R D Richard D. Monkman 

Rebecca A. Patterson 

Sonosky, Chambers, Sachse, 

Miller & Munson, LLP 

900 West Fifth Avenue, Suite 700 

Anchorage, Alaska 99501 

Telephone: (907) 258-6377 

Facsimile: (907) 272-8332 

AUG 1 7 2015 

HEARING DOCKET 

In the Matter of: 

... u.S.DEPAR-TMEN+OFTRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

) 

) Case No. 2015NM730027 

Arctic Slope Native Association, Ltd. ) Docket No. FAA-2015-2437 

__________________________ ) 

ANSWER TO COMPLAINT 

Respondent Arctic Slope Native Association, Ltd. ("ASNA") through counsel, Richard 

D. Monkman and Rebecca A. Patterson and the firm of Sonosky, Chambers, Sachse, Miller & 

Munson, LLP, answers the Complaint as follows: 

I. 

Admit the first sentence. Admit the second sentence to the extent it is limited to the May 

4, 2015 Notice. Respondent did send a response to the FAA regarding this incident on April15, 

2015. Admit the third and fourth sentences. 

II. 

l. Admit in part, and deny in part. Respondent offered a 24-piece shipment on 

March 23, 2015 to Alaska Airlines. Except as admitted, deny. 

2. The Air Waybill speaks for itself and no response is required. 

3. Deny. The Alaska Airlines agent filled out the Waybill and selected the 

"Shelving Dry Goods" description. 

4. Admit. 

ANSWER TO COMPLAINT Page 1 of 3 

In re Arctic Slope Native Association, Ltd., Docket No. FAA-2015-2437 
5. Paragraph 5 is a legal conclusion that requires no response, but should a response 

be required, then it is denied. 

6. Admit. 

7. Admit that no emergency response telephone number was provided on the 

shipping paper. Whether any telephone number provided meets the requirements of§ 172.604 is 

a legal conclusion that requires no response. 

8. The Air Waybill speaks for itself and no response is required. 

9. The Air Waybill speaks for itself and no response is required. 

10. The Air Waybill speaks for itself and no response is required. Whether any 

certification or declaration was required is a legal conclusion that requires no response. 

11. Admit that Respondent did not provide two copies of a certification. Whether any 

certification was required is a legal conclusion that requires no response. 

12. Admit. 

13. Admit the package was not marked. 

14. Admit. 

15. Admit. 

III. 

Paragraph I, subsections (a) through (m) state legal conclusions that require no response. 

To the extent a response is required, these subsections are denied. 

IV. 

I. 49 U.S.C. § 5123 speaks for itself and no response is required. Deny that 

Respondent is liable for a civil penalty for each violation of the regulations, as Respondent did 

not knowingly violate these regulations as required by §5123(a)(l) for imposition of a penalty. 

ANSWER TO COMPLAINT Page 2 of3 

In re Arctic Slope Native Association, Ltd., Docket No. FAA-2015-2437 
2. This is the Federal Aviation Administration's legal conclusion, to which no 

response is required. To the extent a response is required, it is denied. 

DATED this 301

h day of July, 2015July, 2015. 

SONOSKY, CHAMBERS, SACHSE 

MILLER & MUNSON, LLP 

By:··~'/;{_)_f/2/{ 

&"'RICHARD 

~ 

D. MONKMAN 

Alaska Bar No. 8011101 

REBECCA A. PATTERSON 

Alaska Bar No. 1305028 

Attorneys for Respondent 

CERTIFICATE OF SERVICE 

I hereby certify that I delivered, or caused to be delivered, a true 

and correct copy of the foregoing ANSWER TO COMPLAINT 

by mail upon the following this 30"' day of Jnly, 2015: 

Attention: Hearing Docket Clerk (Original + 1) 

AGC-430, Wilbur Wright Building, Suite 2Wl000 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

The Honorable Richard C. Goodwin (Copy) 

Service via email: Richard. Goodwin @dot.gov 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

Howard L. Martin, Howard.Martin@faa.gov 

Glenn H. Brown, Glenn.Brown@faa.gov 

Office of the Regional Counsel 

222 West 7th Avenue, #14 

Anchorage, AK 99513 

ANSWER TO COMPLAINT 

In re Arctic Slope Native Association, Ltd., Docket No. FAA-2015-2437 

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