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13 VI. SUMMARY OF COMMON INDUSTRY 5. Few airport sponsors submit their Minimum PRACTICES Standards for FAA review. As examined in Section III, airport sponsors are not required to submit draft Mini- The research, survey, and interviews conducted in mum Standards to the FAA for review or approval; preparing this digest indicate that there are some com- however, if a formal or informal complaint is filed with mon industry practices used in developing and updating the FAA, the FAA will be called upon to consider the airport Minimum Standards. While this digest is not airport sponsor's compliance with the Sponsor Assur- intended to serve as a how-to guide, understanding ances and related federal obligations. Several survey these common practices may assist airport lawyers, respondents have been parties to such informal and airport sponsors, airport managers, and consultants formal proceedings. It appears that airport sponsors who desire to, or are tasked with, developing or updat- determine on a case-by-case basis whether or not to ing airport Minimum Standards. seek FAA review and comment before adopting and Some common industry practices include the follow- implementing Minimum Standards. ing: 6. Airport Managers and/or the Airport Governing Body typically lead the team. As outlined in Section 1. Most airport Minimum Standards share common IV.B and Appendix B, Airport Managers and/or the features. As described in Section V, the vast majority of Airport Governing Body typically lead the team respon- the subject documents define key terms, prescribe stan- sible for the development/update process. dards generally applicable to all commercial aeronauti- 7. Airport sponsors regularly review and update air- cal activities, require some form of agreement with the port Minimum Standards and typically complete the airport sponsor, and require an application. development or update process in less than 1 year. As 2. Airport Minimum Standards typically, but do not reflected in Appendix B, the survey revealed that always, correspond to the commercial aeronautical ac- roughly half of the respondents review their airport tivities that currently, or may in the future, occur at the Minimum Standards annually, and a majority update airport. As detailed in Section V, the survey revealed 11 their airport Minimum Standards every 5 or fewer commercial aeronautical activities that customarily years. The vast majority of respondents indicated that occur at airports. The survey and analysis of the subject it took less than 1 year to develop or update their Mini- documents further revealed that some airport Mini- mum Standards. mum Standards fail to prescribe standards for each of these customary activities or fail to prescribe standards for commercial aeronautical activities occurring at the airport. Further, a few respondents indicated receiving requests to conduct commercial aeronautical activities that were not covered by the airport's Minimum Stan- dards. 3. Airport Minimum Standards vary widely on the standards prescribed for specific commercial aeronauti- cal activities. As analyzed in Section V and reflected in Appendix D, there is no consensus regarding the spe- cific or numeric standards that should be established for any given subject. Where specific or numeric stan- dards are prescribed, the standards that have been es- tablished vary widely from airport to airport. Thus, airport sponsors appear to tailor Minimum Standards to the particular circumstances occurring at the airport. To ensure that airport Minimum Standards are rele- vant and attainable, as required to comply with the Sponsor Assurances, the FAA supports this approach and discourages fill-in-the-blank Minimum Standards. 4. Airports typically rely on FAA resources in devel- oping and updating Minimum Standards. As detailed in Section IV.B and Appendix B, airports rely primarily on the Sponsor Assurances and FAA orders and advi- sory circulars. The literature review summarized in Section IV.A identified some additional resources. Ap- pendix A includes citations to 36 cases specifically on the subject of airport Minimum Standards that provide guidance to airport lawyers, airport sponsors, airport managers, and consultants in approaching the task of developing or updating airport Minimum Standards.