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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 ADDRESStallan@omm.com

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; tallan@omm.com.

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