O'Melveny & Myers llp - smgov.net · commercially-infeasible fuels and by offering substandard...
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o O'Melveny & Myers llp BEIJING BRUSSELS CENTURY CUT HONG KONG LONDON NEWPORT BEACH NEW YORK 400 South Hope Street Los Angeles, California 90071-2899 TELEPHONE (213) 43O-60OO FACSIMILE (213) 430-6407 www.omm.com RECEIVED September 13, 2016 SEP 1 3 2016 Office of the Chief Counsel PART 16 DOCKETS Attention: FAA Part 16 Airport Proceedings Docket AGC-600 Federal Aviation Administration 800 Independence Ave., S.W. Washington, D.C. 20591 Re: PART 16 COMPLAINT SAN FRANCISCO SEOUL SHANGHAI SILICON VALLEY SINGAPORE TOKYO WASHINGTON, D C. OUR FILE NUMBER 530,799-029 WRITER’S DIRECT DIAL (213) 430-6670 WRITER’S E-MAIL ADDRESS [email protected] Atlantic Aviation FBO, Inc. v. City of Santa Monica, California Dear Sir or Madam: Pursuant to 14 C.F.R. § 16.23, Atlantic Aviation FBO, Inc. (“Complainant”) brings this complaint against the City of Santa Monica, California (the “City”), which is the owner, operator, and sponsor of Santa Monica Municipal Airport (“SMO” or the “Airport”). Given the nature of the violations herein alleged and the urgency with which corrective action is needed, Complainant respectfully requests that the Director issue an order expediting the handling of this matter. See 14 C.F.R. § 16.11(b). This complaint is based on the City’s continuing failure and refusal to adhere to its federal obligations, and on the specific actions and conduct alleged hereafter. The City’s objectives are now crystal clear: Fight the FAA for “local control” of SMO in the courts and, in the interim, undertake any measure at its disposal to severely curtail or discourage air traffic at SMO. If the City is permitted to take over Complainant’s fixed base operation (“FBO”) at SMO, as it has resolved to do, it will do all it can to minimize air traffic by limiting fuel sales to commercially-infeasible fuels and by offering substandard services and inconvenient hours. All communications with respect to this complaint should be addressed to Tad Allan, O’Melveny & Myers LLP, 400 S. Hope St., Los Angeles, CA 90071; (213) 430-6000; [email protected]. COMPLAINANT 1. Complainant has operated a full service FBO at SMO since 2007, assuming a lease that has been in effect, under several ownerships, since approximately 1986. Ex. A
Transcript of O'Melveny & Myers llp - smgov.net · commercially-infeasible fuels and by offering substandard...
oO'Melveny & Myers llp
BEIJING
BRUSSELS
CENTURY CUT
HONG KONG
LONDON
NEWPORT BEACH
NEW YORK
400 South Hope Street Los Angeles, California 90071-2899
TELEPHONE (213) 43O-60OO FACSIMILE (213) 430-6407
www.omm.com
RECEIVED
September 13, 2016SEP 1 3 2016
Office of the Chief Counsel PART 16 DOCKETSAttention: FAA Part 16 Airport Proceedings DocketAGC-600Federal Aviation Administration 800 Independence Ave., S.W.Washington, D.C. 20591
Re: PART 16 COMPLAINT
SAN FRANCISCO
SEOUL
SHANGHAI
SILICON VALLEY
SINGAPORE
TOKYO
WASHINGTON, D C.
OUR FILE NUMBER 530,799-029
WRITER’S DIRECT DIAL (213) 430-6670
WRITER’S E-MAIL [email protected]
Atlantic Aviation FBO, Inc. v. City of Santa Monica, California
Dear Sir or Madam:
Pursuant to 14 C.F.R. § 16.23, Atlantic Aviation FBO, Inc. (“Complainant”) brings this complaint against the City of Santa Monica, California (the “City”), which is the owner, operator, and sponsor of Santa Monica Municipal Airport (“SMO” or the “Airport”). Given the nature of the violations herein alleged and the urgency with which corrective action is needed, Complainant respectfully requests that the Director issue an order expediting the handling of this matter. See 14 C.F.R. § 16.11(b).
This complaint is based on the City’s continuing failure and refusal to adhere to its federal obligations, and on the specific actions and conduct alleged hereafter. The City’s objectives are now crystal clear: Fight the FAA for “local control” of SMO in the courts and, in the interim, undertake any measure at its disposal to severely curtail or discourage air traffic at SMO. If the City is permitted to take over Complainant’s fixed base operation (“FBO”) at SMO, as it has resolved to do, it will do all it can to minimize air traffic by limiting fuel sales to commercially-infeasible fuels and by offering substandard services and inconvenient hours.
All communications with respect to this complaint should be addressed to Tad Allan, O’Melveny & Myers LLP, 400 S. Hope St., Los Angeles, CA 90071; (213) 430-6000; [email protected].
COMPLAINANT
1. Complainant has operated a full service FBO at SMO since 2007, assuming a lease that has been in effect, under several ownerships, since approximately 1986. Ex. A
