RECEIVED 

JUL 15 2015 

PI(Rfi~OOCKF!'tS::'flY A !TORNEY 

602 S. Main Street • Joplin, MO 64801 • (417) 624-0820 

Fax Number 417-625-4713 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Ave., SW 

Washington, D.C., 20591 

July 6, 2015 

Peter C. Edwards- City Attorney Ext. 225 

Jordan Paul- Assistant City Attorney Ext. 227 

ATTN: FAA Part -16 Airport Proceedings Docket, AGC-61 0 

RE: In re the Complaint ofR.L.S. Rental Company, Inc., d/b/a/ Mizzou Aviation v. 

Joplin Regional Airport, City of Joplin, Missouri; Docket No. 16-13-06 

Gentlemen/Madame: 

Please fmd enclosed our Second Motion to Supplement pursuant to 14 CFR 16.19. The information 

contained herein was not available at the time the pleadings closed. We have included as an exhibit 

a copy of Alpha Air's Part 141 certificate. If you have any questions, please feel free to contact us. 

CC: Shelley A. Ewalt 

McBreen & Kopko 

500 North Broadway, Suite 129 

Jericho, New York 11753 

Very truly yours, 

cyY> 

Jordan L. Paul 

Assistant City Attorney 

Office of the City Attorney 

City of Joplin 

602 S. Main Street 

Joplin, MO 64801 

( 417) 624-0820 X227 

JPaul@JoplinMo.org 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

In re the Complaint of 

R.L.S. RENTAL COMPANY, INC., 

D/B/A/MIZZOU AVIATION 

Complainant, 

-againstJOPLIN REGIONAL AIRPORT, 

CITY OF JOPLIN, MISSOURI 

Respondent. 

Pursuant to Part 16 of the 

Federal Aviation Regulations 

Docket No. 16-13-06 

SECOND MOTION TO SUPPLEMENT 

RECEIVED 

JUL 1 5 2015 

PART Hl DOCKETS 

COMES NOW THE RESPONDENT, Joplin Regional Airport, City of Joplin, Missouri 

("Respondent" or "The City of Joplin"), and files this. Motion to Supplement. Pursuant to 14 CFR 

16.19, the Respondent may file an application for an order or ruling not otherwise specifically 

provided for by the Part 16 rules of procedure. Respondent requests that the FAA consider certain 

material information that is relevant to this Part 16 preceding which only came to light after the 

deadline for submission. In support thereof, the City of Joplin states: 

l. Alpha Air obtained its Part 141 certificate on or about June 12,2015 (See Alpha 

Air's Part 141 certificate, attached as Exhibit A). 

2. Respondent is informed and believes, and upon such information and belief 

alleges that Alpha Air intends to apply for its Part 145 certificate. 

1 
RELIEF SOUGHT 

Respondent requests the FAA admit the material information contained in this Motion to 

its consideration of this Part 16 proceeding. Further, Respondent requests all other timely 

determinations, orders, and relief as requests and set forth in its prior submissions. 

Dated: July 7, 2015 

Joplin, Missouri 

2 

Respectfully submitted, 

Jordan L. Paul 

Assistant City Attorney 

Office of the City Attorney 

City of Joplin 

602 S. Main Street 

Joplin, MO 64801 

( 417) 624-0820 X227 

JPaul@JoplinMo.org 
Certificate of Service 

I hereby certify that I have today, the 6th day of July, 2015, caused the foregoiug Motion 

to Supplement to be served by certified delivery service on the following: 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Ave., SW. 

Washiugton, D.C., 20591 

Attention: FAA Part 16 Airport Proceediugs Docket, AGC-610 

Shelley A. Ewalt 

McBreen & Kopko 

500 North Broadway, Suite 129 

Jericho, New York 11753 

(703) 399-6078 (phone) 

(516) 364-0612 (fax) 

Attorney for Complainant 

Jordan L. Paul 

3 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

AIR AGENCY CERTIFICATE 

Number 8JAS435N 

This certificate is issued to 

Alpha Air Center., LLC 

whose business address is 

5509 N. Dennis Weaver Dr. 

Webb City, MO 64870 

uponfinding that its organization complies in all respects with the 

requirements oft he Federal Aviation Regulations relating to the 

establishment of an Air Agency, and is empowered to operate an 

approved provisional pilot school with the following ratings: 

Private Pilot Certification Course 

This certificate, unless canceled, suspended, or revoked, shall 

continue in effect until June 3 0, 2 017. 

Date Issued: Jl,llle 12,2015 

By Direction of the Administr or 

T~...td:;..-t/'~1./ Manager, Kansas City FSDO 

CE05, Kansas City, MO 

1'his Cerlificate is. nol Transferable AND ANY MAJOR _CHANGE"ID THE BASIC FAClLlTIES. OR IN TilE LOCA:TlON THEREOF, SHALL BE lMM:EDIATELY 

REPORTED TO THE APPROPJUATE REGIONAL OFF1CE OF THE FEDERAL AVJATION ADMINISTRATiON 

Any alteratitm of-this cenifica(e-is punishable by~ litie of not excee<Jing $1,000, or imprisonment not e,'{ceeding 3 years, or both 

FAA Form 8000-4 (l-67)_SUPERSEDES FAA FORM 390. EleCtronically Generated 
'" '- .:_ 

City J ·I. I~ A of IJ~ 

,lH,LrlJtt1 h ? 

OFFICE OF CITY ATTORNEY 

602 S. Main St. • Joplin, MO 64801 

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Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Ave., SW 

Washington, D.C., 20591 

ATTN: FAA Part 16 Airport Proceedings Docket, 

AGC-610 

U_S_ \ 

ZiP 64

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