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35 APPENDIX C--Interviews and Results Leaders within the airport industry that likely would have experience with airport Minimum Standards were identified for interviews. Leaders were drawn from the following areas: Government agencies, including FAA compliance personnel and state aviation directors or managers. Major industry trade associations, including senior executives or managers. Airports, including directors or managers from some of the top general aviation airports in the country (measured in terms of annual aircraft operations). Fixed base operations (FBOs), including senior executives or managers. Industry suppliers/vendors, including senior executives or managers. Twenty-eight individuals responded to the request for an interview. Interview Questions and Responses Note: The narrative responses for each question are arranged by frequency, from the most to the least fre- quent. 1. Organization name. 2. Your position/title. 3. What is your role with the organization (or what responsibilities do you have)? 4. Who does your organization serve or represent (who are your members/constituents)? 5. What experience do you have with regard to the development, implementation, and/or enforcement (or in- terpretation) of Minimum Standards? Respondents have (1) developed/updated Minimum Standards, (2) participated in the process of develop- ing/updating Minimum Standards, (3) developed/updated guidance documents for Minimum Standards, and (4) worked with others to develop/update Minimum Standards. A few had little or no experience with (or related to) Minimum Standards or had not dealt with them extensively.

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36 6. In your opinion, what "roles" or "purposes" do Minimum Standards serve? Respondents indicated that Minimum Standards (1) level the playing field and/or promote fair competition, (2) protect consumers, (3) require minimum level of service, (4) protect airports, and (5) provide guidance for the development of the airport. 7. Which aeronautical activities at an airport should be subject to Minimum Standards? a. Commercial ("for hire"). i. Fixed Base Operator (FBO). ii. Specialized Aviation Service Operators (SASO). b. Non-Commercial ("not for hire" or "private"). i. If so, please describe the activity(ies): All respondents indicated that all commercial (for hire) aeronautical activities (i.e., FBO and SASO activities) should be subject to Minimum Standards. Approximately 70 percent of respondents indicated that noncommer- cial (not for hire) aeronautical activities should be subject to Minimum Standards. 8. Do you believe that some commercial ("for hire") aeronautical activities should be "prohibited" at an air- port? a. _____ No _____ Yes b. If yes, please describe the activity(ies): i. Should the activities that you have described be prohibited "universally" or "only under specific circum- stances"? 1. _____ Universally _____ Only Under Specific Circumstances 2. If "only under specific circumstances," please describe the circumstances. Approximately 67 percent of respondents believe that some commercial aeronautical activities should be pro- hibited. These respondents described several commercial aeronautical activities that could, in some cases, create

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37 a safety hazard (or jeopardize safety) at an airport (e.g., commercial skydiving, aerial advertising/banner tow- ing, ultralights, gliders, blimps, etc.). Approximately 33 percent of respondents believe that, from a general stand- point, commercial aeronautical activities should not be prohibited at an airport, although it is significant to note that many of these respondents also provided an important caveat to the response "that unless a safety hazard is created (or safety is jeopardized) at the airport." 9. What are your thoughts ("specifically" as it relates to Minimum Standards) with regard to: a. Through-the-fence activities. Respondents indicated the following: If through-the-fence activity is going to be allowed at an airport, the operator should be subject to Minimum Standards. Through-the-fence activities are already allowed at the airport, subject to the operator meeting certain condi- tions (e.g., having an access agreement with the airport sponsor). They were generally opposed to through-the-fence activities, but indicated that the activity may be acceptable under certain circumstances or uses (e.g., aircraft manufacturing). They were opposed to through-the-fence activities, indicating that the activity should not be allowed under any circumstances. Through-the-fence activities should be addressed on a case by case basis. b. Independent operators. Respondents indicated the following: Generally, independent operators should not be allowed at airports, but this activity may be acceptable under certain circumstances and subject to meeting Minimum Standards and/or other conditions established by the airport sponsor. Generally, independent operators should be allowed at airports, subject to meeting Minimum Standards and/or other conditions established by the airport sponsor. Independent operators are already allowed at the airport, subject to meeting Minimum Standards or other conditions established by the airport sponsor. Independent operators should be addressed on a case-by-case basis. Independent operators should not be allowed or are not allowed at the airport.

