FAA – Section 163 Docket, Document 0027 Attachment

Office of Airport Compliance and Management Analysis Federal Aviation Administration 800 Independence Ave. SW Washington, D.C. 20591 RE: Federal Aviation Administration; Request for Comments Draft FAA Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land Docket No. FAA‐2022‐1203 (Sep. 15, 2022) Dear Mr. Willis: The American Association of Airport Executives (AAAE), the world’s largest professional organization for airport executives, appreciates the opportunity to provide its feedback and perspectives in response to the Federal Aviation Administration’s (FAA) request for comments on the notice, “Draft FAA Policy Regarding Processing Land Use Changes on Federally Acquired or Federally Conveyed Airport Land” (“Proposed Policy”) (87 Fed. Reg. 56,601 (Sep. 15, 2022).) As a representative of over 7,000 members from nearly 875 public‐use commercial service and general aviation airports, AAAE has heard significant concerns from its members that FAA’s Proposed Policy would inhibit non‐aeronautical land development, add significant time for executing leases and land‐related transactions, unnecessarily insert FAA into airport land use decision making, and result in the loss of airport revenue. We strongly urge FAA to reconsider this proposed framework and maintain existing policies that allow airports more flexibility in pursuing non‐aeronautical development projects on federally acquired or federally conveyed airport land, especially because FAA has not articulated any problem or concern that justifies such a significant change. The Proposed Policy Would Negatively Impact the Airport Industry and FAA Non‐aeronautical land development has become an increasingly important source of revenue for airports in recent years, especially as they have…
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