September 22, 1999 Federal Aviation Administration
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| September 22, 1999
Federal Aviation Administration Airports Financial Assistance Division, APP-500 Room 619
800 Independence Avenue, SW Washington, DC 20591 Re: Airport Improvement Program Grant Assurances; Proposed Modifications and Opportunity to Comment IntroductionThe National Air Transportation Association (NATA) represents nearly 2,000 aviation businesses owning, operating and servicing aircraft. These companies serve the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, aircraft parts sales, aircraft storage, flight training, non-scheduled air charter, aircraft rental, and scheduled commuter operations in smaller aircraft. NATA members are the vital link in the aviation industry that provides services to the airlines, general aviation, and the military. The Association has a long history of assisting both managers of aviation businesses (fixed base operators or FBOs) and individuals in airport management with airport compliance and other management issues. SummaryWhile NATA supports the change implemented by the FAA to Assurance 22, subparagraph a., the Association recommends adding language to clarify how the revised assurance can be implemented. Discussion of FAA Action The change implemented by the Agency on September 1, 1999, to Assurance 22a.:
Based on the experience of the NATA staff, one of the biggest challenges facing the airport operator’s responsibility to oversee aeronautical services is implementing and enforcing minimum standards in accordance with the Sponsor Assurances. The NATA Comments Airport Improvement Program Grant Assurances; Proposed Modifications and Opportunity to Comment
Association concurs with the City of Houston that the previous wording of Assurance 22a. implied an open-ended right for individuals or any other entity to offer services without regard to safety standards. NATA supports the recommendation made by the City of Houston that the Assurance should “require all parties engaging in aeronautical activity be qualified and meet applicable safety standards.” NATA RecommendationIn the Notice published in the Federal Register, the FAA stated, “Furthermore, the FAA believes that an airport sponsor’s minimum standards should reflect local safety requirements and quality of service requirements so long as these are reasonable, relevant to the activity, and applied without unjust discrimination.” NATA strongly agrees with the FAA’s statement. However, NATA requests that the FAA include the concept of this statement in the Sponsor Assurance. By doing so, the Agency could make it extremely clear to both airport sponsors and aviation businesses how it evaluates compliance with the economic nondiscrimination element of the Grant Assurances. In evaluating the experience of the NATA staff, nearly half of the inquiries we receive would be addressed by such a reference, while protecting the rights of those wanting to provide aeronautical activities from economic discrimination. Therefore, NATA recommends the following sentence be added to Assurance 22a.: “It may implement minimum standards that reflect local safety requirements and quality of service requirements so long as these are reasonable, relevant to the activity, and applied without unjust discrimination.” The Association appreciates the FAA’s interest in clarifying its intent in the Airport Improvement Program Grant Assurances. NATA urges the FAA to revise the Assurance that would enhance the Agency’s intent on nondiscrimination. Sincerely, Andrew V. Cebula Vice President Directory: data -> files -> GIA -> airport misc files -> Course Description files -> Short Term Consultancy-Design Engineers (3) Terms of Reference Organizational Background files -> Background airport misc -> What’s at Issue GIA -> President’s budget says cut aip funding, implement user fees february 6, 2008 What’s at Issue files -> Monitoring of Russian tv channels files -> Silver Bullet Solutions, Inc. Berger, Peter L, and Thomas Luckmann GIA -> Nata aircraft Maintenance & System Technology Committee Best Practices Download 10.3 Kb. Share with your friends:
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