Protecting Federal Investments at General Aviation Airports

Jan. 6, 2025
Discover how general aviation airports can navigate tight budgets, federal compliance requirements, and local encroachment challenges to maintain their vital role in supporting economic growth and critical public services
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General aviation airports are essential components of the national air transportation system, fueling economic growth and supporting critical firefighting, air ambulance, cargo, humanitarian and public service missions that benefit communities.

These airports often operate on tight budgets, making federal grants a lifeline for maintaining safe and functional facilities. Airport Improvement Program (AIP) grants administered by the Federal Aviation Administration (FAA) provide essential funding for runway and taxiway maintenance, navigational aids and lighting, safety and security enhancements, environmental sustainability and other projects. These grant dollars are raised through aviation taxes and other industry sources that are not associated with general fund monies.

Compliance Requirements

According to the Airport Cooperative Research Program,  over 3,000 public-use airports  in the United States have received an AIP grant from the FAA for airport planning or development purposes. Many of these airports receive this funding on an annual basis.

When an airport sponsor accepts a federal AIP grant, it also accepts the obligation to comply with certain requirements that must be met under its terms. There are 40 numbered requirements, called grant assurances, covering a broad range of topics. They range from how to use airport revenue properly, to how to maintain and operate an airport safely. For example, the most recent grant assurance introduced requires airport sponsors to permit the sale of 100-octane low lead (100LL) avgas until certain conditions are met.  

Many of the grant assurances themselves contain multiple requirements, making compliance challenging for many airports, especially those with minimal staff or resources. The number of grant assurances an airport sponsor must comply with, as well as the duration of time during which it must comply, depend on: 1) whether the grant is a development or planning grant and 2) the useful life of the project being funded.

The maximum duration of the obligation for almost all grant assurances is 20 years, although the duration can be shorter under specific circumstances. The three exceptions are Grant Assurance 23, Exclusive Rights; Grant Assurance 25, Airport Revenues; and Grant Assurance 30, Civil Rights, which create perpetual obligations. Also, if an airport receives an AIP grant for land acquisition, the duration of the obligation to utilize not just that land, but the entire airport, for aeronautical purposes is perpetual.

The FAA’s compliance program is designed to ensure airport sponsors take any necessary actions to comply with the terms of their grant agreements. When evidence of noncompliance is found, the FAA typically requires the airport sponsor to submit a corrective action plan outlining specific steps to resolve the discrepancy within a reasonable period of time. 

If an airport sponsor does not satisfactorily resolve compliance discrepancies within a reasonable period of time, the FAA can withhold consideration of future funding. In rare cases, the FAA may take other enforcement actions, such as collecting fines when evidence of revenue diversion or misuse of grant funds is found.  

Additionally, if an individual or entity believes an airport sponsor is not complying with the terms of its grant agreement, they may file a complaint with the FAA under 14 CFR Part 13 or 14 CFR Part 16. In simple terms, a Part 13 complaint is a relatively simple, informal process handled at the regional level, while a Part 16 complaint is a more complex, formal process handled at the national level.

Threats from Local Encroachment

One of the most pressing issues facing general aviation airports is local encroachment, which occurs when residential, commercial or industrial developments expand near airport boundaries. For example, population growth and pressure for housing construction around airports have contributed to increased community concerns about the negative impacts of aircraft noise and emissions.

In the current situation, a growing number of legislators are attempting to implement aggressive operational, access and land use restrictions for airports at the local level. These proposed measures not only threaten to violate the preemptive authority of the FAA and jeopardize an airport’s grant funding, they may weaken the economic base of communities and endanger airport jobs and businesses.

A closely related issue is the challenge of zoning conflicts. Local city planning decisions can lead to the establishment of incompatible land uses near airports, such as schools, hospitals or high-density housing. An airport’s proximity to incompatible land uses may also increase the risk of wildlife hazards and obstructions that compromise aviation safety.

The FAA currently lacks authority to require that city zoning and planning ordinances prevent incompatible developments near airports. This legislative gap makes it challenging to address encroachment issues, leaving airports vulnerable to land use decisions that compromise their safety, efficiency and viability. When encroachment occurs, airports face future threats.

20-Year Lifespan Requirement

While the maximum duration of time during which an airport sponsor must comply with most grant assurances is 20 years, this warrants additional discussion. Above all, the FAA’s timeline is rooted in the expectation that federally funded improvements—such as runways, taxiways or lighting systems—will provide long-term value and ensure the responsible use of public funds.

It is important to consider that infrastructure investments are capital-intensive, with costs often spanning millions of dollars. While a 20-year requirement that was implemented in the policy decades ago may align with accounting practices for asset depreciation, it may not provide enough time to fully amortize the high construction costs of today’s airport projects. Increasing the grant obligation window to a project lifespan of 25 or 30 years could reduce the frequency of large-scale reconstruction projects and spread costs over an extended period – improving return on investment.

For example, a runway built to last 30 years with minimal maintenance could cost less in the long term than one requiring significant repairs every 10-15 years designed to not exceed the 20-year standard. Reducing the frequency of construction activities also has environmental benefits, such as less use of heavy machinery, reduced material consumption and minimized waste.

Many large infrastructure projects, such as highways and bridges, are now designed with 50- or even 75-year lifespans in mind. Airports, as critical infrastructure, may benefit from changing standards. However, this may not be feasible or cost-effective for assets that have shorter lifecycles, such as navigational aids or lighting systems, due to technological advancements.

Instead of a one-size-fits-all approach, perhaps the FAA could adopt tiered or flexible project lifespan requirements that protect public investments while supporting the evolving needs of general aviation airports.

A Balanced Approach

General aviation airports are vital assets that contribute significantly to the nation’s air transportation network and local economies. Protecting the federal grant infrastructure that supports them requires addressing challenges such as local encroachment and compliance requirements related to the useful life of the project being funded.

Airports should actively engage with business, community and government stakeholders to promote the benefits of aviation and develop policies that respect the integrity of their federal grant assurance obligations. By prioritizing proactive planning and collaboration, they can safeguard federal investments and ensure the continued delivery of vital services to the public.

About the Author

Curt Castagna | President and CEO

Curt Castagna, principal of Aeroplex Group Partners, serves as president and CEO of the National Air Transportation Association, member and past chair of the Los Angeles County Airport Commission, and president of the Van Nuys and Long Beach airport associations. A certified private, seaplane and instrument-rated pilot, he continues to instruct courses in aviation administration at Cypress Community College and Cal State Los Angeles.