Development of a Guidebook for Managing Small Airports (2009)

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ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports APPENDIX H: INDUSTRY REVIEW COMMENTS AND ADJUDICATION No. Name Airport/Organization Chapt. Pg/Para Comment Response 1 M. Reisman Greeley-Weld Co. Airport General N/A There are uses of acronyms and abbreviations for common things with which I am not familiar and a number of terms referenced are now obsolete. Acronyms in the list and in the document will be verified. 2 M. Reisman Greeley-Weld Co. Airport General N/A Recommend adding a reference to the sharing of common documents between airports and airport managers. Such a reference will be added in the appropriate section. 3 M. Reisman Greeley-Weld Co. Airport General N/A No specific references to FAR Part 150 Noise Issues in the document. Add a section on FAR 150 in the appropriate location if it is not already there. 4 M. Reisman Greeley-Weld Co. Airport General N/A Airport Finance could use better information on establishing rates and charges and explaining the difference between compensatory and residual methods. Expand the explanation of rates and charges and add definitions of compensatory and residual methods. 5 M. Reisman Greeley-Weld Co. Airport 1 General Add references about the roles of Airport Advisory Boards and tenants associations. Accepted. 100

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 6 M. Reisman Greeley-Weld Co. Airport 1 General Guidebook lacks information on how an airport manager fits into the overall chain of command/authority in a city/county as it relates to a city/county manager and city council or county board. Add information about this subject in the appropriate section. 7 M. Reisman Greeley-Weld Co. Airport 2 General Several sections, such as minimum standards, flying clubs, rules and regulations, exclusive rights, and rates and charges, may be better used in another section outside of the Airport Finance chapter. Not accepted. Minimum standards, flying clubs, rules and regulations, exclusive rights, and rates and charges, all pertain to leases which are a form of revenue generation. 8 M. Reisman Greeley-Weld Co. Airport 2 General There is no mention of airports that operate as “Enterprise Funds.” See response to comment 9 below. 9 M. Reisman Greeley-Weld Co. Airport 2 29 The paragraph on Enterprise Funds should be referenced as a special economic development fund or similar to avoid confusion with an airport that operates as a true “Enterprise Fund” so that it is a financially self-supporting and revenue generating department or organization. Partially accepted. Enterprise funds come in many different forms and vary widely by state and municipality. Some enterprise funds are exclusively for capital projects related to business development activities and some are for self- supporting municipal services (e.g., sewer, water, airport, etc.). The former is appropriately mentioned in the sources 101

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response of revenue section. The latter is more appropriate to Chapt. 1 Airport Organization. Will considered adding enterprise funds to Chapt. 1, as appropriate. 10 M. Reisman Greeley-Weld Co. Airport 3 General There is no real reference to the importance of the 150 series of ACs which contain substantial information relevant to airport operations and recommended operating practices. Accepted. The 150 series of ACs is referenced throughout this chapter. A paragraph will be added emphasizing the importance of this series of ACs and referring airport managers to both the guidebooks bibliography and the FAA’s online regulatory library. 11 M. Reisman Greeley-Weld Co. Airport 3 37/3 NOTAM issuance procedures have changed and several states have pilot programs to improve issuance support issues by Lockheed Martin. Then general statement concerning the manner of issuance is no longer true in all locations. Add language to reflect change in NOTAM issuance procedures and potential variation by state. 102

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 12 M. Reisman Greeley-Weld Co. Airport 4 73/4 The term “jurisdictional boundary” may not be correct, especially when used to describe areas outside of the airport property. This insinuates that an airport has some form of governmental or zoning control over lands outside of its perimeter which is not always true, especially for airports that are owned by airport authorities. Do you mean “airport influence area”? 13 M. Reisman Greeley-Weld Co. Airport 4 97/2 Recommend that you reference the FAA Model Height Zoning Ordinance which can be found in the AC. Accepted. That AC is included in the References section of the chapter. 14 M. Reisman Greeley-Weld Co. Airport 7 General Recommend that you reference the numerous model training programs produced by the FAA and available to operators. Also, FAA and AOPA training tapes on operations and the AAAE Airport News and Training Network Digicast system. Accepted. References to the various FAA and association training programs will be added. 103

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 15 M. Reisman Greeley-Weld Co. Airport App. General Many of the terms included in the glossary are not used in the document. There is no need to list all of the acronyms in this section. The acronyms used in the document should be included in the list at the front of the guidebook. Not accepted. The intent is to provide a comprehensive glossary and list of acronyms regardless of whether or not a term or acronym is referenced in the text. The list of commonly used terms and acronyms at the front of the document is just that; its purpose is as a quick reference. 16 C. Barrow Bartow Airport 6 General As a GA airport operator, this section did not apply 100% to me; although the section regarding leasing tips was informative. A discussion of commercial service was mandated in the project’s RFP. The research team will consider adding a “disclaimer” that this chapter may not apply to airports without commercial service. 104

