Data Supporting the Impact of Regulatory Compliance Costs on Small Airports, Volume 2: Technical Appendixes to ACRP Report 90 (2013) / Chapter Skim
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Most of the ACs identified and discussed in the research report originate with the FAA Airport Engineering, Design and Construction Program. The ACs are considered safety-related because one objective of the design and construction standards is objective the safety of aircraft operations in the airport environment.
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The final source of compliance requirements is the FAA Airport Compliance Program. The compliance program is based on statutory grant assurances contained in 49 USC §47107 and other sections of the statute governing AIP (49 USC §47101 et seq.)
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A.2 DOT Requirements Table A-1 in Appendix A of the research report also summarizes the DOT regulatory and compliance requirements adopted during the study period. The DOT requirements are listed following the FAA requirements.
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holders as well as new certificate holders would incur increased costs. The added costs for new certificate holders (Category III airports)
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adjustment of written standards to match current practices, others were potentially costly. For example, Change 11 to the AC prohibits automobile parking in the central portion of the runway protection zone (RPZ)
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Maintenance of Airport Pavements (July 14, 2003) revised procedures for maintaining airfield pavement.
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the other FAA/DOT requirements discussed in this document. Table B-2 in Appendix B of the research report summarizes the responses to the remaining Phase 2 survey questions not discussed in this Technical Appendix.
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exist; the value of the arithmetic mean is substituted in these cases mainly for consistency in presentation. Readers should take note that because of the small number of airports responding, results may not apply to all airports.
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Table TA-1. Airfield Design, Standards and Operations Requirements, Initial Costs Question(s)
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A simple project to remove vegetation would be less costly than a project requiring grading or fill work. Land acquisition could also increase compliance costs.
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interquartile mean cost is $466. The discrepancies between average and interquartile mean costs suggest that interquartile mean cost may be the more reliable indicator of typical unit costs.
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• Class I airports have scheduled and charter service with large aircraft. Class I airports previously held full operating certificates.
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Limited certificate holders (Class II airports under the new certification system) were exempt from many of the requirements applicable to full certificate holders.
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the reported impact of the Part 139 Amendment on existing certificate holders. The reported result for the airport certification manual is inconsistent with the terms of the rule, which required all certificate holders to update their airport certification manual.
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Table TA-3. Impact of Part 139 Amendments on Newly Certificated Airports, Initial Costs Question(s)
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Table TA-4. Impact of Part 139 Amendments on Newly Certificated Airports, Recurring Costs Question(s)
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revisions to certification manuals, and revisions to snow and ice control plans. Table TA-5 summarizes initial compliance costs, and Table TA-6 summarizes recurring compliance costs.
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Table TA-6. Impact of Part 139 Amendments on Existing Certificated Airports, Recurring Costs Question(s)
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for vehicle operators. Initial and recurrent training is required for airport employees.
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Table TA-7. Modifications to Policies on Vehicle Operations in Aircraft Operations Area, Initial Costs Question(s)
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Table TA-8. Modifications to Policies on Vehicle Operations in Aircraft Operations Area, Recurring Costs Question(s)
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four Part 158 amendments implemented changes in Section 40117. The fourth amendment, increased the rate of carrier compensation for PFC collection and handling and was undertaken at FAA's initiative.
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implemented the non-hub pilot program. Of the airports that submitted a PFC application after issuance of PFC Update 50-06, 27% reported incurring increased costs to supply additional cost information as specified in the update.
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Table TA-9. Costs Incurred by Airports Affected by Changes to PFC Requirements Question(s)
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to the AIP, DOT, through the Office of the Secretary of Transportation, has promulgated DBE requirements. Background and Change in Requirements The DOT maintains separate rules for participation of DBEs in airport concessions (49 CFR Part 23)
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Figure TA-6. Airports Affected by DBE Rule Changes (Sample: 86-87 airports)
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Table TA-10. Airports Affected by DBE Rule Changes, Initial Costs Question(s)
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C.6 AIP Administrative Requirements During the study period, the FAA modified a number of administrative requirements for the AIP program and operation of AIP-obligated airports. Actions in this broad category included changes to requirements for procurement of services for grant-funded projects, internal guidance to FAA staff on administering the AIP and identifying projects for potential discretionary funding, and standards for applying AIP grant assurances.
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plans in response to new FAA guidance issued in 2008 (Table A-1, Item 113)
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Table TA-12. Miscellaneous FAA Administrative Requirements, Initial Costs Question(s)
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Table TA-13. Miscellaneous FAA Administrative Requirements, Recurring Costs Question(s)
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D.1 Overview of Potential Funding Sources The AIP is a significant source of funding for airport capital development, planning and environmental mitigation. AIP funds cannot be used for operations and maintenance (O&M)
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In the context of the FAA requirements listed in Table A-1, incremental costs associated with the design or construction standards listed in ACs, Orders and Cert Alerts are eligible for AIP funding, to the extent they apply to AIP-eligible construction. Capital costs associated with the Part 139 requirements are eligible, as well.
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Limitations on the Benefits of Federal Assistance Although the use of AIP or PFC funds may reduce the amount of funding airports must generate from other sources, e.g. rates and charges, bond proceeds, discretionary reserves, to comply with federal requirements, there is an opportunity cost associated with this use.
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1 2 37 Airfield Design, Standards and Operations The funding sources for airfield design, standards and operation requirements are summarized in Figure TA-8 through Figure TA-13. A substantial number of airports were able to obtain AIP funding for the full federal share of project costs for these compliance requirements.
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14 12 10 8 12 6 4 2 2 2 1 0 None Less Than Local Share Local Share Only More Than Local Share Figure TA-9. PFC Funding Levels for Initial Costs of Fencing Requirements In contrast, 12 out of 17 airports reported using no PFC funds to comply with wildlife fencing requirements.
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Nineteen out of 25 airports received AIP funds for the full federal share of their runway protection projects, and only one airport received no federal funding. 3 2 0 0 None Less Than Local Share Local Share Only More Than Local Share Figure TA-11.
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10 9 8 7 6 9 4 3 2 1 0 None Less Than Local Share 6 0 Local Share Only More Than Local Share Figure TA-13. PFC Funding Levels for Initial Costs of Airfield Signage Requirements Consistent with the other requirements, a majority of airports (nine out of 16)
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Figure TA-14. AIP Funding Levels for Initial Costs of Part 139 Requirements, Existing Part 139 Airports There was more diversity in the use of AIP funds for Part 139 requirements than the previous requirements.
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Requirements for Vehicle Operations on the Airport Figure TA-16 and Figure TA-17 show the use of AIP funds and PFCs, respectively, for financing compliance with requirements for vehicle operations on the airfield. The figures show the funding for all requirements combined, and they include multiple responses from individual airport, i.e., the same airport may have incurred costs for compliance with enforcement and control requirements and requirements for emergency vehicle operations.
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Figure TA-17. PFC Funding Levels for Initial Cost of Compliance With Requirements for Vehicle Operations A substantial majority of airports (25 out of 31)
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16 2 3 None Less Than Federal Share Full Federal Share 1 Total count may include multiple responses for individual airports Figure TA-18. AIP Funding Levels for Initial Costs of Consultant Selection and GIS Requirements1 A substantial majority of airports (16 out of 21)
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Thirteen out of 14 airports reported using only airport funds (other than PFCs) to finance the initial costs of compliance with the requirements for snow and ice control plans.
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Figure TA-20. Funding Sources for Recurring Costs of Requirements for Vehicle Operations While the majority (19 out of 29)
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