OFFICE OF THE CITY ATTORNEY 

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

FaX Number 417-62S-4713 

~LE~[e~\W!E~ 

AUG 12 2014 

PART 16 DOCKETS 

Offi~e of the Chief Cmmse1 

Federal Aviation Administration 

800 Independence Ave., SW 

Washington, D.C., 20591 

August 4, 2014 

Peter C. Edwards -Interim City Attorney Ext. 225 

Jordan Paul, Assistant City Attorney Ext. 227 

ATTN: FAA Part 16 Airport Proceedings Docket, AGC-610 

RE: In re the Complaint of R.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 find enclosed our Motion to Supplement pursuant to 14 CFR 16.19. The information 

contained herein was not available at the time the pleadings closed. If you have any questions, 

please feel free to contact us. 

Very truly yours, 

o-u 

Jordan Lowther Paul, 

Assistant City Attorney 

Office of the City Attorney 

602 S. Main Street 

Joplin, MO 64801 

( 417) 624-0820 

JPaul@JoplinMo.org 
CC: Shelley A. Ewalt 

McBreen & Kopko 

500 North Broadway, Suite 129 

Jericho, New York 11753 
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 

MOTION TO SUPPLEMENT 

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: 

1. A significant portion of Complainant's "Motion to Admit Material Facts" filed on 

or about April9, 2014, focuses on Alpha Air's alleged failure to timely apply for relevant 

certifications. 

2. Alpha Air made Application for Pilot School Certification (FAA Form 8420 

1 
8) on or about July 7, 2014. (See letter from Tiffany Chitwood, Manager, Kansas City Flight 

Standards District Office to Joshua Crooker, General Manager, Alpha Air Center, attached as 

Exhibit A.) 

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: August 4, 2014 

Joplin, Missouri 

2 

Respectfully submitted, 

Jordan Lowther Paul 

Assistant City Attorney 

City of Joplin 

Attorney for Respondent 

602 S. Main Street 

Joplin, MO 64801 

( 417) 624-0820 (phone) 

(417) 625-4713 (fax 
Certificate of Service 

I hereby certifY that I have today, the 4th day of August, 2014, caused the foregoing 

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. 

Washington, D.C., 20591 

Attention: FAA Part 16 Airport Proceedings 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 Lowther Paul 

3 
U,S. Deportment 

of Transportation 

Federal Aviation 

Administration 

'JUL 2 fi ZD1~ 

Joshua Crooker 

Genenil Manager 

Alpha Air Center, LLC 

5509 N_ De1mis Weaver Drive 

Webb City, MO 64870 

Dear Mr. Crooker: 

Kansas City Flight Standards District Office 901 Locust, Room 403 

Kansas City, MO 64106 

(816) 329-4000 (800) 519-3269 

FAX (816) 329-4010 

EXHIBIT 1--4--

Timnk you for the recent Application for Pilot School Certification (FAA Fom1 8420-8), 

dated July 7, 2014, and your letter of intent you submitted to the Federal Aviation 

Administration, Kansas City Flight Standards District Office. 

We are currently evaluating our resources in order to determine if and/or when we can 

support your application for certification. We will respond to you within 30 days from the 

date of tllis letter to inform you of our resource evaluation results. 

In the meantime, thank you for your patience and cooperation. If you have any questions or 

we can be of any fUrther assistance, please do not hesitate to contact us at (816) 329-4000 or 

(800) 519-3269. Our office hours are 7:30a.m. to 4:00p.m., Monday through Friday, 

except holidays. 

Sincere! v, ., ~ r··---- / 1 1 'i 

~ ~ " \ \ I I/' t i 

,.r;r J ///12 i' I/ It/ ' fJ'! ' c YLt 1; 1/;(5;::,._ / , - v t<{/t ."'· M J F /'L-·.-'.1' ~1/ 7 l ' 

l (J) .l '-""' L,.Y:--"' ~ { Tiffany J. Chitwem(\ 

Manager, Kansas City Flight Standards 

District Office