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CONTENTS I. Preface/Summary, 3 II. Introduction, 3 III. Competition in Context, 4 A. DOT/FAA Approach to Regulating Competition, 4 B. Airline Industry Trends, 6 C. FBO Industry Trends, 8 D. Airport Sponsorsâ Role and Interest in Promoting Competition, 10 IV. Relevant Legal Authorities, 11 A. Statutory Framework, 11 B. AIP Grant Assurances, 12 C. Surplus Property Conveyances, 16 D. Passenger Facility Charges, 17 E. Competition Plans and Competitive Access Reports, 17 F. Airline Deregulation Act, 18 G. Private Contracts, 18 V. Legal Issues Relating to Promoting Airline Competition, 19 A. Alternative Rates and Charges Methodologies, 19 B. Air Carrier Incentive Programs, 21 C. Recent Dispute/Litigation Regarding Gate Access, 25 VI. Legal Issues Relating to Promoting FBO Competition, 27 A. Rates and Charges, 27 B. Minimum Standards, 27 C. Multiple Classes of FBO, 29 D. Unbundling of FBO Services, 29 E. Proprietary (Exclusive) Services, 30 F. Requests for Proposals, 31 G. Controlling Prices or Quality of Service, 32 VII. Conclusion, 33 2 ACRP LRD 37 Revised November 2019