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 17 R. Grierson Dubuque Regional Airport General N/A Airport training is important but I think comments like training as dictated by FAR Part 139 should be reflected throughout the airport staff. Such training is job specific and can be obtained at most AAAE conferences. The purpose of Chapter 7 is to emphasis the importance of training and orientation programs at small airports that may experience significant staff turnover or have services (e.g., snow removal) provided by county or municipal staff. While AAAE training programs can be valuable, the staff at small airports may not be able to attend those conferences and programs. 18 R. Grierson Dubuque Regional Airport General N/A Chapter 4 should cover in detail land use planning for adjacent parcels off airport. Partially accepted. A paragraph or two referring airports to state zoning handbooks for information on adjacent parcel zoning will be added. 19 R. Grierson Dubuque Regional Airport 6 General Discuss a little more on the business side of airlines what they want at an airport. Accepted. Additional information about airline expectations will be included. 20 M. Henry Easton Airport General N/A I would like to have seen a more in depth discussion of business/financial planning. Additional information on business/financial planning will be included, as appropriate. 105

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 21 M. Henry Easton Airport 2 30/1 Add information about USDA rural business development grants. Accepted. Appropriate information on USDA rural business development grants will be added. 22 M. Henry Easton Airport 3 53/4 Add information about “continuity of government- continuity of operations (COG- COOP)” Accepted. Appropriate information about COG- COOP will be added. 23 M. Henry Easton Airport 4 90/2 Add fuel truck parking information. Accepted. Appropriate information about fuel truck parking will be included. 24 T. Mathis Gallatin Field 5 Make sure that your community is aware of the many valuable uses of your airport, such as air ambulance, fire fighting, aerial agriculture spraying, search and rescue, and law enforcement. A note with a picture of these activities sent to the local newspaper can go a long way in illustrating the importance of your local airport. Accepted. Information about activities or services valuable to the community will be added to the appropriate section of this chapter. 25 S. Decker Fairbury Municipal Airport 2 15/5 Totally unusable for GA airports. Partially accepted. The information in this paragraph will be reviewed to ensure it applies to GA airports. 26 S. Decker Fairbury Municipal Airport 2 15/6 Not feasible for GA airports. Partially accepted. The data behind this revenue source will be reviewed. 106

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 27 S. Decker Fairbury Municipal Airport 2 19/4 Should read “flight instruction” and airports should not be involved with regulations for flying clubs. Partially accepted. “Flight inspection” will be changed to “flight instruction.” Airports should have rules that prohibit a flying club from operating like an FBO. 28 S. Decker Fairbury Municipal Airport 2 21/3 Should not have individual owners bringing or storing their own fuel. Not accepted. While this comment may be an advisable practice, an airport cannot outright prohibit self-fueling without being in violation of Sponsor Assurances. 29 S. Decker Fairbury Municipal Airport 3 38/3 Airfield driving program? Again, not appropriate for small GA airports. Not accepted. The FAA has identified inadequate training as a source of airfield driving accidents and includes a sample training curriculum in AC 150/5210. Establishing an airfield driving program is appropriate to any GA airport that wishes to reduce the risk of airfield driving accidents. 30 S. Decker Fairbury Municipal Airport 7 General Not for small GA airports. The inclusion of a discussion of commercial service was mandated in the project’s RFP. 107

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 31 G. Januska Casper/Natrona County Int’l Airport 1 3/3 Not sure that “many” states build, own, and operate their own airports. The number of state built, owned, and operated airports will be verified. 32 G. Januska Casper/Natrona County Int’l Airport 1 4/8 This paragraph implies that the perception of airports is not good. Will adjust language to avoid connation that the perception of airports is not good. 33 G. Januska Casper/Natrona County Int’l Airport 1 4/10 This assumes that you are not considering private airports as part of small airports. The guidebook is geared towards publicly owned airports. However, much of the information is relevant to managers of small, privately owned airports. 34 G. Januska Casper/Natrona County Int’l Airport 2 9/6 If you discuss non-operating expenses, you may want to touch on non-operating revenue, interest income, etc. Accepted. Appropriate information about non- operating sources of revenue/income will be added. 35 G. Januska Casper/Natrona County Int’l Airport 2 15/2 As in dollar amount or greatest used? Will verify information and clarify text. 36 G. Januska Casper/Natrona County Int’l Airport 2 15/4 Associated municipalities have bonding authority. Accepted. Language indicating the municipalities may issue bonds for airport projects will be added. 37 G. Januska Casper/Natrona County Int’l Airport 2 17/Table, 2nd line These two do not go with one another. Accepted. This example will be verified. 108

