FAA – Section 163 Docket, Document 0014 Attachment

1200 New Jersey SE, Washington, DC 20590 RE: Comments on Docket Number FAA 2022-1203 To Whom it May Concern: Charlotte Douglas International Airport (CLT), owned and operated by the City of Charlotte, appreciates the opportunity to comment on the Draft Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land (the Policy). We read the Policy as an attempt to support the Federal Aviation Administration (FAA) in ensuring that airports continue to prioritize aeronautical development. That said, we believe that existing legal and regulatory requirements already enable airports to utilize non-aeronautical land for their benefit without jeopardizing future aeronautical development. Therefore, CLT asks the FAA to consider strengthening and clarifying existing practices and policies in lieu of enacting a new Policy. If the FAA does move forward, CLT asks the FAA to modify its Policy to explicitly acknowledge that airports’ non-aeronautical land development programs fulfill an important airport purpose not requiring FAA consent or approval beyond the provisions of Section 163. The FAA has, we hope inadvertently, narrowed the distinction between “non-aeronautical” and “airport purposes,” suggesting that only aeronautical land can serve an airport purpose. Any land the airport owns could, in theory, be used for an aeronautical purpose at some point in the future but the interim use designation does not solve the practical problems that the Policy could cause. The FAA should continue to support the practice of airports compatibly developing non- aeronautical land without creating major hurdles to accomplishing a mutually beneficial goal.…
V V