# R 

# D Richard D. Monkman RebeccaA. Patterson Sonosky, Chambers, Sachse,

Miller & Munson, LLP 900 WestFifth Avenue, Suite 700 Anchorage, Alaska99501 Telephone: (907) 258-6377 Facsimile: (907) 272-8332 

## AUG 17 2015 

## HEARING DOCKET

Inthe Matter of: ...u.S.DEPAR-TMEN+OFTRANSPORTATION FEDERALAVIATION ADMINISTRATION ) ) Case No. 2015NM730027 Arctic Slope Native Association, Ltd. ) DocketNo. 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 aresponse to the FAAregarding 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 AlaskaAirlines. Except as admitted, deny. 2. The AirWaybill speaks for itselfand no response is required. 3. Deny. The Alaska Airlines agent filled out the Waybill and selected the "ShelvingDry Goods" description. 4. Admit. ANSWERTO COMPLAINT Page 1of3 In re Arctic SlopeNativeAssociation, Ltd., DocketNo. FAA-2015-24375. Paragraph 5 is a legal conclusion that requires no response, but should a response berequired, 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 AirWaybill speaks for itselfand no response is required. 9. The AirWaybill speaks for itselfand no response is required. 10. The Air Waybill speaks for itself and no response is required. Whether any certification or declarationwas required is a legal conclusion thatrequires no response. 11. Admit that Respondent did notprovide two copies ofa certification. Whether any certification was required is a legal conclusion that requires no response. 12. Admit. 13. Admit thepackage was not marked. 14. Admit. 15. Admit. III. Paragraph I, subsections (a) through (m) state legal conclusions that require no response. To the extent aresponse 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 requiredby §5123(a)(l) for imposition ofa penalty.

ANSWERTO COMPLAINT Page 2 of3 In re Arctic SlopeNativeAssociation, Ltd., Docket No. FAA-2015-24372. This is the Federal Aviation Administration's legal conclusion, to which no response is required. To the extent a response is required, itis denied. DATED this 301 h day ofJuly, 2015July, 2015. SONOSKY, CHAMBERS, SACHSE

MILLER & MUNSON, LLP



### By:··~'/;{_)_f/2/{ **~** &"'RICHARD D. MONKMAN AlaskaBarNo. 8011101 REBECCA A. PATTERSON AlaskaBarNo. 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 ofJnly, 2015: Attention: HearingDocket Clerk (Original + 1) AGC-430, Wilbur WrightBuilding, Suite 2Wl000 Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 The Honorable Richard C. Goodwin (Copy) Service via email: Richard.Goodwin @dot.gov Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 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 ofthe Regional Counsel 222 West 7th Avenue,#14 Anchorage, AK 99513

ANSWER TO COMPLAINT In reArctic Slope NativeAssociation, Ltd., DocketNo. FAA-2015-2437 Page 3 of3