UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C. RECEIVED HTX HELICOPTERS, LLC, JUL 28 2021 D/B/A HELIBLOCK, Complainant, PART 16 DOCKETS V. FAA Docket No. 16-21-10 RIIHIODE ISLAND AIRPORT CORPORATION, Respondent. RESPONDENT RHODE ISLAND AIRPORT CORPORATION'S ANSWER TO THE COMPLAINT Designation of persons to receive service for Rhode Island Airport Corporation: W. Eric Pilsk
[email protected] Adam Gerchick agerchickkaplankirsch.com KAPLAN KIRSCH & ROCKWELL LLP 1634 I (Eye) Street, NW, Suite 300 Washington, D.C. 20006 Telephone: (202) 955-5600 David Y. Bannard
[email protected] KAPLAN KIRSCH & ROCKWELL LLP 101 Federal Street, Suite 1900 Boston, MA 02110 Telephone: (617) 329-4687 1 ANSWER Respondent Rhode Island Airport Corporation ("RIAC" or "Respondent"), by and through its undersigned counsel, pursuant to 14 C.F.R. § 16.23(h), hereby responds to the allegations ofthe Complaint filed by HTX Helicopters, LLC, d/b/a HeliBlock ("HeliBlock" or "Complainant") as set forth in the numbered paragraphs below. RIAC denies all allegations contained in the Complaint except to the extent that such allegations are specifically admitted in this Answer. In further support of its Answer, and pursuant to 14 C.F.R. § 16.23(i), RIAC submits a Memorandum Of Law In Support Of Its Answer To The Complaint, filed with this Answer and herein incorporated by reference, with a concise statement ofthe facts upon which RIAC relies and a discussion of the legal principles demonstrating that the Complaint should be dismissed in its entirety and RIAC found to be in compliance with its federal grant assurances.