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

Introduction


The 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.

Summary


While 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.:




  • Removes the reference to any person, firm, or corporation to conduct or engage in any aeronautical activity for furnishing services to the public at the airport and,

  • Replaces it with the reference to all types, kinds and classes of aeronautical activities, including commercial aeronautical activities offering services at the airport.

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

Page 2 of 2


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 Recommendation


In 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

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