested a meeting with CRE to address its safety 

concerns and discuss operations for the upcoming season. See Exhibit at 113. In its 

answer, CRE indicated that HCDA should also be a party to the discussion. See Exhibit 

1, at 114. 

Three days later, on Sunday, January 26, 2014, responding to an inquiry relating 

to holds, Robinson Aviation, Inc., Manager of Aviation Area II, Richard Allen indicated 

the need to possibly contact the FAA "runway incursion folks again ref. the golf carts 

and etc. today." See Exhibit 1, at 119. 

On February 3, 2014, SDMB again attempted to schedule a meeting with MYR, 

CRE and other interested parties. See Exhibit 1, at 130. Later that same day, SDMB 

was contacted by HCDA about another vehicle/pedestrian complaint by CRE to FAA for 

an active area incursion. See Exhibit 1, at 138. 

On February 5, 2014, SDMB set a meeting for Friday, February 7, 2014, to 

discuss CREs recent complaints to the FAA. See Exhibit 1, at 153. Additionally, SDMB 

responded to HCDAs request for information related to the golf cart and skydiver 

taxiway "incursion". See Exhibit 1, at 158. 

In the February 7, 2014, meeting, CRE advised SDMB about a LOA between 

HCDA and CRE whereby procedures for vehicular and pedestrian entry into "active 

areas" required CRE ground communication protocols. SDMB agreed to comply with 

these provisions, requested a copy of the LOA and implemented internal procedures to 

meet the terms of the HCDA-CRE LOA. See Exhibit 1, at 164-166. SDMB also 

requested repairs to the hangar for electrical, lighting and a street side door access to 

mitigate the deleterious effects of HCDAs refusal to accept parcel deliveries. See 

Exhibit 1, at 167-168. Mr. Jackson objected to the minutes in that "the FBO would not 

sign for deliveries however we will except [sic] any delivery that does not require a 

signature". See Exhibit 1, at 167. Following the meeting, CRE provided SDMB 14 CFR 

§ 139.329 as the authority for its complaints to the FAA and HCDA. See Exhibit 1, at 

192. 

On February 10, 2014, CRE and SDMB included the ground communications in 

part of the draft between SDMB, ZJX, MYR, CRE, and HCDA proposed LOA. See 

Exhibit 1, at 194. 

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On or about February 14, 2014, CRE indicated that it would attend the Safety 

Meeting March 8, 2014, adding "I plan to do all I can to make this work for all of us." 

See Exhibit 1, at 197. 

On February 17, 2014, SDMB attempted to address its maintenance, mail and 

parcel delivery issues with HCDA. See Exhibit 1, at 210. 

On February 19, 2014, HCDA was provided a letter from the Deputy County 

Attorney, Director of Airports, and Airport Manager, at the FAA-sponsored Safety Day. 

The letter identified more than ten (10) "serious" alleged FAA regulatory violations 

relating to skydiving as reported to HCDA by CRE. See Exhibit 3 at pages 54-57. Due 

to these allegations, the Deputy County Attorney indicated that a lease was not 

forthcoming but a new temporary space use could be used as an alternative provided 

SDMB paid the higher of $1,200 per month or 24% of its gross sales. See Exhibit 3, at 

60, 1[4.B. The new terms were non-negotiable and SDMB had seventy-two (72) hours 

to execute or vacate the hangar. See Exhibit 3, at 57. 

On February 19, 2014, a copy of the proposed LOA with the terms between 

SDMB and CRE as agreed was sent to MYR for review and comment. See Exhibit 1, at 

214. On February 24, 2014, skydiving operations at Grand Strand appeared smooth, 

without incident, and a working relationship with ZJX, MYR, CRE and SDMB had been 

developed with a workable LOA involving all parties. See Exhibit 1, at 216-224. (HCDA 

did not participate in the draft LOA discussions although it was invited to do so). 

On February 21, 2012, SDMB addressed each of the allegations in the HCDA 

letter, denied violating any Title 14 regulation, asked for a copy of the HCDA operating 

regulations or authority and requested to work out the issues between HCDA either 

informally or in a court. See Exhibit 3, at 67-78. 

On February 23, 2014, the day after Harry County's seventy-two (72) hour takeit-or-leave-it deadline, without notice, HCDA FBO staff under the direction of manager 

Tim Jackson, delayed fuel service to SDMB at Grand Strand by initially denying 

altogether, and later reconsidering on the phone. See Exhibit 5, at 35 (Affidavit of Ben 

Auker). 

On February 24, 2014, SDMB filed a Formal Complaint with FAA. See Exhibit 3, 

at 50. 

On February 26, 2014, HCDA attorneys informed SDMB that it did not engage in 

"good faith" negotiations prior to filing its Part 16 formal complaint and requested SDMB 

to withdraw its formal complaint. See Exhibit 3, at 48. 