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38 c. Commercial skydiving. Respondents indicated the following: Generally, commercial skydiving should be allowed at airports, subject to meeting specific conditions. Generally, this activity should not be allowed at airports, but may be acceptable under certain circumstances and subject to meeting specific conditions. This activity should be addressed on a case-by-case basis. Commercial skydiving should not be allowed or is not allowed at the airport. d. Ultralights. Respondents indicated the following: Generally, ultralights should be allowed at airports, subject to meeting specific conditions. Generally, this activity should not be allowed at airports, but may be acceptable under certain circumstances and subject to meeting specific conditions. This activity should be addressed on a case-by-case basis. Ultralights should not be allowed or are not allowed at the airport. e. Aerial advertising (banner towing). Respondents indicated the following: Generally, aerial advertising should be allowed, subject to meeting specific conditions. Generally, this activity should not be allowed at airports, but may be acceptable under certain circumstances and subject to meeting specific conditions. Aerial advertising should not be allowed or is not allowed at the airport. This activity should be addressed on a case-by-case basis. f. Other (please describe). Several respondents identified gliders as another activity that should be addressed on a case-by-case basis. 10. How often should an airport's Minimum Standards be: a. Reviewed (to determine whether or not they need to/should be updated)

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39 i. Every 6 months. ii. Every year. iii. Every 3 years. iv. Every 5 years. v. Every 10 years. vi. More than every 10 years. Approximately 54 percent indicated every 5 years (several interviewees indicated a range between 3 to 5 years), approximately 19 percent indicated every 3 years, approximately 12 percent indicated every year, and approxi- mately 12 percent indicated when the situation and/or circumstances (in the industry, in the market, at the air- port, etc.) change or if FAA guidance changes or if the guidance provided by industry associations (or others in the industry) changes. In addition, several respondents who provided a definitive answer to this question (i.e., every year, every 3 years, every 5 years, etc.) also indicated that if the situation and/or circumstances change, Minimum Standards should be reviewed (i.e., that airport sponsors should not wait until some prescribed or scheduled time to review the document). Finally, approximately 4 percent indicated Minimum Standards should 54 be reviewed at least every 10 years. a. Updated i. Every 6 months. ii. Every year. iii. Every 3 years. iv. Every 5 years. v. Every 10 years. vi. Every 15 years. vii. Every 20 years. viii. More than every 20 years. Approximately 42 percent indicated every 5 years, approximately 42 percent indicated when the situation and/or circumstances change, and approximately 15 percent indicated every 3 years.55 54 Percentages do not add up to 100 percent due to rounding. 55 Percentages do not add up to 100 percent due to rounding.

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40 11. What challenges, issues, and/or problems (relating "specifically" to Minimum Standards) have you or your members/constituents encountered (or are you or your members/constituents currently encountering) relating to the development (or updating), implementation, and/or enforcement (or interpretation) of Minimum Standards? Respondents indicated the following: The document is not balanced (i.e., current situation/circumstances and future considerations/possibilities are out of balance with too much weight or emphasis being given to one or the other). The document is out of date (not current), not relevant for the aeronautical activities taking place at the air- port, or not reasonable and/or appropriate (too low or too high) for the airport and/or the market. There is a lack of process or the process is not timely or there is little or no opportunity for stakeholder in- volvement/input during the process. Political influences are significant. There is a lack of consistent (and/or uniform) enforcement. 12. Do you believe that airport sponsors (owners/operators) have the requisite resources and/or guidance from the FAA and/or association (and/or industry) groups to develop (or update), implement, and enforce Minimum Standards (check "all" that apply)? While the majority of respondents (just over 90 percent) answered affirmatively (yes), approximately 26 percent of the respondents indicated that (1) the airport sponsor may not know about the resources and/or guidance, (2) it may be difficult to find (or understand) the resources and/or guidance, or (3) it may be hard to apply the re- sources and/or guidance to specific situations and/or circumstances. The remaining respondents (about 9 per- cent) answered negatively (no). 13. What do you think the FAA's "role" should be with regard to the development (or updating) and imple- mentation of Minimum Standards (check "all" that apply)? a. The FAA should "not" require that airport sponsors adopt Minimum Standards. b. The FAA should require that airport sponsors adopt Minimum Standards. c. The FAA should "not" review Minimum Standards before adoption.

