FAA – Section 163 Docket, Document 0026 Attachment

1390 Chain Bridge Road– #A106 • McLean, VA 22101 (202) 925-1337 • www.nasao.org October 17, 2022 Mr. Kevin Willis Director, Office of Airport Compliance and Management Analysis Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 Re: Draft FAA Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land (Docket No. FAA-2022-1203) Dear Mr. Willis: On behalf of the National Association of State Aviation Officials (NASAO), I appreciate the opportunity to share these general comments and questions to the Federal Aviation Administration (FAA) in response to the Request for Comments on Draft FAA Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land, published on September 15, 2022. NASAO is the nationally recognized voice for the public interest in aviation on behalf of the states and territories. NASAO represents state officials of all 50 states, Guam, and Puerto Rico, who, as part of their many responsibilities, make decisions on funding aviation systems and airport infrastructure at our nation's more than 3,300 public-use airports. NASAO appreciates FAA’s efforts to clarify its policy on airport land use changes, however there are several questions and issues that should be addressed with stakeholders before a final policy is published: Lease Reviews • NASAO is concerned that the draft policy will require lengthy FAA reviews of all leases where such reviews do not currently exist. This could inadvertently encourage airport sponsors to create longer term leases, which may not necessarily be in the best interest of…
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