By letter dated February 28, 2014, SDMB related its Part 16 Complaint was 

discrete from its state court complaint and attached a copy of its state complaint as a 

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courtesy. See Exhibit 3, at 46. SDMB also indicated its willingness to resolve the 

matters but refused to withdraw its Part 16 complaint. /d. 

On March 4, 2014, HCDA moved to dismiss the Part 16 Complaint without 

prejudice. See Exhibit 3, at 44. 

On March 6, 2014, SDMB attempted to amend its Part 16 Complaint. See 

Exhibit 3, at 39. 

On March 7, 2014, HCDA raised SDMBs failure to attach supporting documents 

and moved to dismiss. See Exhibit 3, at 38. 

On March 18, 2014, FAA dismissed SDMBs Part 16 Complaint for 

incompleteness. See Exhibit 3, at 35. 

On March 20, 2014, HCDA issued a policy letter for tenant mail and parcel 

delivery for tenants at GSA and instituted Driver Training. See Exhibit 3, at 34. 

On March 25, 2014, and again on March 27, 2014, SDMB staff attempted to 

attend the required driver training but no HCDA representative showed up. HCDA 

Manager Tim Jackson and Lineman Jack Teal personally came to Hangar 7 to 

apologize for the course failure. The driving course was rescheduled on March 28, 

2014. See Exhibit 1, at 228. The class was again cancelled and has not been 

rescheduled to date. 

On April 3, 2014, HCDA dumped approximately six (6) yards of peat moss on the 

SDMB staff parking lot preventing access to three (3) staff parking spaces. See Exhibit 

1, at 235. 

On April 7, 2014, through its attorneys, HCDA offered its version of "good faith" 

negotiations- reducing the monthly lease percentage of gross from 24% to 10%. HCDA 

also indicated that eviction proceedings would be initiated if this was not accepted by 

SDMB. See Exhibit 3, at 23. 

On April 12, 2014, a heated email exchange between CRE and SDMB ended 

with a threat to file another FAA complaint and a promise to forward all future CRE 

complaints to the FSDO and HCDA. See Exhibit 1, at 241. 

On April 18, 2014, SDMB again attempted to negotiate terms for leasing Hangar 

7, and again requested a meeting to finalize the LOA for non-emergency parachute 

operations at GSA. See Exhibit 3, at 21-22. 

On April 28, 2014, HCDA issued a Notice of Termination unless the terms in its 

April 7, 2014, correspondence were agreed to. See Exhibit 3, at 19. The letter further 

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stated, "SDMB may not base its aircraft or its skydiving operations at CRE. However, 

as long as SDMB operates in accordance with all applicable laws, including the letter of 

agreement, the [FAA], the CRE tower and HCDA, SDMB may continue to use the 

aeronautical facilities at CRE, including the landing zone as a transient operator. 

However, without a valid Space Use Permit, SDMB must vacate Hangar No. 7 and may 

not base its aircraft at CRE." /d. 

On May 10, 2014, CRE notified SDMB it was forwarding a complaint for a 

taxiway incursion. See Exhibit 1, at 243. 

On May 19, 2014, HCDA requested information relating to an FAA "Letter of 

Investigation triggered by skydivers operating on an active taxiway on May 10." See 

Exhibit 1, at 245-256. 

On May 22, 2014, SDMB gave a counter offer to HCDAs Notice of Termination 

relating to Hangar No. 7 and again requested a meeting to finalize the LOA. See 

Exhibit 3, at 16-18. 

On May 24, 2014, CRE reported a skydiver crossing the runway. See Exhibit 1, 

at 257. 

On May 28, 2014, HCDA rejected SDMBs counter offer and demanded SDMB to 

vacate Hangar No.7 and remove its aircraft from CRE. See Exhibit 3, at 14-15. 

On May 29, 2014, SDMB offered to mediate with HCDA in an attempt to resolve 

the issues. See Exhibit 3, at 19. 

On May 30, 2014, HCDA conditionally accepted SDMBs offer to mediate. See 

Exhibit 3, at 10. 

On June 2, 2014, SDMB countered HCDAs conditional offer to mediate in order 

to meet ethical requirements relating to South Carolina state law. See Exhibit 3, at 8-9. 

On June 5, 2014, HCDA conditionally accepted SDMBs offer to mediate with 

several modifications and filed an Application for Eviction in Myrtle Beach Magistrate's 

Court. See Exhibit 3, at 5-6; Exhibit 2. 

On June 10, 2014, MYR invited all interested parties to discuss the LOA. See 

Exhibit 1, at 272. Although the proposed LOA included penalty and reporting provisions 

that were objectionable to SDMB, a meeting was set for June 24, 2014. See Exhibit 1, 

at 273-298. 

On June 18, 2014, SDMB offered to mediate but conditioned its acceptance on 

compliance with SCRPC Rule 4.2 necessitating the attendance or written consent of all 

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represented parties in order to discuss matters relating to SC state law. See Exhibit 3, 

at 4. 