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41 d. The FAA should review Minimum Standards before adoption. e. The FAA should "not" approve Minimum Standards before adoption. f. The FAA should approve Minimum Standards before adoption. g. Other (please describe). Approximately 68 percent of respondents believe that the FAA should "not" require that airport sponsors adopt Minimum Standards (approximately 32 percent believe the FAA should require adoption of Minimum Stan- dards). With regard to believing that the FAA should "review" Minimum Standards before adoption by the air- port sponsor, approximately 55 percent of respondents believe it should not, while 45 percent believe it should. Just over 90 percent of respondents believe that the FAA should "not" approve Minimum Standards before adop- tion (approximately 9 percent believe the FAA should approve Minimum Standards before adoption). 14. On a scale of 1 to 4 (with "1" being "not" reflective, "2" being "not very" reflective, "3" being "somewhat" re- flective, and "4" being "extremely" reflective), how well do FAA policies, practices, and decisions "reflect" the market-based realities of commercial aeronautical activities at airports? Approximately 58 percent of respondents indicated a 2 (not very reflective), 25 percent indicated a 3 (somewhat reflective), and approximately 17 percent indicated a 1 (not reflective). 15. What statement best reflects your views on the Sponsor Assurances, as currently interpreted and enforced by the FAA: a. Too favorable for airports--it's too easy to achieve and maintain compliance (not enough weight is given to the meeting the needs of commercial aeronautical operators). b. About right in terms of the balance between airports and commercial aeronautical operators. c. Too burdensome for airports--it's too difficult to achieve and maintain compliance (too much weight is given to meeting the needs of commercial aeronautical operators). Approximately 63 percent of respondents indicated "about right" in terms of the balance between airports and commercial aeronautical operators, 25 percent indicated "too burdensome for airports" (i.e., it's too difficult for airports to achieve and maintain compliance--too much weight is given to meeting the needs of commercial aero-

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42 nautical operators), and approximately 13 percent indicated "too favorable for airports" (i.e., it's too easy for air- ports to achieve and maintain compliance--not enough weight is given to the meeting the needs of commercial aeronautical operators).56 16. As it relates "specifically" to Minimum Standards, have you (or any of your members/constituents) ever been a party to a: a. 14 C.F.R. Part 13 "informal" complaint? i. _____ No _____ Yes ii. If yes, what was the outcome? Approximately 68 percent of respondents have not been a party to a Part 13 informal complaint (32 percent have). b. 14 C.F.R. Part 16 "formal" complaint? i. _____ No _____ Yes ii. If yes, what was the outcome? Approximately 70 percent of respondents have not been a party to a Part 16 formal complaint (26 percent have, 4 percent are unsure). c. Lawsuit? i. _____ No _____ Yes ii. If yes, in which court? iii. _____ Federal _____ State iv. If yes, what was the outcome? Approximately 70 percent of respondents have not been a party to a lawsuit (22 percent have, 8 percent are un- sure). 17. What's your bottom line on Minimum Standards--if you could say one thing to the "entire" industry about Minimum Standards, what would it be? 56 Percentages do not add up to 100 percent due to rounding.

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43 Respondents indicated the following: Airports (airport sponsors) need to adopt Minimum Standards (Minimum Standards are a valuable/useful tool). Airport sponsors need to consistently (and uniformly) enforce Minimum Standards (once adopted). Minimum Standards need to be relevant, reasonable, and appropriate. Minimum Standards level the playing field (between operators)/promote fair competition (amongst opera- tors). Airport sponsors need to consider today and tomorrow (when developing/updating and/or implementing Minimum Standards). Minimum Standards protect operators and airports. Minimum Standards ensure the long-term viability of operators or airports. Airport sponsors need to keep Minimum Standards current. Airport sponsors need to include airport stakeholders in the (development/updating and implementation) process.