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 38 G. Januska Casper/Natrona County Int’l Airport 3 39/3 Not sure how. My experience, talking about wildlife management gets the PETA, etc. people riled up. Will revise parenthetical clause to indicate that wildlife “may” provide a good public relations opportunity. 39 G. Januska Casper/Natrona County Int’l Airport 3 45/2 Not true, most airports are privately owned. Will verify information and revise paragraph accordingly. 40 G. Januska Casper/Natrona County Int’l Airport 4 61/4 Deliverables by whom? Accepted. Will clarify the last sentence. 41 G. Januska Casper/Natrona County Int’l Airport 4 61/4 May want to preface this by saying that most master plans are prepared by 3rd parties. Accepted. 42 G. Januska Casper/Natrona County Int’l Airport 5 100/5 I’d talk about understanding the media requirements (deadlines for stories, printing, etc.) Accepted. Will add information about considering media needs. 43 J. Pestka Missouri DOT 1 3/3 Mention block grants and state functions? These items are, and are more appropriately, addressed in other parts of the guidebook. 44 J. Pestka Missouri DOT 4 78/2 Not sure what this (last sentence of the paragraph) is conveying. The intent is to make clear the advisory nature of the FAA’s role in airport consultant selection. The sentence will be reviewed and, if possible, clarified. 109

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 45 R. Null Florida DOT General N/A If the audience for this guidebook is “small airport manager” I am afraid to say that this document is rather long and for the most part, intimidating. Other comments expressed concern about the length but acknowledged that the comprehensive guidebook required the current length. The expectation is that the guidebook will be used as a ready reference. The topical break down in the table of contents should lead airport managers to the information they seek quite quickly. 46 R. Null Florida DOT 1 3/3 Aviation office inspections are more than “safety,” they directly relate to statutory requirements to meet state airport licensing standards. Accepted. The discussion of state aviation office inspections will be expanded, as appropriate. 47 R. Null Florida DOT 1 7/7 FAA does not provide an airport the authority to operate – states (at least Florida) provide public use airports the legal authority to operate by issuing a license – even to Part 139 airports. Accepted. A paragraph about state airport licensing requirements will be added. 48 R. Null Florida DOT 3 39/5 Stress that there are some wildlife hazards that may NOT be reduced due their protected species status (e.g., eagles nests on or near airports in Florida). Accepted. 110

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 49 R. Null Florida DOT 3 50/4 States may have stringent airport security requirements imposed by state law. Florida requires airport security plans for some airports not required by FAA and that security is mandatory to ensure airport licensing by the state. Accepted. The paragraph will be revised to recognize the varying nature of airport security requirements by state. 50 R. Null Florida DOT 3 59/5 Some states such as Florida have very specific airport inspection standards required to obtain an airport operating license from the state. Airport Master Plans and Airport Layout Plans that only address FAA requirements may be missing critical information that may make the airport ineligible for state funding of their planned projects. Accepted. A paragraph about state airport licensing requirements will be added. 51 R. Null Florida DOT 4 76/3 Add “LPV Approach” discussion somewhere in vicinity of “Area Navigation” discussion. Tremendous interest in acquiring LPV approaches at airports in Florida. Definitely an “Emerging Trend.” Accepted. A section on LPV approaches will be added in an appropriate place in the guidebook.. 111

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports No. Name Airport/Organization Chapt. Pg/Para Comment Response 52 R. Null Florida DOT 4 84/2 Last sentence is incorrect and should be removed. FAA does not issue permits for construction. The FAA only issues an airspace determination. Authority to issue a “permit” for construction lies with the state or local government only. Accepted. The last sentence will be eliminated to revised. P. Friedman FAA AAS-100 General N/A Take a closer look at how to treat specific questions . . . if may of these types of questions could be answered it would be an extremely useful reference for airport managers down the road. The research team gave this comment substantial consideration but decided not to include an FAQ section in the Guidebook. The research team determined that any list of FAQs would be deemed lacking important questions and an FAQ section would not be consistent with the agreed upon outline and format of the Guidebook. As more ACRP projects are completed, developing a single FAQ volume based on all of the projects might be a valuable ACRP Synthesis topic. P. Friedman FAA AAS-100 1 2 Remove “please specify” from the pie chart slice labeled “Other” Accepted 112

ACRP Web-Only Document 5: Development of a Guidebook for Managing Small Airports 113 No. Name Airport/Organization Chapt. Pg/Para Comment Response P. Friedman FAA AAS-100 1 6 Show a link to the AC web page P. Friedman FAA AAS-100 1 11 Are there any other online/electronic resources for airport operators to calculate their economic impact? The short answer is no. Most economic impact calculations are performed by consulting firms for specific airports. The currently available online calculators tend to be dated and regionally focused, like the one developed by the University of Minnesota for the DOT. Developing a basic web- based economic impact calculator for airports would make an excellent ACRP project.