On June 24, 2014, HCDA, ZJX (via phone), MYR, CRE and SDMB met at MYR 

to discuss the LOA. The meeting did not finalize the LOA, and it was agreed that 

operations would continue under the terms of the existing LOA until matter could be 

finalized. HCDA could not provide a return date. Incident reporting was discussed, and 

for the first time HCDA revealed that CRE was reporting all skydiver taxiway crossings 

to HCDA at their direction. 

On June 27, 2014, SDMB requested regulatory authority requiring CRE to report 

skydivers on active areas to FAA and requested a discussion about Title 14, Part 105. 

SDMB was referred to FAA. See Exhibit 1, at 322. 

On or about June 27, 2014, an unidentified photographer6 was observed taking 

pictures of Hangar 7 from the Grand Strand Airport Parking lot. See Exhibit 2, at 15. 

On June 27, 2014, at 1546 on a Friday, counsel for HCDA rejected SDMBs offer 

to mediate by its failure to offer assurances that counsel for all parties would attend or 

provide written consent to discuss matters of state law. See Exhibit 2, at 14; Exhibit 3, 

at 1. 

On June 27, 2014, HCDA emailed SDMB relating its safety concerns from CRE 

and FAA with reports that were attached. See Exhibit 2, at 11. The FAA reports were 

styled "Horry County Department of Airports Unusual Activity Report" and filed by CRE 

to HCDA employees Stan Cox and Edward Dingley. See Exhibit 2, at 10-13. 

On Sunday, June 29, 2014, HCDA employee Ed Dingley repeatedly drove to the 

LZ in a golf cart to observe each parachute drop conducted during the day. See Exhibit 

2, at 17-18. 

CONCLUSION 

Since it appears that HCDA and CRE are either unable or unwilling to 

differentiate between Part 139 "pedestrian" activity and Part 105 "parachutist" activity in 

Title 14 as it applies to legitimate aeronautical practices delineated in Parts1 05, AC 105-

4E and set forth above, SDMB has no alternative other than to see relief through FAAs 

Part 16 formal complaint process. 

6 The photographer has been identified by SDMB staff as HCDA Operations Supervisor 

Edward Dingley. On Friday when questioned by SDMB staff after being observed taking pictures from a 

concealed location in the parking lot, Mr Dingley stated that he was a taking pictures as was his hobby 

when on vacation or words to that effect. 

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The current arbitrary attempts to restrict the landing area and the continued 

practice of reporting authorized parachute operations (landings) as violations pursuant 

to Part 139, under the sheepskin of "safety concerns" is unreasonably restrictive and 

discriminatory as applied to an FAA recognized aeronautical activity. Safety concerns 

have been continually improved and updated with national input by experts from the 

parachute industry and FAA and are addressed in AC 105-4E. The purpose of this AC 

is to "improve sport parachuting safety and disseminat[ion of] information to assist all 

parties associated with sport parachuting." See AC 1 05-4E, ~ 1. 

Thank you for your attention to this matter. I look forward to hearing from you in 

the near future. Should you have any questions, please do not hesitate to contact me. 

Encl.: Exhibit 1 Emails (323 pages) 

Exhibit 2 Documents (28 pages) 

Very truly yours, 

/) UJ(_} . 

ruh-vf; r {f;d~ Robert G. Eastman 

Exhibit 3 Part 16 Correspondence {88 pages) 

Exhibit 4 SC Magistrate Court Pleadings (15 pages) 

Exhibit 5 SC Court of Common Pleas Pleadings (36 pages) 

cc: Aaron Holly (via email) 

RGE/fub 

Robert Varnado, Esq. (via email) 

Samuel F. Arthur, Ill, Esq. (via email) 

David Bannard, Esq. (via email) 

Mike Battle, Esq. (by hand) 

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CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing Complaint on the 

following persons at the following addresses and emails by first class US Postal Service 

and electronically. 

9-AWA-AGC-Part 16@faa.gov 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket 

Clerk AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Richard.allen@rvainc.com 

Robinson Aviation, Inc. 

1601 NW Expressway 

Oklahoma City, OK 73118-1435 

Dated this 1st day of July, 2014. 

Robert G. Eastman, Esq. 

For Skydive Myrtle Beach, Inc. 

140627. sdmb. hcda. faa. com pi aint 

Aponep@HorryCounty.org 

Pat Apone, Director 

Harry County Dep't of Airports (HCDA) 

1100 Jetport Road 

Myrtle Beach, SC 29577 

dbannard@foley.com 

David Banner, Esquire 

Jeffrey Blease, Esquire 

Jaclyn Piltch 

Foley & Lardner LLP 

111 Huntington Avenue 

Boston MA 02199 

Counsel for HCDA